HomeMy WebLinkAboutAgenda Packet 1992/10/12 Jt. Planning Comm
Monday, October 12, 1992
6:00 p.m.
1.
ROll CALL:
"l deciare under penalty o~ perJury that I am
employed by the City of Chula Vista in the
Oilice of the Ci ty Clerk and that I posted
this AgenJ,,/,lolice on the Bulletin Board at ,
b~' S ,';)-'Buildin' and at ~_ Council Chambers
the Pu IC rv ~ /' P bl' S . B 'ld'
DATED, fa 7._ SIGNED "-- :I " U lC emces Ul mg
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Joint Meetin~ of the City of Chula Vista City Council
and the Plannins< Commission
CALL TO ORDER
Councilmembers Horton _, Malcolm _, Moore _, Rindone -' and Mayor
Nader _
Commissioners Carson -' Decker -' Fuller _, Martin _, Ray _, and Chair
Casillas _
2. PLEDGE OF AlLEGIANCE TO TIlE FLAG. SILENr PRAYER
PUBUC HEARINGS AND RELATED RESOLlJTIONS AND ORDINANCES
The foUowing items have been advertised and/or posted as publU: hemin&, as required by liJw. If you wish to speJJk
to any item, please fill out the "Request to Speak Form" available in the lobby and submit it to the City Clerk prior
to the meeting. (Complete the green form to speak in favor of the staff reconrnrendJlti complete the pink form
to speJJk in opposition to the' staff recornmendJJtimL) Comments are limited to five minutes per individual
3.
PUBUC HEARING
RESOLlJTION
CONSIDERATION OF TIlE DRAFT PROGRAM ENVIRONMENTAL IMPACf
REPORT FOR TIlE OTAY RANCH GENERAL PLAN AMENDMENTS AND
GENERALDEVELOPMENTPLAN/SUBREGIONALPLAN (SCH #89010154)-
It is recommended that the City Council and Planning Commission take
testimony on the adequacy of the Draft Program Environmental Impact
Report (PElR) and on the length of the public review period for this Draft
PElR. It is further recommended that the City Council set a date for close
of public review. Staff recommends approval of the resolution. (Tony
Lettieri)
ESTABUSHING PUBUC REVIEW PERIOD FOR TIlE DRAFT PROGRAM
ENVIRONMENTAL IMPACf REPORT ON TIlE OTAY RANCH GENERAL
PLAN AMENDMENTS AND GENERAL DEVELOPMENT
PLAN/SUBREGIONAL PLAN (SCH #89010154)
ORAL COMMUNICATIONS
This is an opportunity for the general publU: to address the City Coum:il on any subject matter within the Coum;jJ's
jurisdii:tion that is not an item on this agenda. (State liJw, however, generally prohibits the City Council from
taking action on any issues not included on the posted agenda.) If you wish to address the Council on such a
subjec~ please complete the yeUow "Request to Speak Under Oral Communications Form" available in the lobby
and submit it to the City Clerk prior to the meeting. Those who wish to speIlk, please give your 1lIlme and address
for record purposes and foHow up action. Your time is limited to three minutes per speaker.
Agenda
-2-
October 12, 1992
OTIIER BUSINESS
4. CI1Y MANAGER'S AND DIRECfOR'S REPORTCS)
5. MAYOR'S AND CHAIR'S REPORT(S)
6. COUNCIL'S AND COMMISSIONER'S COMMENTS
ADJOURNMENT
The meeting will adjourn to the Regular City Council Meeting on October 13, 1992 at 6:00 p.m. in the City
Council Chambers and to the Regular Planning Commission Meeting on October 14, 1992 at 7:00 p.m. in
the City Council Chambers.
COUNCIL AGENDA STATEMENT
Agenda Item
Meeting Date
-'3
lO/U/92
ITEM TITLE:
Public Hearing Consideration of the Draft Program Environmental Impact Report
for the Otay Ranch General Plan Amendments and General Development Plan/
Subregional Plan (SCH #89010154)
SUBMITTED BY:
Resolution Establishing Public Review Period for the Draft Program
Environmental Impact Report on the Otay Ranch General Plan Amendments and
General Development Plan/Subregional Plan (SCH #89010154)
(]v-
Anthony J. Lettieri, AICP, Otay Ranch General Manager
REVIEWED BY:
City Manager If
t
(4/5th Vole: Yes_NoX)
RECOMMENDATION:
This is a continuation of the Planning Commission Hearings of September 16 and October 7, 1992. It is
recommended that the City Council and Planning Commission take testimony on the adequacy of the Draft
Program Environmental Impact Report (PEIR) and on the length of the public review period for this Draft
PEIR. It is further recommended that the City Council set a date for close of public review.
BOARDS/COMMISSIONS RECOMMENDATIONS:
The Planning Commission has taken no action regarding the Draft PEIR. The Commission did pass a motion
recommending a 60-day extension (from October 7, 1992) of the public review period.
The Resource Conservation Commission will be meeting on these subjects on October 5, 1992. A verbal
presentation will be given at your meeting.
See Attachment A for letters of comment on the Draft PEIR.
A. DISCUSSION: PUBUC REVIEW PERIOD
The State CEQA Guidelines provides that "The public review period for a draft EIR should be not less than 30
days nor longer than 90 days, except in unusual circumstances." [Section 15105 (n)]
The Council initially established a 6O-day review period. However, because of the Planning Commission meeting
schedule, a tentative end of the public review period was set for the joint Planning Commission meeting of
October 7, 1992, a 69-day review period. The Board of Supervisors and Council met on September 24, 1992, at
which time the Board recommended that the Council extend public review and deferred to the Council, as Lead
Agency, regarding the length of that time extension. The Council scheduled this joint meeting with the Chula
Vista Planning Commission to discuss the issue.
The revised environmental review procedures also provides the Council with the alternative of assuming the
public hearing duty. This would exclude the Planning Commission from further participation in the preparation
of the environmental documents for this project. They would have to review and consider the Final PEIR for
this project before making a recommendation to the Council.
Attachment C to this staff report are the letters requesting an extension of the review period beyond October
7, 1992. Also in this attachment is an excerpt from the draft minutes of the September 16, 1992 joint meeting
of the Planning Commissions dealing with the issue of time extension.
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B. DISCUSSION:
Role of Chula Vista and Countv Planninl! Commissions
As required by the City of Chula Vista's.environmental review guidelines, the
Planning Commission shall hold a public hearing to take testimony on the adequacy of the
draft EIR. For the County of San Diego this hearing will function as a workshop and no
action will be taken by the County Planning Commission.
Summarv of CEOA Process To Date
In an effort to coordinate the evaluation of the Otay Ranch Project, joint planning
and concurrent processing of the project is being conducted by the City of Chula Vista and
and the County of San Diego. Both jurisdictions have entered into a Memorandum of
Understanding (MOU) and have established a Joint Project Planning Team to process the
required plans and environmental documentation. The City of Chula Vista has been
designated as the lead agency responsible for the preparation of environmental
documentation and for coordination with the County of San Diego and with the
Interjurisdictional Task Force. The County of San Diego, as a responsible agency, has
also provided direction in the preparation of the EIR. Cooperating agencies involved in the
environmental review process include the City of San Diego, County of San Diego Air
Pollution Control District, San Diego Association of Governments, Metropolitan Transit
Development Board and San Diego Local Agency Formation Commission.
The Interjurisdictional Task Force established by the MOU consists of elected and
appointed representatives from the City of Chula Vista, City of San Diego, and the County
of San Diego. The Interjurisdictional Task Force's primary role has been to set policy in
the development of project alternatives.
The City of Chula Vista circulated a Notice of Preparation (NOP), dated
November 9, 1989, to all responsible agencies, interested groups, and individuals to
solicit comments on the preliminary contents of the EIR. In response to a request by
LAFCO, the City of Chula Vista circulated a revised NOP dated December 13, 1989 to
provide additional information about the proposed project. All comments received during
the NOP review have been considered during the preparation of the EIR.
A public scoping meeting was held by the City of Chula Vista on October 26, 1989
to solicit public input to the issues associated with the Otay Ranch Project. The public
comments received during the scoping process were considered in the environmental
analyses presented in the EIR. Prior to the release of the Draft EIR for public review, three
public site visits, including oil-road tours, were conducted to present to the Planning
Commission the project in the context of the natural resources on the property.
The Draft EIR was issued for public review by the City of Chula Vista on July 31,
1992 for a period of 60 days. Although CEQA requires a 45-day public review period for
EIRs submitted to the State Clearinghouse, the City of Chula Vista and County of San
Diego jointly agreed to at least a 60-day review period for the Otay Ranch EIR. Written
comments and public testimony at noticed public 'hearings addressing the adequacy of the
Draft EIR will be accepted by the City of Chula Vista until the close of the public hearing
scheduled to occur on October 7, 1992.
Under the direction from City of Chula Vista and County of San Diego staff, Ogden
will prepare written responses to all written comments and public testimony received from
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public agencies, interested parties, and private individuals during Draft EIR circulation and
at the public hearing on the Draft EIR. Report revisions related to public review comments
will also be completed, as appropriate. Responses along with public review comments will
be appended to the EIR as part of the Final EIR.
Discretionarv ADDrovals
The proposed Otay Ranch Project requires the following discretionary approvals by
the City of Chula Vista and the County of San Diego:
. Resource Management Plan - City of Chula Vista and County of San Diego
. General Plan Amendment - City of Chula Vista and County of San Diego
. Subregional Plan - County of San Diego
. Prezoning - City of Chula Vista
. Rezone - County of San Diego
. General Development Plan - City of Chula Vista
. ServicelRevenue Plan - City of Chula Vista and County of San Diego
. Property Tax Agreement - City of Chula Vista and County of San Diego
Development Agreement - City of Chula Vista
. Public Benefit Agreement - County of San Diego
. Phasing Plan - City of Chula Vista and County of San Diego
. Public Facility Implementation Plans - City of Chula Vista and County of San
Diego
The above discretionary approvals are covered by this Program ElR. There will be other
discretionary actions in the future requiring subsequent environmental review.
EIR Comments Received to Date
Since issuance of the Otay Ranch Draft Program EIR for public review on July 31,
1992, the City of Chula Vista has received five comment letters (see Attachment A) from
organizations and individuals. Comment letters have been received from:
. San Diego County Office of Education (dated August 7, 1992)
. City of Chula Vista Parks and Recreation Department (dated August 28, 1992)
. City ofChula Vista Fire Department (dated August 20,1992)
. County of San Diego Flood Control (dated August 27, 1992)
. City of Chula Vista Engineering Division (dated September I, 1992)
Pro Dosed Proiect
Otay Ranch is located in southwestern San Diego County approximately 3.5 miles
east of downtown Chula Vista and 14 miles southeast of downtown San Diego. The
southern boundary of Otay Ranch is approximately 2 miles north of the United States-
Mexico international border. The property spans an approximate distance of 12 miles from
the Chula Vista city limits on the west to State Route 94 (Campo Road) on the east; the
property spans approximately 8.5 miles from north to south.
In order to accurately evaluate the effects of developing over 23,000 acres of land
with a new community, the property was grouped by the project applicant into three
geographically distinct areas or parcels: the Otay River parcel, containing the portion of the
site adjacent to eastern Chula Vista; the Proctor Valley parcel, corresponding to the northern
portion of the site surrounding the Jamul Mountains; and the San Ysidro parcel,
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encompassing the land in the San Ysidro Mountains. This approach allowed the Draft ErR
to analyze both broad and parcel-specific impacts of the Otay Ranch Project.
The New Town Plan submitted by Baldwin Vista Associates contains both a land
use plan and policy language developed to guide the long-term development of the 23,088-
acre property. The land use plan proposes a mix ofresidential neighborhoods, commercial
centers, research-oriented industrial uses, natural open spaces, recreational parks, a civic
center, art centers, resort facilities, a town center, and a university site. The plan envisions
a series of villages or clusters of development within a cohesively planned community. See
Attachment B for a more detailed description of the proposed project.
Summarv of EIR Document
The size, complexity and nature of the Otay Ranch Project required special considerations
and comprehensive analyses during the preparation of the Program EIR as discussed
below.
Prowam EIR
A Program ElR was prepared on the Otay Ranch project to evaluate the
environmental effects that could be expected from overall plan adoption, allowing the
subsequent EIRs on SPA Plans and Tentative Maps to focus on the environmental effects
of specific development proposals. A Program EIR for Otay Ranch provides an
opportunity to evaluate a more complete range of project alternatives, ensures a thorough
analysis of cumulative project effects, avoids duplication of basic policy considerations,
and allows the lead agency and responsible agencies to consider broad policy alternatives
and program-wide mitigation measures early in the process.
Public Services
Because of the regional impacts of the Otay Ranch Project, the public services and
utilities analysis in the Program ElR was greatly expanded to provide a comprehensive
evaluation of all public services potentially affected by the long-term buildout of the project.
For example, in addition to the typical public services (such as water, sewer, waste
management, police, fire, emergency services, schools, libraries, parks, and utilities), the
analysis was expanded to include mental health facilities, community clinics, and other
non-hospital medical institutions, government social services, non-profit charitable
organizations, home healthcare, senior services, cemeteries, child care, and animal control.
Cumulative Impact Assessment
The cumulative impact assessment for Otay Ranch considered the interrelated
impacts of other developments in proximity to the proposed project. In an effort to provide
a comprehensive regional analysis of cumulative impacts, the City of Chula Vista, City of
San Diego, and County of San Diego provided lists of current and anticipated projects in
southwestern San Diego County. Cumulative area statistics derived from the EIRs (e.g.,
number of dwelling units, amount of open space, acres of impact) were compiled to
determine the extent and degree of development anticipated in the project area over the long-
term. Three project alternatives were evaluated with respect to other developments: New
Town Plan, Phase I-Progress Plan, and Environmental Alternative. Cumulatively
significant impacts were identified for: land use, landform alteration/aesthetics, biology,
cultural resources, paleontology, agricultural resources, mineral resources, water
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resources, water quality, transportation/circulation/access, air quality, noise, and public
services.
Indirect Impacts of Offsite Roadway Improvements
Certain transportation and circulation impacts identified for the Omy Ranch Project
would require offsite roadway improvements for mitigation. Since the road improvements
would involve the widening or extension of several segments beyond what was previously
approved and planned, additional secondary impacts to biological resources, cultural
resources, existing and planned land uses, landforms and visual resources are anticipated.
A constraints-level evaluation of these indirect impacts was conducted for offsite roadway
improvements required to mitigate impacts of the New Town Plan, Phase I-Progress Plan,
and Environmental Alternative.
Southwest County Landfill Site Analyses
The County of San Diego is currently conducting engineering and environmental
impact analyses for the development of new Class III municipal landfill sites in the
southwestern portion of the county. Two of the three candidate sites under study are
located on the Otay River parcel of Otay Ranch. Although none of the alternatives for the
Omy Ranch Project includes a landfill site, the Program EIR evaluated the potential impacts
of a landfill on proposed development if either or both of the sites were selected by the
county. The qualitative discussion considers the same environmental issues evaluated for
the Otay Ranch Project.
Analyses of Alternatives
The EIR evaluated eight alternatives to the proposed project, including the No
Project Alternative. They are presented in the document in order of decreasing density,
with the exception of the Phase II-Progress Plan Alternative, which was added during the
course of the latter stages of environmental analyses. Each issue area is discussed under
each alternative. In order to identify the full range of environmental impacts anticipated
under the various project alternatives, the environmental impacts of the Phase I-Progress
Plan and the Environmental Alternative are analyzed in equal detail to the New Town Plan.
These three scenarios represent the high (New Town Plan), middle (Phase I-Progress
Plan), and low (Environmental) ends of development with respect to residential density and
area of disturbance. The impacts of the remaining alternatives are discussed in a qualitative
manner, as they fall within the range of the three quantified impact scenarios.
One of the eight alternatives evaluated in the EIR is the Composite General Plans
Alternative. The Interjurisdictional Task Force agreed that the City of Chula Vista General
Plan would be used as the basis for evaluation of the Otay River parcel, and the County of
San Diego General Plan would form the basis for evaluation of the Proctor Valley and San
Ysidro parcels. A comparison of project impacts with those already anticipated under
approved planned development is presented in the evaluation of the Composite General
Plans Alternative where appropriate, particularly the traffic analyses for the various other
alternatives. See Attachment B for a more detailed description of project alternatives.
Offsite Alternatives
In compliance with CEQA, offsite alternatives were selected for analysis in this
EIR. Four alternatives were identified and analyzed to assess their potential to eliminate or
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minimize significant impacts in comparison to the proposed project. See Attachment B for
a description of offsite alternatives.
Environmental Data Collection
Baldwin Vista Associates initiated baseline resource studies on Otay Ranch in 1989.
These studies have evaluated overall biological resources, sensitive plant and animal
species, and vernal pools. A preliminary geotechnical investigation and hazardous
contamination study were other products generated in the early stages of project planning.
Separate studies have been conducted for water resources infrastructure, including urban
runoff protection for Lower Otay Reservoir, draft master plans for reclaimed water, potable
water and sewer service, and a drainage study. A long-range master plan for educational
facilities was prepared along with implementation plans for all public facility needs of the
Otay Ranch Project. This comprehensive set of baseline environmental data was
supplemented by more recent environmental studies to fill data gaps during the
environmental impact assessment of the Otay Ranch Project.
Mapped environmental resources were digitally input into a Geographic Information
System (GIS) and supplemented by data collected during the additional studies. Digital
overlays of the three quantitatively evaluated alternatives were conducted to accurately
assess project impacts, where appropriate. ErR technical reports were prepared evaluating
cultural resources, biological resources, and traffic and circulation. Additional biological
studies were conducted in conjunction with the preparation of the Resource Management
Plan (RMP), which is designed to provide management policies and guidelines for the
onsite open space preserve and to replace the County's Resource Protection Ordinance.
The ErR studies included a comprehensive wildlife corridor study and a raptor management
study.
The Draft Program EIR incorporates and references all study results pertaining to
the proposed project and the alternatives.
Summarv of the Environmental [moaet Analvsis
As described above, a comprehensive environmental impact analysis of nine
development plans was conducted for the Oray Ranch Program EIR. Table A presents a
comparison of the significant unmitigable impacts associated with each alternative. This
table addresses impacts which are: I) significant and not mitigated at this level of analysis
(S) or 2) significant and unmitigable (SUM) at any level of analysis for one or more of the
project alternatives.
The following is a summary of the key significant unmitigable impacts that would
occur with the development of Otay Ranch under many of the alternatives noted below. As
indicated in Table A, the degree of impact would vary by alternative.
Land Use Planning, and Zoning
I. Inconsistency with the Jamul-Dulzura Subregional Plan due to the extension of
the CUDA adjacent to Jamul. This impact would occur with the New Town
Plan, Phase I-Progress Plan, and Phase II-Progress Plan due to the nature of
development in the Proctor Valley and San Y sidro parcels.
2. Inconsistency with Chula Vista goals regarding low-medium density
development as the primary land use in the Eastern Territories. The New Town
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Plan, Phase I-Progress Plan, and Phase II-Progress Plan would result in this
impact due to the amount of higher density residential development proposed
for these alternatives.
3. Conversion of the site's character from undeveloped open space to developed
land. All of the alternatives except the No Project Alternative would result in
this impact; under the Environmental Alternative, this impact would be limited
to the Otay River parcel.
4. Inconsistency with Chula Vista's goal for a university. The Fourth Alternative
does not propose a university site on Otay Ranch.
Landform Alteration/Aesthetics
I, Alteration of significant or sensitive landforms, All of the alternatives except
the Environmental and No Project Alternatives would result in this impact;
however, the impact would be unmitigable only with development of the New
Town Plan or the Phase I-Progress Plan.
2. Change in overall visual character of the project area from open space to
developed land. All of the alternatives except the No Project Alternative would
result in this significant unmitigable impact; under the Environmental
Alternative, this impact would be limited to the Otay River parcel.
3. Development in highly visible areas. This impact would occur under all of the
alternatives except the No Project Alternative; this impact would be unmitigable
only for the New Town Plan.
Biolo~y
I. Disturbance to senS1l1ve uplands, wetlands, and vernal pool habitat. The
impacts to these habitats would vary widely among the alternatives. The acres
of coastal sage scrub and maritime succulent scrub habitats affected would
range from approximately 6,400 acres for the New Town Plan to 4,400 for the
Phase I-Progress Plan, 2,300 for the Phase !I-Progress Plan, and 1,700 for the
Environmental Alternative.
The wetlands impacts would range from approximately 640 acres for the new
Town Plan to 70 for the Phase I-Progress Plan, 50 for the Phase II-Progress
Plan, and 30 for the Environmental Alternative.
Vernal pool impacts would range from approximately 130 acres for the new
Town Plan to 10 acres for the Phase I-Progress Plan and Phase II-Progress
Plan, and less than I acre for the Environmental Alternative.
These habitat impacts are all considered significant and unmitigable with the
exception of the impacts associated with the Environmental Alternative which
are mitigable to below a level of significance.
2. Impacts to high-priority plant species. The number of high-priority plant
species would vary from seven species for the New Town Plan to six for the
Phase I-Progress Plan, three for the Phase !I-Progress Plan, and two for the
Environmental Alternative.
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3. Impacts to least Bell's vireo, coastal cactus wren, and California gnatcatcher.
The impacts to least Bell's vireo would range from lOa percent of their points
of occurrence on Otay Ranch for the new Town Plan to 13 percent for the
Phase I-Progress Plan and Phase II-Progress Plan, and zero for the
Environmental Alternative. Only the New Town Plan impacts are considered
unmitigable.
The percentage of coastal cactus wren locations impacted would range from
72 percent for the new Town Plan to 45 percent for the Phase I-Progress
Plan, 42 percent for the Phase II-Progress Plan, and 18 percent for the
Environmental Alternative. The impacts from the New Town Plan, Phase 1-
Progress Plan, and Phase II-Progress Plan are considered unmitigable.
The impacts to coastal cactus wren locations would range from 66 percent for
the New Town Plan to 49 percent for the Phase I-Progress Plan, 43 percent for
the Phase II-Progress Plan, and IS percent for the Environmental Alternative.
The New Town Plan, Phase I-Progress Plan, and Phase II-Progress Plan
impacts are considered unmitigable.
4. Impacts to Riverside fairy shrimp and Quino checkerspot. The impacts to these
sensitive species are considered significant for all of the alternatives except the
Environmental and No Project Alternatives. The impacts are potentially
mitigable at a subsequent level of analysis.
5. Impacts to regional raptor populations. These impacts would be significant and
unmitigable for all of the alternatives except the Environmental, for which the
impacts would be significant and mitigable, and the No Project Alternatives for
which the impacts would not be significant.
6. Impacts to regional wildlife corridors. The New Town Plan would impact all
thirteen regional wildlife corridors. Eight corridors would be blocked by
development and five would be constrained by adjacent development and/or
major road crossings. The Phase I-Progress Plan would impact twelve
regional corridors whereas the Phase II-Progress Plan would impact ten
regional corridors. Under the Phase I-Progress Plan, three corridors would be
blocked by development and nine could be constrained by adjacent development
and/or major road crossings. The Phase II-Progress Plan would block four
regional corridors with development or manufactured open space. Another six
corridors could be constrained by development and/or major road crossings.
The Environmental Alternative would not block any regional corridors;
however, seven regional corridors could be impacted by major road crossings
and one corridor could be constrained by adjacent development. The No
Project Alternative would not block or significantly impact any existing regional
corridors. Impacts to regional wildlife corridors would be significant and
unmitigable under the New Town and Phase I-Progress Plans. Impacts to
regional corridors under the Environmental and Phase II-Progress Plans would
be significant but mitigable. Although the Phase II-Progress Plan blocks four
regional corridors, changing the manufactured open space designations in two
corridors to natural open space would partially mitigate impacts to these two
corridors under this plan.
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Cultural Resources
1. Disturbance of significant prehistoric and historic resources. All of the
alternatives except the No Project Alternative would result in significant impacts
to cultural resources. The number of known sites impacted would vary by
alternative; however, the implementation of an approved mitigation plan would
avoid significant impacts for all alternatives.
A!!ricultural Resources
1. Conversion of farmlands and elimination of existing crop production. All of the
alternatives except the No Project Alternative would result in this impact.
2. Inconsistency with existing County of San Diego and City of Chula Vista
agricultural plans and policies. All of the alternatives except the No Project
Alternative would result in this impact.
3. Agricultural conversion pressures due to indirect growth-inducing impacts.
This impact would occur under all alternatives except the Composite General
Plans and No Project Alternatives.
Mineral Resources
1. The potential preclusion of mineral extraction activities on Rock Mountain.
This impact would occur for all alternatives except the Composite General
Plans, Low Density, and No Project Alternatives; however, the impact is
mitigable for all alternatives with the phasing of development to enable prior
extraction of the mineral resources.
2. The potential conflict with future mineral resource extraction. This impact
would be significant for all alternatives except the Composite General Plans and
No Project Alternative; however, the impact is mitigable for all development
alternatives with the phasing of development to enable prior extraction of the
mineral resources.
Traffic
1. Impacts to road segments due to increased traffic. The total number of roadway
miles (onsite and offsite) impacted by the development of Otay Ranch would
range from approximately 54 miles under the New Town Plan to 52 miles for
the Phase I-Progress Plan, 37 for the Phase II-Progress Plan, and 24 for the
Environmental Alternative (see Table A for the other alternatives). Of these
totals approximately 24 miles of offsite roadway miles remain significant and
unmitigable at this level of analysis for the new Town Plan, compared to 23 for
the Phase I-Progress Plan, 14 for the Phase II-Progress Plan, and 11 for the
Environmental Alternatives, respectively; these impacts may be mitigable at the
SPA Plan level depending upon project design. No onsite roads were
determined to be significant and unmitigable at this level of analysis for any of
the project alternatives.
The number of offsite miles of roadway determined to be significant and
unmitigable at subsequent levels of analysis would range from approximately 5
for the New Town Plan, 4 for the Phase I-Progress Plan, I for the Phase II-
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Progress Plan, and 0.1 for the Composite General Plans, Environmental, and
No Project Alternatives. There would be no significant unmitigable impacts to
onsite road segments from any of the Otay Ranch development plans.
AirOuality
I. Exceedance of the current State Implementation Plan (SIP) air quality attainment
regulations. This impact would be significant for all alternatives except the
Environmental and the No Project Alternatives.
2. Potential increase in federal and state ozone standard violations due to project
emissions of nitrogen oxides, reactive organic gases, carbon monoxide, and
stationary sources. The total estimated emissions in the year 2020 would range
from approximately 28,900 tons per year for the New Town Plan to 20,500 for
the Phase I-Progress Plan and 5,400 for the Environmental Alternative.
Noise
1. Exceedance of 60 dBA CNEL noise standard. Noise impacts would result
from increased traffic on onsite and offsite roads; offsite land uses, including
the Nelson Sloan and Daley quarries, the Otay Landfill, and the San Diego Air
Sports Center; and onsite industrial activities. These impacts would occur
under all of the Otay Ranch development alternatives; the impacts are potentially
mitigable at the SPA Plan level depending upon project design.
2. Indirect roadway and construction impacts on least Bell's vireo habitat. These
impacts would occur under all of the Otay Ranch development alternatives;
these impacts are potentially mitigable at the SPA Plan level.
Significant impacts would occur to the following resources; however, these impacts
would be mitigable to below a level of significance (SM).
Geology and Soils
Site-specific geotechnical studies and subsequent implementation of recommended
design and construction techniques shall be required to mitigate potential impacts.
Paleontolo~ical Resources
Construction monitoring and subsequent recovery of identified fossils shall be
required to mitigate potential impacts to paleontological resources.
Water Resources and Water Ouality
Site-specific studies to determine the required design for bridges, culverts, and
other facilities and subsequent implementation of the design recommendations shall
be required to mitigate potential impacts to surface water and ground water.
Public Services and Utilities
With the provision of adequate facilities and services for the population associated
with each alternative, these impacts would be reduced to below a level of
significance.
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Risk of Upset
Adherence to applicable regulations for the transport, use, storage, and disposal of
hazardous materials shall mitigate health risks to below a level of significance.
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Table A
COMPARISON OF SIGNIFICANT IMPACTS
PROPOSED PROJECT AND PROJECT ALTERNATIVES
Project
Potential New Town Phase 1- Phase II- Fourth Team COffijX)sile Low Density Environmental No Project
Impact Plan Progress Plan Progress Plan Ahemative Ahemalive General Plans Alternative Alternative Alternative
I and Use Planninl~ and
~,
Change in Open Space SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
Character of the Site
Incompatible with Oay Annex S/M S/M S/M S/M NS NS S NS NS
Landfill
Incompatible with San Diego S/M S S S S NS S S NS
Air Sports Center
Incompatibility with internal S/M S/M S S S NS S S/M NS
>---- project land uses on Olay River
"'~ "",eel
Inconsistent with County SlUM SlUM SlUM SlUM SlUM NS NS NS NS
Goals re: Rural Lands
Inconsistent with City of San NS NS NS NS NS NS NS S NS
Diego Industrial Goals
Inconsistent with Chuta Vista S S S S S NS NS NS NS
Goals re: Low-mediwn
Density
Inconsistent with Chula Vista NS S/M S/M S S NS NS SlUM S/M
Goals re: University Site
'.andform Alterationl
Aesthetics:
Change in Visual Character of SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
Project Area
Alteration of Significant or SlUM SlUM S/M S/M S/M S/M S/M NS NS
Sensitive Landforms
Impacts in Highly Visible SlUM S/M S/M S/M S/M S/M S/M S/M NS
An'"
North of Lower Otay Lake SlUM S/M S/M S/M S/M NS S/M S/M NS
,
Soulhweslcm Part of San SlUM S/M SIM S/M S/M S/M S/M NS NS
Ysidro Parcel
Table A (Continued)
COMPARISON OF SIGNIFICANT IMPACTS
PROPOSED PROJECT AND PROJECT ALTERNATIVES
Project
Potential New Town Phase I - Phase II- Fourth Team Composite Low Density Environmental No Project
Impact Plan Progress Plan Progress Plan Alternative Alternative General Plans Alternative Alternative Ahemalive
North/Nonheastem lamul SlUM S/M S/M S/M S/M NS S/M NS NS
Foothills
Biolof!ical Resources;
Total Acres of Habitat SlUM SlUM SlUM SlUM SlUM SlUM SlUM S/M NS
Impacted 15,428 12,054 10,496 9,383 9,646 N/A 9,631 6,109 0
(66%) (52%) (46%) (41%) (42%) (42%) (27%)
Acres of Coastal Sage Scrub SlUM SlUM SlUM SlUM SlUM SlUM SlUM S/M NS
and Maritime Succulent Scrub 6,412 4,385 2,309 <32% < 32% N/A < 32% 1,729 0
'>', Communities hnpacted (56%) (38%) (21%) (15%)
U" Acres of Needlegrass SlUM SlUM SlUM SlUM SlUM SlUM S/M NS
Grassland Impacted 252 223 172 < 65% < 65% N/A < 65% 100 0
(95%) (85%) (65%) (38%)
Acres of Wetlands Impacted SlUM SlUM' S/UM4 SlUM4 SlUM4 SlUM4 S/M NS
638 73 51 5,10% 5-10% N/A 5-10% 28 0
(82%) (9%) (7%) (4%)
Acres of Vernal Pool Habitat SlUM SlUM SlUM S/M SIUMI SlUM I S/M S/M NS
Impacted 128 14 14 <8% <8% <8% <1% 0
(72%) (8%) (<8%)
Acres of Soulhem Interior SlUM S/M S/M S/M S/M S/M S/M NS NS
Cypress Forest and Coast Live 25 7 16 N/A N/A N/A N/A 0 0
Oak Woodland Habitat (7%) (2%) (5%) (<3%) (<3%) N/A (<3%)
Impacted
No. of High Priority Plant 7 6 3 5 5 N/A 5 2 NS
Species Significantly Impacted 0
Percent Least Bell's Vireo SlUM S/M S/M S/M S/M S/M S/M NS NS
Points of Occurrence Directly 100% 13% 13% 25% 25% 50% 12.5% 0 0
Impacted By Habitat Loss
Indirect Noise Impacts on Least S S S S S S S S NS
Bell's Vireo Habitat
Percent Coastal Cactus Wren SlUM SlUM SlUM SlUM SlUM SlUM SlUM S/M NS
Locations Impacted: 72% 45% 42'1'0 38% 38% 65% 30% 18%
Percent California Gnatcatcher S/[;~ SlUM S/LM S~JM S~JM SMM SlUM SIM NS
Locations Impacted 66% 49% 43% 42% 42% 56%2 38% 15%
Table A (Continued)
COMPARISON OF SIGNIFICANT IMPACTS
PROPOSED PROJECT AND PROJECT ALTERNATIVES
Project
Potential New Town Phase J- Phase Il- Fourth Toam Composite Low Density Environmental No Project
Impact Plan Progress Plan Progress Plan Alternative Alternative General Plans Alternative Alternative Alternative
Impacts to Riverside Fairy S S S S S S S NS NS
Shrimp
Impacts to Quina Checkerspol S S S S S S S NS NS
Impacts to Regional Raptor SlUM SlUM SlUM SlUM SlUM SlUM SlUM S/M NS
Populations
No. of Regional Wildlife SlUM SlUM S/M S/M S/M S/M NS NS
Corridors Bloded 8 3 4 3 2 33 2 0 0
No. of other regional wildlife SlUM SlUM S/M S/M S/M S/M SIM NS
"- corridors potentially impacted, 5 9 6 8 8 23 8 8 0
~ consLrained, or indireclly
impacted
Wildlife impacts to oilier SlUM SlUM SlUM S S S S SIM NS
sensitive species
Cultural Resources:
N:o. of Prehistoric Sites S S S S S S S S NS
hnpaded 186 150 133 134 135 51 131 82 0
No. of Historic Sites Impacted S S S S S S S S NS
43 24 18 25 25 9 27 14 0
No. of PrehistoriclHistoric S S S S S S S S NS
Sites Impacted 28 28 22 24 26 6 27 6 0
Al!ricultural Resources:
Conversion of Prime Agricul- SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
ural Soils to Development or
Open Space
Loss of County Agricultural SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
Land and Land Suitable for
Production of Coastal-
Dc~ndCnl Crops
Inconsistent with Counly SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
ZoninglLand Use Designations
Which Designate Olay Ranch
for Agricultural Uses
Table A (Conlinued)
COMPARISON OF SIGNIFICANT IMPACTS
PROPOSED PROJECT AND PROJECT ALTERNATIVES
Project
Potential New Town Phase 1- Phase 11- Fourth Team Composite Low Density Envirorunental No Project
Impact Plan Progress Plan Progress Plan Alternative Alternative General Plans Alternative Alternative Alternative
Inconsistent with Chula Vista SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
Open Space and Conservation
Element which Calls for Pres-
ervation of Agricultural Land
Indirect, Growth-Inducing SlUM SlUM SlUM SlUM SlUM NS SlUM SlUM NS
Effects Resulting in
Agricultural Conversion
Mineral Resources;
Preclusion of Mineral S S S S S NS NS S NS
Extraction Activities on Rock
G Mountain
\ Proposed Land Uses could S S S S S NS S S NS
Conflict with Future Mineral
Resource Extraction
TransDOrtation: Standard Village
Assumntion lli>Wl
Total Impacted Roadway Miles 54.18 52.DO 51.58 36.50 44 36 26.24 30 24.22 28.21
(LOS 0 or E) 24.23 (S) 23.01 (S) 23.01 (S) 13.52 (S) 11.73 (S) 10.78 (S)
5.09 (SlUM) 3.81 (SlUM) 3.81 (SlUM) 1.37 (SlUM) 0.11 (SlUM) 0.11 (SlUM) 9.63 (S)
0.13 (SlUM)
TOlallnterseclions 18 15 13 10 8 10 8 9 3 4
2 (S) 4 (S) 4 (S) 2 (S) o (S) o (S) O(S)
o (SlUM) o (SlUM) o (SlUM) o (SlUM) o (SlUM) o (SlUM) o (SlUM)
Air Oualitv:
Increase of Pollutant SlUM SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS
Emissions in the Regional 28,907 lons/year 20,552 lonslyear 5,422 lonslyear
Airshed (Year 2(20) (YOM 2(20) (year 2020)
Inconsistent wilh SIP SlUM SlUM SlUM SlUM SlUM SlUM SlUM NS NS
~:
Onsite Roadway Noise Grealer S S S S S S S S NS
than 60 CNEL within Fulure
Residential Areas
Table A (Continued)
COMPARISON OF SIGNIFICANT IMPACTS
PROPOSED PROJECT AND PROJECT ALTERNATIVES
Potential
Impact
Project
New Town Phase 1 - Phase 11- Fourth Team Composite Low Density Environmental No Project
Plan Progress Plan Progress Plan Alternative Alternative General Plans Alternative Ahemalive Alternative
S S S s. S S S S NS
S S S S S S S S NS
Increase in Roadway Noise
Affecting Existing Offsite
Noise Sensitive Receptors
Potential Noise Impacts to
Future Residents from Rock
Quarries, Landfill, SD Air
Sports Center, and Industrial
Activities
Indirect Noise Impacts on Least
Bell's Vireo Habitat
s
S
S
S
S
S
S
S
NS
"~
~.
Notes:
NS
S
SIM
SlUM
N/A
,
\
~
~
Not significant.
Significant and not miligaled at this level of analysis. Future environmental analysis will be required al the SPA Plan level 10 determine the significance and to identify mitigalion requirements.
Significant and miligable
Significant and unmitigable
The impacts were nol quantified for these allernatives; the impacts would fall within the range of impacts of the Phase I.Progress Plan Alternative and the Environmental Alternative.
J
2
3
4
OlaY Mesa vernal pool groups 123, 124, and 125 are designated as Parks and Recreation; all others on Olay Mesa are designated as Residential.
Includes only impacts 10 populalions in the Oay River parcel; does not include impacts to populations in the San Ysidro ll1ld Proclor Valley parcels
Applies only to Otay River parlA:1.
Alkali meadow impacts are unmitigable al this level of analysis. All other wetland impacts are mitigable.
A TT ACHMENT A
LETTERS OF COMMENT
ON DRAFT EIR ADEQUACY
RECEIVED TO DATE
17
STATE OF CALIFORNIA
PETE WilSON. Governor
GOVERNOR'S OFFICE OF PLANNING AND RESEARCH
1400 TENTH STREET
SAC~NI9' ,CA:I.~'911
DOUGLAS D. REID
OTAY RANCH PLANNING TEAM
315 FOURTH AVENUE, SUITE A
CHULA VISTA, CA 92010
'~~~-L~ (~-(~-!~'-~l.7-~~-:~
,ij))i-----.-~!j ii,
F~I' SEP 21 ,:/!i
111\ 'I I:'
.11 I Il ) J'
iU I 11.;/ I
. ./
@iJf""'.'""
.... "
. .
. .
'. ,~
- ~_. '
. ..~..,
Subject: OTAY RANCH
SCH # 89010154
Dear DOUGLAS D. REID:
The State Clearinghouse has submitted the above named draft
Environmental Impact Report (EIR) to selected state agencies for review.
The review period is now closed and the comments from the responding
agency(ies) is(are) enclosed. On the enclosed Notice of Completion form
you will note that the Clearinghouse has checked the agencies that have
commented. Please review the Notice of Completion to ensure that your
comment package is complete. If the comment package is not in order,
please notify the State Clearinghouse immediately. Remember to refer to
the project's eight-digit State Clearinghouse number so that we may
respond promptly.
Please note that Section 21104 of the California Public Resources
Code required that:
"a responsible agency or other public agency shall only make
substantive comments regarding those activities involved in a
project which are within an area of expertise of the agency or
which are required to be carried out or approved by the agency."
Commenting agencies are also required by this section to support
their comments with specific documentation. These comments are forwarded
for your use in preparing your final EIR. Should you need more
information or clarification, we recommend that you contact the
commenting agency(ies).
This letter acknowledges that you have complied with the State
Clearinghouse review requirements for draft environmental documents,
pursuant to the California Environmental Quality Act. Please contact
Tom Loftus at (916) 445-0613 if you have any questions
regarding the environmental review process.
Sincerely,
/7/,
(' - ,
; ..,
I [ ~.
i /,~ r _"
~L--/~y,-c..-T\fi-.-/
/
-:1/ .
;'f, _. . _ ,
c........::_,.-......?,~
Christine Kinne
Acting Deputy Director, Permit Assistance
Enclosures
cc: Resources Agency
If
.
. .j'
July 23, 1992
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT:
Determination
for the Draft
Ranch Project
of an "adequate" period of public review
Environmental Impact Report for the Otay
of the Baldwin Co. in San Diego county.
Project Team:
As a citizen of San Diego county, and a member of the Valle de
Oro Community Planning Group, I have been following the progress
of the Otay Ranch Project Team. I have also attended the joint
planning commission workshops and field tours. I write to you
now, and to the other decision-makers involved, to address the
issue of adequate public review for the forthcoming draft EIR.
The State Guidelines for CEQA refer to this aspect of the
process in several articles:
Article 7. EIR Process - Public Review of Draft EIR (page 108)
15087. (c) In order to provide sufficient time for public
review, review periods for draft EIRs should not be less than 30
days nor longer than 90 days from the date of the notice EXCEPT
IN UNUSUAL SITUATIONS. (emphasis mine)
Article 8. Time Limits
Public Review (page 124)
15105. (a) Same statement as above citation.
Article 10. Considerations in Preparing EIRs and Negative
Declarations Page Limits (page 147)
15141. The text of draft EIRs should normally be less than 150
pages and FOR PROPOSALS OF UNUSUAL SCOPE OR COMPLEXITY SHOULD
NORMALLY BE LESS THAN 300 PAGES. (emphasis mine)
Article 13. Review and Evaluation of EIRs and Negative
Declarations Adequate Time for Review and
Comment (page 177)
15203. The Lead Agency shall provide adequate time for other
public agencies and members of the public to review and comment
on a draft EIR or Negative Declaration that it has prepared.
J7
/
I am told by Anne Ewing that the current single-spaced draft of
the EIR is running over 1600 pages with appendices and supporting
technical reports of some additional 2000 pages.
If an EIR of "unusual scope or complexity" should come in under
300 pages, the Otay Ranch Project draft EIR must surely qualify
as a one-of-a-kind submittal. We all certainly recognize the
unusual character of this project.
I haven't been in school for some time now, but my arithmetic
tells me that if 300 pages deserve 90 days, then 1600 pages (and
more) deserve about 450 days for adequate review. I realize this
is not practical and I suggest a compromise period of 180 days.
I will be attending your meeting on July the
comments public. Please place this letter in your
my intention to establish an administrative
project.
30th to make my
file as it is
record on this
Sincerely,
;()M J r-
-
/~
Daniel Ford Tarr
11524 Fuerte Farms Rd.
El Cajon, CA 92020
619 588-4863
cc: Otay Ranch Project Team, Chula Vista City Council Members,
Members of the Board of Supervisors, Valle de Oro Community
Planning Group, State Dept. of Fish and Game, U.S. Fish and
Wildlife Service, State of California Office of Planning and
Research, South County Environmental Working Group 1 I
rZIC;D; :Sv,-'-Q.!-c--,,,,iC-.... (P0 JQ~l\.. 1\,
I
."Je~ ~ ~~. I -t c \.-L.." s
dv
CHULA VISTA FIRE DEPARTMENT
BUREAU OF FIRE PREVENTION
PLAN CORRECTION SHEET
Address crr~ ?J'!1C-i
~I?~90-o1-FB 048
Plan File No. Checker w-V::
Oa te 8/:'1/92
Type Constr.
Occupancy
No. Stories
B1 dg. Area
The following list does not necessarily include all errors and omissions.
PROVIDE AND SHOW ON PL~~:
1. )-.;. 2-21 Sec--icn 2.3.2..; ?..!.blic E'ac:.lities !leme..."!t _
~';ate= rnai..r'l .;:=essure ~:':'all Nor e..,<ceeC 150 psi (:!?g. 3.13-2)
2. Pg. 3:13-41 Olympic Trai..:u::g Ce..'1te::- - '!'his sec--:.on may c.~.C'e f,\l~o;:."1 t::e
in.t~i..rn Station ~6 is q:e..r'J.ed.
3. F"..lel n-c:iification has ~or bee..'1. ElisC'..lSseC. i....l t..ns ccc..=r.e.."1t. CUe t::>
se..1"'I..siti.ve habitat r:3 in t.J:e Otay ?.anc.~ ?rojec~ area,. t..:"'e 2.::?1..iC2...~1: is
unable to p.rovic.e fi:=e apparatus ac::ess into C3.I'!Y'on 2reas. ..'lJ.te.=::at..:..~.le
IT'.et..~cds o:E ?rovidi.ng fi.:'s prot~.....i.on to c:-...e..."1 s:-....ace I u=ban i:1ter::ac2 areas
and brus..~ artd wilcllan::. are=.s :nust be ac.c.:-essed.
,~P9-29
,;);
To:
Anna Noah
(0340)
~-dc'~
J
f;j,o lliS: ~ O~g:,!~!
:U\ i~i
I
~fJ-
AUgust 27, 1992
From:
F~ood Cont::-o~
(0362)
(WA#U"rl~510)
(0:3:36)
315 Fourth Ave., Suite A,
CA. 91910
Chu~a Vista,
CC:
Bill Hoeben
steve Thomas
.,
Public Revie~ Comments ~or Draft Program Enviror~enta~
Impact Report - Otay Ranch (dated JU~Y 1992)
I. :BACXGROmm:
Subject:
Flood Cont::-ol revie\oled draft EIR c!leck prints in Septlamber
1991 and March 1992. Various Otay Ranch drainage plans have
a~so been revie~ed. Comments were made with ~~ose reviews
to aid final docu:ent preparation.
The Flood Control issu~s that follow need to be addressed in EIR:
II. ISSUES AND C~~S:
A. !ss'Ue:
Provision of comcrehensive master drainage plans,
studies, financing, and phasing plans for on-site
and Off-site otay Ranch .drainage facilities.
'._"~" <';~,'" Flood cont:-ol reviewed draft "Drainage and Flood
Control 1"1ans for t.'le Deve~opment of Otay Ranch by th,a
:Baldwin Company" trom "/TN Southwest, 'I.nc. and Church
Engineering, Inc. dated.May 1990. Comments were provided
after reviews on those documents. FlOOd Control has not
received amended documents. The July 1992 draft EIR did not
address how or when acceptable comprehensive d::-ainage,
phasing, or financing plans would be established for otay
Ranch; or how drainage infrastructure will be provided ror
each aJ. ternati ve. Staging / development detail, timing,
financing, and responsibility for drainage impacts 6hou~d be
'established. Specific zoning, planning, and improvem~nt
detail is necessary to develop al~ of ~ese plans.
. . ...
It it is not desireible to set the precise'land planning and
zoning necessary to allow development ot these plans with
the EIR; it ~ay be acceptable to estahlish master drainage,
staging, and financing plans with .the first SPA within each
drainage.hasin. However, the EIR must establish the plan
development process, responsibility ot first developer to
provide such plans, and a surety procedure to be instituted
with each SPA to assure appropriate plans are develop,ad and
observed in the entire drainage basin impacted by each SFA.
_--6.~
-..- ..../
B. Issue:
provision and utilization o~ Sto~ Water Quality
Design, Monitoring, and Treatment.
The City o~ Chula Vista and CQunty of San Diego have a
Municipal permit fro~ the State Regional Water Quality
Control Board ~or 5to~ water discharge. New development
mu~t consider and mitigate impacts to sto~ water quality
with regard to the local agency Municipal Per:it.
A stor: water quality General Industrial Pe~it has also
been adopted by the State and is active. Any industrial
activity defined by the state Regional Water Quality C~ntrol
Eoard as being sul::lject: to t.'1e Industrial Ganeral Permi\: !:lust
file an Nor or ol::ltain a separate permit for such activity.
A state Construction General P~rmit will ce approved and ae
operational by octocer 1992. All projects, or parts of
proj ects, "f i ve" ac=es and gJ:'ea tar are requi::-ed to obtll.in
NOI's. Implementation o~ $torm water quality practices !:lust
be included, maximized, and i~plemented wit.'1 all
const-~ction. The designs must include monitoring, Sto~
Water Pollution Prevention Plans, and Use of guideline
manuals and Best Management Practices (EMP'S).
BMP's, design, treatment, and !:lonitoring for sto~ watar
quality ~ust be addressed with respect to t.~e Municipal,
Industrial, and Const--uction Permits with all Baldwin Ot~y
Ranch sto~ water runo~f (not Otay Lakes basins only). !n
addressing storm water quality issues t.~e use o~ deten"tion,
retention, and treatment ponds ~ay be Used. The :aste:
drainage, staging, and ~inancing plans must include all
construction and ~aintanance ot these sto~ water quality
facilities as San Diego County does not accept these as
public facilities for maintenance.
. ,
Most comments provided in previous responses listed above
are current and still need address. Comments addressed
should cover all proposed and selected alternatives. Mi..<i..,o
of several alternatives as a project develops would be -
anot.~er alternative and should have ~aster plan address
prior to establishment.
C. Issue: Existing and future flood plain ~apping for streams
and land develooment treatment, policy, and procedure tor
regulation P~oses.
Major streams having flood plain maps should be identified.
Other streams with one square mile and greater drainage area
.should also be listed and identi~ied to be flood plain
mapped prior to development near those st::-eams. Flood pla.ir:
regUlations and procedures for development near flood plains
should" be identi.l:ied, listed as goals, and adhered to ;;i~"
all Bald;;in otay Ranch development.
O(&y14,.34
d3
,-
TO: OGDEN
,--- AUG-28-'92 FRI 14:49 ID:OTAY RANCH PROJECT TEL NO:619/422-7690
11583 P02/05
~
August 28, 1992
TO: ~e Bazzel, Senior Planner, Otay Ranch Project
VIA: Jess Valenzuela, Director of Parks and Recreation
FROM:
Martin Schmidt, Landscape Architect
~~
RE: OTAY RANCH PROJECT. DPEIR COMMENTS
The scope of this review has been contained to the parameters of the Parks and
Recreation Element, the Open Space Element, and the Trails/Greenbelt components.
MAJO.R...I..s..S.l1.E.S:.........................................................................__m_m..............................
1. PARK NETWORK:
Page 3.13.63:
A. In the second paragraph, second sentence: delete the word "private" from
the statement. Private reaeation facilities do not receive credit towards the
Park Dedication requirement.
B. In the portion that lists the site components {or Neighborhood and
Community Parks, a statement to the effect of the following is to be
included-
'This list is specifically for analysis purposes only. The final determination
of the types, quantities and locations of the specific facilities to be provided
at each park will be based upon a needs analysis and the 5UbseqW!I\t park
master plan for each park type and site."
C. At the bottom of the page in the Chula Vista Greenbelt section, the text
addresses the greenbelt as If it already is in piace. The text should be
revised to reflect that the greenbelt is in the various stages of the planning
process. Potential revision could read:
'The City of Chula Vista General Plan has a conceptual greenbelt ~,ystem
plan which includes active and passive parks, undeveloped open llpace,
;);1
TO: OGDEN
.,.- AUG-28-'92 FRI 14:50 ID:OTAY RANCH PROJECT TEL NO: 619/422-7690
1:1583 P03/05
(
OIly RaocII ElK
KeYlewCoINll..lIl
'12JJ/fJ2
Pap 2
stream valley and flood plains, wetlands, water and asrlcultural ilreas that
will form a continuous 28-mile system around the city."
Page 3.13 -65:
A last sentence at the bottom of the page identif1eS that,
''The PAD fee is CUlTently $4,375 per dwelling unit (Sclunidt 1992)."
This is correct only for single family homes only. See the attached fee
schedule for the correct fees for the various types of housing.
Page 3.13 -68:
The last bullet point at the bottom of the page identifies that the lee per
dwelling unit is $800. This is incorrect and is to be revised to reflect the fee
schedule provided.
These items are the issues of major significance relative to the Otay Ranch DPEIR.
All other aspects of this project as identified in the DPElR and previous GDP and
EIR submittals will be brought forth for discussion and resolution to the Parks and
Recreation Department's and the City's satisfaction.
(;)r{
TD:DGDEN
AUG-28-'92 FRI 14:51 ID:OTRY RRNCH PROJECT TEL NO:619/422-7690
11583 P04,'05
"J
.
~
1.
. .
--
,May 21, 1991
I,
'1'0:
All Department Head.
.:re.. Valenzuela, Director of Parks and
R.creat.io~
FROM:
SfJIlJEC'l' :
Park Acqui.ition and Development (PAD) !'.e Inl::rea..
On April 23, 1991, the City council approved an increase in the
City's exist in; PAD te.., to take effect 60 days atter thilJ date.
Therefore, the new fees becOIIIe etfective on Jun. 22, 1991, and will
apply to all project. that will not have an approved and ~.cord.d
final map a. ot the June date. Projects that have had PILD f..s
waived or have had special conditions tor park development placed
on their tentative lIIaps which exempt them from new PAD fens will
not be subject to the new fees.
Attached is a copy of the eXistinq fees anel the proposed teell which
were accepted by Council. The tees are divided into an acqu:L.iUon
portion and a development portion. 'l'he new combined PAD foee are
as follows:
Sinql$ family:
AttaChed:
Duplex:
Multi-falllily:
Kobilehollle:
Residential/transient
motel anc1 hotel:
$4,375/du
$3, 810/du
$3,365/du
$2,990/du
$2,230/du
$2, 03 O/du
If you have any questions, or need additional information, please
do not hesitate to call.
dl
TO:iJGDEN
--;.- AUG-28-'92 FRI 14:51 ID:OTAY RANCH PROJECT TEL NO:619/422-7690
.
11583 P05/05
Attachment B
.
PARK ACQUISITION AND DEVELOPMENT FEES
CURRENT .
'ark ACDUi$1lton F~e!
Stngl. faml1y
Attache4
Duplex
Multt-famny
MobnehD1lle
Res' dent 'a1 lIote 1
S390/clu
5335/4u
$300/4u
$Z65/du
$2oo/du
5180/du
, Neighborhood
Park COlllllun1tv Park JOTAL
Single flllll1y $ 800/du $490/4u $1.210/4u .
Attached $I,155/du $430/du U.125/du
DIlVlex $I,025/du 5370/4u $ 185/4u
Mu tt.faml1y $910/du 5340/4u $ 885/du
Mobnehome $680/du $250/du $ 155/du
Residential and transient $620/du $230/du $ 100/du
IIOte1/hote1
PROPOSEQ - As o~ r,{,-z.../"I (
~ Acauisition Fees
Single famny $2.1I5/du
Attached $I,830/du
Duplex 51.625/dll
Multi-family $1.440/4u
Mobilehame $1.070/du
Residential hotel $ 180/du
~ DeYQloDm~nt '..1
Neighborhood ~
--=.mL- mAL
Sing'e famny $I,510/du $750/du $2,210/du
Attached 51,310/du $670/du $I,980/du ,
Duf'ex $1.160/4u 558O/du 51.740/du .
Mu tt -family $I,030/du 5520/dll $I,550/du .
Mobnehollle 5770/du $390/dll '1,IIO/du
Residential and transient $700/du 5350/du 51,050/du J
IIOtl1/hote'
,
"PC 1128R
d7
~ ~~~Il?~~~~O~O~~r~G~~~J~N~ ~~_7~9~U~~r!2~~
Board of Education
Martin Block
Bill Hampton
Ann Navarra
Jack Port
Joe Rindone
Superintendent
01 Schools
Harry C. Weinberg
August 7, 1992
()
Mr. Douglas D. Reid
Environmental Review Coordinator
otay Ranch Project Planning Office
315 Fourth Avenue, STE A
Chula Vista, CA 91910
-:L:
-'
RE: OTAY RANCH PROJECT IMPACT
Dear Mr. Reid:
The County Office of Education (SDCOE) is in receipt of the
Draft Environmental Impact Report (DEIR) for the Otay Ranch
Project. For your reference, I am the designated point of
contact for any future correspondence. We appreciate the
opportunity to respond and offer the following comments.
We note that you anticipate 31,295 K-12 students to be
generated from this project. The County Office of
Education was not referenced in the DEIR as an affected
taxing entity. Our review of this report indicates the
impact to SDCOE to be potentially significant.
The County Office of Education is an independent agency
governed by the elected trustees composing the County Board
of Education. This agency provides direct educational
programs throughout the county including the following
program areas:
· Regional Occupation Educatior.
· Special Education
· Infant Preschool Special Education
· Special Education for Profoundly
Handicapped Students
· Migrant Education
· Court Schools
· Outdoor Education
~jf
Mr. Douglas D. Reid
August 6, 1992
Page 2
In addition, the SDCOE provides educational and administrative
support services to virtually all of the school districts in San
Diego County. These services include:
. Teacher education
· Curriculum development and implementation
. Educational assessment
· Management Academy
. Data processing
. Accounting
· Financial advisory services
· Facility planning and financing
. Library and media services
The SDCOE is impacted by the development activities of the Otay
Ranch Project. The impact comes from the lack of facilities to
accommodate the additional demand for services. This demand is
generated by the housing component of the Project and the indirect
effects of commercial and industrial components of the proposed
development. The impacts are both in terms of direct participation
in SDCOE educational programs of new residents and employees
generated by the Project in addition to the increased demand for
SDCOE services by school districts impacted by the project,
specifically Chula vista Elementary, Sweetwater High, Jamul-
Dulzura, and Grossmont Union High. Based upon the individual
district need, these services vary in level and intensity of
activity.
It is our goal to provide your agency with specific information
about our programs to assist in determining the impact of your
project. Attached is a listing of the major program units of the
County Office of Education which are providing services throughout
the county.
If you have any questions, or need additional information, please
contact Pamela Montgomery of my staff at 292-3883.
~ ~~J;~
Th/mas E. Robinson
Director, Facility Planning
Attachment
TER:PM:rh
cc: Kate Shurson, Chula vista Elementary
Thomas Silva, Sweetwater
Tom Bishop, Jamul-Dulzura
Linda RObinson, Grossmont union
:7Z1
SAN DIEGO COUNTY
OFFICE OF EDUCATION
~
'---
I DDDD
- - -
August, 1992
:if)
MISSION
The San Diego County Office of Education promotes the improved
motivation, academic achievement and personal well-being of all
students by providing local school districts, students, and the public
with service and leadership.
GOALS
Through its accessibility, support and leadership, the San Diego County Office of
Education shall:
. Identify and respond to the needs of school districts with special attention to
small districts.
. Improve student motivation, academic achievement, personal well-being,
and readiness for college andlor career.
. Improve the quality and efficiency of instructional, personnel and business
practices in local school districts. .
. Provide programs and services which can be operated more economically-
on a regional, rather than single-district, basis.
. Assist schools and districts to achieve greater success with educationally
disadvantaged, low income, and minority youth.
. Provide staff development to increase the productivity and enhance the
morale of school personnel.
. Strengthen the management and leadership of schools and districts.
. Increase public confidence in public education.
. Assist school districts in influencing and complying with legal, fiscal and
program requirements.
. Identify and communicate future trends impacting education and assist
districts in responding to them.
. Provide excellent educational services to students in the court schools,
Friendship School, and Hope Infant programs.
. Improve the effectiveness and efficiency of the San Diego County Office of
Education operations.
1
,?;
SAN DIEGO COUNTY OFFICE OF EDUCATION
AT -A-GLANCE
STUDENTS
Juvenile Court & Community Schools (10,000 students)
Special Education Coordination (38,000 students)
Regional Occupational Program (35,000 youth and adults)
Migrant Education (13,635 students in Orange/SO counties)
Outdoor Education (25,000 students)
HOPE Infant (400 handicapped infants)
Friendship School (50 profourldly handicapped students)
':':':':~"':~':~':':""
,...." ",............ -.-..--.
. _ ;#:::;.?\" .:,H~@::;M%M,.;;:::::;:'':;:::~;:.
County Office: $7~ID!llI119.n;J:il;l;gg~t,'X'g,9 employees
Self-Insurance JF1('$~ "",et~~~i1llittJ.tlds;'~;;!;$68.3 million)
Payroll (41,OOOnlpnthly crr~ for ~6;:gt9tricts)
CredentIals (18"500 teaGliec:credentlalsVWh
:':::'"'t:, ::..,..,.;w,...:.:,_.:..,,_:......._,:.,,:':;.:.,:'::.:-"::::":"', "IX,::::""
ITV (servingg&{er 60JJ:jQQp:fior)1~s!f4@d 43;Ji:;{?chools)
RlmlTape L,ig~ary (39igpiitractihg);gJstricts}i\iiji\
School Ub(~ Servt~gsi~;la-dist!iiCt$;And 61\\$Phools)
~~~~7;~~~}at~'~.\1~~~~tif'~nist;~\1 trained}
School'E:aclllty Planmng'Wi.WN"'".,
Staff/clJiculum o!~tejolien~ll;'all[!lrguage AS*uisition
. Three-year dropout rate in SO County falls from 24.9% in 1986
to 16.3% in 1990 (state average is 20.2%) .33.9% of hiQh
school seniors complete courses required for UC admission
(state average is 31.1 %) . College-going rate jumps from 52.9%
to 56.4% (state average is 55.7%) .1990 drug survey shows
drug use declining among SO County students
FACTS ABOUT LOCAL SCHOOLS
43 school districts, 532 schools; 5 community college districts
1990-91 expenditures for all 43 districts: $1.7 billion
1990-91 enrollment: 393,041 students
FTE educational staff: 16,066 teachers; 1,400 administrators
Classified staff: 8,671 full-time; 8,721 part-time
Updalcd: JUDe 17. 1991
-} -i
.Je
COUNTY OFFICE OF EDUCATION
PROGRAMS AND SERVICES
ADMINISTRATIVE SERVICES
Instructional Television (ITV)
ITV provides production services to teachers, students, and administrators
along with programming services to K - 12 schools, community colleges,
universities and general interest educational programs for adults.
Court and Community Schools
This program provides education program to students who are wards of the
court, on probation, or under the supervision of the County Department of
Social Services. Classes are held at the 30 community sites and 6
detention / rehabilitation sites located throughout the county.
Planning, Assessment, and Leadership
This unit has three components. Planning coordinates the strategic
planning process for the County Office; Assessment provides student
evaluations and results of standardized tests to school personnel, press and
parents; and Leadership provides development guidance for school district
superintendents and their board members.
Student Information System
The Student Information System is a fully integrated information system
which provides services to 27 school districts to assist in the management
of student data and the enhancement of their instructional programs.
Services available include: student master file maintenance; attendance
accounting and reporting; scheduling; grade reporting; standardized test
scoring and reporting; and California guidance and graduate requirements.
33
BUSINESS SERVICES
District Financial Services
The District Financial Services section consists of two major components:
Business Advisory Services and District Accounting Services.
Business Advisory Services
This area of service includes school district budget processing, budget
development, monitoring and review, and the processing, review and
approval of all K-12 and community college state fiscal reports.
District Accounting Services
This area includes payroll, retirement and commercial warrant processing,
audit and financial accounting. More than 492,000 payroll checks are
computed and issued annually along with the maintenance of employee
records of earnings and reporting to the state and federal agencies.
The Retirement Unit maintains retirement records and provides monthly
reports to two state retirement systems for over 49,000 employees paid by
the county, plus approximately 25,000 employees paid by independent
school districts. New memberships, retirements and refunds are also
processed.
Approximately 188,000 school district commercial payments are made and
audited annually to ensure the legal and proper expenditure of school
funds. The Financial Accounting Unit issues over 30,000 accounting
documents for transfers of cash, distribution income and adjustment of
records, and enters 950,000 line items of accounting transactions submitted
by school districts. Over 1,250,000 pages of monthly reports used for
internal management and reporting to state agencies are produced for
county school districts.
Facility Planning
The Facility Planning Unit assists district in meeting the school construction
needs created by San Diego County's tremendous growth. Staff provides
31/
a variety of services to school districts, including assistance with the state
school construction program, review and approval of site acquisitions,
assistance with the development of long-range comprehensive master
plans, and evaluation of financing alternatives for facility acquisition. The
unit also acts as local government and state agency Iiasion for all 43 K-12
districts.
INSTRUCTIONAL SUPPORT
SERVICES
MEDIA SERVICES
The Research and Reference Center provides professional materials for use
by teachers and administrators in the 48 school districts in the county. The
School Library Service center provides extensive staff development for
library media specialists in all districts throughout the county as well as
maintaining 59 Branch library collections at selected school sites.
AVID
The AVID program or Advancement Via Individual Determination began in
1980 at Clairemont High School to motivate minority and low-income
students to attend college and be successful. Since that time, the program
has expanded to more than 100 schools throughout the county with an
enrollment of 5,500. The college entrance rate is 98%. Recognized
statewide and nationally, the program is growing giving students the skills,
support and guidance that they need to fulfill their potential.
LANGUAGE ARTS
This project team provides curriculum and instructional services to improve
the quality of instruction and student achievement in the area of language
arts. The College and High School Ready Writers project is countywide and
focuses on skills for 8th and 12th grade students.
STUDENT WELL BEING
Programs offered in this unit include training and assistance to districts in
developing and implementing activities to promote overall student well-being
and include: Alcohol and Drug Prevention; Dropout Prevention; Gang
;;c;
Involvement Reduction; Mental Health; Pregnancy Prevention (including
sexually transmitted diseases). Team members provide the training to
teachers and administrators on the implementation of the curriculum
packages.
ADMINISTRATOR TRAINING
The Administrator Training Center is one of thirteen selected sites in
California, as part of the State Department of Education's California School
Leadership Academy, to provide the instructional leadership training for
practicing and aspiring administrators with an emphasis on principalship.
The Management Academy provides training for administrators in schools,
districts, and business operations.
PERSONNEL I
SPECIAL EDUCATION
CREDENTIALS
The Credentials unit processes all the paperwork required for a teacher to
become properly credentialed. In addition, staff guarantees that the
applicant follows all relevant laws, and ensures the applicant is properly
assigned for their credential. Staff examines transcripts for degree
information, experience, and provides counseling in analyzing the
documents.
SPECIAL EDUCATION
The County Office serves as the responsible local agency for Special
Education Local Plan Areas (SELPA's). As the responsible local agency,
the County Office receives and distributes regionalized service funds,
provides administrative and technical support and helps put local special
education plans into action.
FRIENDSHIP SCHOOL
Friendship School is a special education school operated by the County
Office. Located in National City, the school serves a maximum of 50
-'7/
-; ~?
profoundly handicapped and medically fragile students, aged 3 to 21 years.
The students are residents of a licensed residential facility located next door
and cannot be served in other school environments. The daily curriculum
focuses on cognitive development, language and communication, and
environmental awareness.
HOPE INFANT PROGRAM
This program provides a home-based educational program to handicapped
infants between birth and three years of age and their families. The primary
purpose of the program is to enhance the child's development, provide
support and assistance to the family, and maximize the child's and family's
benefit to society. Referrals to the program are made countywide by
physicians, public health nurses, social service agencies, and parents.
Families receive weekly or biweekly home visits, weekly parent meetings, a
parent newsletter and parent training activities.
STUDENT PROGRAMS AND
OPERATIONS
MIGRANT EDUCATION
Migrant Education is a federally funded program which provides
supplementary instruction and support services to children of migrant
agriculture workers and fisherman. Over 30 school districts participate, with
the ultimate goal of the program to increase the graduation rate among
these students.
OUTDOOR EDUCATION
Each year, more than 19,000 San Diego County sixth graders spend a week
at one of the three Outdoor facilities operated by the County Office. San
Diego Unified School District students trek up to our Camp Palomar facility,
while the rest of the county schools take advantage of Camp Cuyamaca and
Camp Fox for outdoor curriculum which includes astronomy, geology,
ecology, hiking, conservation, and plant and animal studies.
61
REGIONAL OCCUPATIONAL PROGRAM (ROP)
ROP is a countywide public education service which provides job training
for residents of San Diego County. ROP offers more than 400 courses at
no charge to all San Diegans interested in developing or improving job
skills. ROP classrooms are located in schools and community sites
throughout San Diego County as part of the public school system. The
courses and services are operated by high school and community college
districts. Employers, business people, union officials, and community
personnel work with the school districts and ROP staff to identify and
develop courses needed to provide up-to-date training.
ENERGY EDUCATION
To assist school districts in providing knowledge of energy conservation to
students, staff, and administrators, the Energy Education program develops
curriculum, and conducts workshops on energy conservation. Staff also
works directly with 15 schools in the San Diego Unified School District as
well as acting as consultant to teachers in providing assistance on what and
how to teach energy conservation. The unit also works with school district
administrators to reduce energy consumption through the maintenance and
operations of individual school sites.
],J'
Carolyn Avalos
605A Hygeia Avenue
Leucadia, CA 920240
September 9, 1992,"-:"':_,
"..-----.-
Mr. Douglas Reid
Otay Ranch project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
-,
----~~.:...-.-==---...:.:..:-
';Cr'
, \'
----
Re: Otav Ranch Draft Proqram EIR
Section ~ Cultural Resources
Dear Mr. Reid:
According to the Cultural Resources Element of this EIR, 6,000
acres have been assessed; 17,000 acres have been generalized (3.4-22).
From what I have researched, three different civilizations of native
peoples are known to be represented within the property in question.
As the document affirms, these findings span 8,000 years, possibly more.
It is noted further on page 3.4-9 that the "earlier San Dieguito
Complex is also suggested. .., but little evidence currently exists to
verify this assertion." According to this element, the existence of
such artifacts would set the antiquity of cultural resources existing
on the property back at least another thousand years.
If so little is known about what Professor Charlotte McGowan
of Southwestern College believes to be the 'most significant
archeological site in the southwest corner of San Diego County
and therefore of the entire country, why are construction plans
being drawn up in the context of the unknown? Professor McGowan is
mentioned in the same section (3.4-36) as being basically
responsible for the area's prehistoric investigation until 10 years
ago, presumably when the Otay Ranch property changed hands.
On page 3.4-24, it is emphasized that one of the few prehistoric
resources determined to be important is the McGowan Site, a
"large and important village site with a considerable demonstrated
antiquity." The New Town Plan would develop this site. If not
directly developed by a different plan, would it be protected from
unauthorized public intrusion fostered by the proximity of residences
and accessibility of roads? What provisions would be made to prevent
even the most primitive of pothunters from damaging this and other
important sites, beginning with the introduction of construction
crews and equipment?
What is implied is the discovery, disturbance, and endangerment
of still untold prehistoric treasures? They might offer vital
information on climate changes, biology, and human origins in
this area and beyond. After-the-fact security would not be consistent
with what I understand to be the intent of CEQA. Uncovering
archeological finds, furthermore, on such a large scale -
simultaneously or progressively - implies an enormous, concerted
6'7'
__ . ___ __ __m___1-____..._
Mr. Douglas Reid
Page two
effort requiring experts in the areas of excavation, identification,
cataloguing, and preservation. It is not clear in the EIR how
this would be justified and what mitigation would be allowed in
each case. How would the various concerns be reconciled to the
satisfaction of CEQA requirements for intensive, systematic
survey and evaluation, followed by possible recovery, curation,
and storage of artifacts? I assume that disturbing these sites has
to be justified convincingly. Relocation of the site or building
on it do not seem to be acceptable according to my sense of CEQA,
and since all of the many alternatives are in the planning stages,
such intrusion into the significant areas could be avoided.
Open space or constructed parks are vulnerable to marauders or
the merely curious. Again, accessibility is the problem. More
deliberate removal of finds would be the inevitable result of grading
for construction. The intense land use for the New Town Plan on the
Otay property would develop 186 out of 213 sites so far identified
(3.4-24). On this same page, it adds that 43 out of 49 historic sites
would be developed and lost under the same plan. The low density
alternative destroys 16 fewer sites. The turn-of-the-century Otay
Ranch Buildings Complex is slated for construction on all plans
encompassed by the EIR. The plans under consideration should provide
for alternatives to such destruction. They do not.
Again, CEQA requires that those sites determined to be "important
resources" should be considered for site avoidance in open space or
capping, excavation, or a combination of these measures (3.4-34).
Page 3.4-37 declares, "All prehistoric sites are considered important
and significant resources for planning purposes." I therefore suggest
to you that this EIR does not adequately address these general
acheological, historical, educational, scientific, and cultural
concerns. It is obvious that plans and measures to mitigate are vague
or nonexistent and inappropriate to the handling of these vulnerable
and fragile resources. I request that you extend the public comment and
consideration period for reasons of this complex issue, in order
to grasp the details of the situation at hand and to allow for
contingencies. Combined with the other questions raised in other
elements of the EIR, the public will surely need more time to review
this document.
Thank you for your attention to this matter.
Sincerely, _~
G.I...<.....f~~/'--C'-C.l'k:L
Carolyn Avalos
Member, San Diego County
Board of Directors
Endangered Habitats League
cc: San Diego County Board of Supervisors
Chula Vista City Council
fZ)
SEP-30-'92 WED 13:18 ID:OTRY RRNCH PROJECT TEL NO:619/422-7690
11819 P02/13
Mr. Douglas D. Reid
otay Ranch Planning Team
315 Fourth Avenue, Suite A
Chula vista, CA 91910
"-. THI IlESOUla5 AGINCY Of CAUfOINlA
,-!~\tTi ~trfo-w ~ ~I
:[)):_......__ IS
'1'\: SEP 14 ~i ,I
: : \.:.1 Jl!:V1 Da,. , Septellber 8, U92
j Subjocl,
Draft Elwironaental
Impact Report. (D2IR)
tor the Otay Ranch
lOB: t.'U01U
Stat. of Califtwnla
Memorandum
To
,Mr. Douglas P. .Wheeler
Secretary for Resources
1...-
From , Oepartment of Con...."tion-Off'lC. .f the Ditect.r
The Department of Conservation has reviewed the city ot
Chula Vista'. DEI:R for the project rererenceci above. -rhe If..-T......---..
project will convert 23,297 acres ot agricultural and grazinq
land. NO W111iamson Act contracts exist on the sit.. '!'h,t
Department/which is responsible tor monitoring faraland
conversion on a statewide basis and also administers the
California Land Conservation (Williamson) AC~haB the tollowing
co_ents.
While the DEIR provides adequate information regarding
agricultural production and impacts of the project on agriculture
and grazing in the area, there are a number ot mitigation
measures that should be considered in the Final Invironmental
Impact Report (FEIR). Residential units could be l;lluster'ld to
retain acre land for agricultural purposes. A dev.lo~nt i~act
te. could be imposed to fund a farmland protection proqrau that
utilize. .uch land use planninq ~ool. as transfer of develo~ent
rights, purchase of development riqhts or con.ervation eadeaent.
and .stablishment of farmland trusts.
The Department appreciates the opportunity to comment on the
Draft Environmental Impact Report. We hope that additional
mitiqation measures to offset the farmland conversion impacts are
given adequate consideration in the Final Environm&ntal Impact
Report. It I can be of further assistance, plsase feel froe to
l;lall me at (916) 322-5873.
~jf.~
Deborah L. Herrmann
Environmental proqram Coordinator
cc: Kenneth E. Trott, Manager
ottice of Land conservation
San Deigc Resource Conservation District
LJ
; I
, '
Carolyn Avalos
605A Hygeia Avenue
Leucadia, CA 920240
September 9, 1992:--=-:_
"'i"'-
~ -..-.- -
-- ._----:-:--
----~
--=--
Mr. Douglas Reid
Otay Ranch project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
\: ';C("
'!
- ~
.-"
Re: Otay Ranch Draft ProGram EIR
Section ~ Cultural Resources
Dear Mr. Reid:
According to the Cultural Resources Element of this EIR, 6,000
acres have been assessed; 17,000 acres have been generalized (3.4-22).
From what I have researched, three different civilizations of native
peoples are known to be represented within the property in question.
As the document affirms, these findings span 8,000 years, possibly more.
It is noted further on page 3.4-9 that the "earlier San Dieguito
Complex is also suggested. .., but little evidence currently exists to
verify this assertion." According to this element, the existence of
such artifacts would set the antiquity of cultural resources existing
on the property back at least another thousand years.
If so little is known about what Professor Charlotte McGowan
of Southwestern College believes to be the 'most significant
archeological site in the southwest corner of San Diego County
and therefore of the entire country, why are construction plans
being drawn up in the context of the unknown? Professor McGowan is
mentioned in the same section (3.4-36) as being basically
responsible for the area's prehistoric investigation until 10 years
ago, presumably when the Otay Ranch property changed hands.
On page 3.4-24, it is emphasized that one of the few prehistoric
resources determined to be important is the McGowan Site, a
"large and important village site with a considerable demonstrated
antiquity." The New Town Plan would develop this site. If not
directly developed by a different plan, would it be protected from
unauthorized public intrusion fostered by the proximity of residences
and accessibility of roads? What provisions would be made to prevent
even the most primitive of pothunters from damaging this and other
important sites, beginning with the introduction of construction
crews and equipment?
What is implied is the discovery, disturbance, and endangerment
of still untold prehistoric treasures? They might offer vital
information on climate changes, biology, and human origins in
this area and beyond. After-the-fact security would not be consistent
with what I understand to be the intent of CEQA. Uncovering
archeological finds, furthermore, on such a large scale -
simultaneously or progressively - implies an enormous, concerted
L~}-
_______.L___.._., _
Mr. Douglas Reid
Page two
effort requiring experts in the areas of excavation, identification,
cataloguing, and preservation. It is not clear in the EIR how
this would be justified and what mitigation would be allowed in
each case. How would the various concerns be reconciled to the
satisfaction of CEQA requirements for intensive, systematic
survey and evaluation, followed by possible recovery, curation,
and storage of artifacts? I assume that disturbing these sites has
to be justified convincingly. Relocation of the site or building
on it do not seem to be acceptable according to my sense of CEQA,
and since all of the many alternatives are in the planning stages,
such intrusion into the significant areas could be avoided.
Open space or constructed parks are vulnerable to marauders or
the merely curious. Again, accessibility is the problem. More
deliberate removal of finds would be the inevitable result of grading
for construction. The intense land use for the New Town Plan on the
Otay property would develop 186 out of 213 sites s'o far identified
(3.4-24). On this same page, it adds that 43 out of 49 historic sites
would be developed and lost under the same plan. The low density
alternative destroys 16 fewer sites. The turn-of-the-century Otay
Ranch Buildings Complex is slated for construction on all plans
encompassed by the EIR. The plans under consideration should provide
for alternatives to such destruction. They do not.
Again, CEQA requires that those sites determined to be "important
resources" should be considered for site avoidance in open space or
capping, excavation, or a combination of these measures (3.4-34).
Page 3.4-37 declares, "All prehistoric sites are considered important
and significant resources for planning purposes." I therefore suggest
to you that this EIR does not adequately address these general
acheological, historical, educational, scientific, and cultural
concerns. It is obvious that plans and measures to mitigate are vague
or nonexistent and inappropriate to the handling of these vulnerable
and fragile resources. I request that you extend the public comment and
consideration period for reasons of this complex issue, in order
to grasp the details of the situation at hand and to allow for
contingencies. Combined with the other questions raised in other
elements of the EIR, the public will surely need more time to review
this document.
Thank you for your attention to this matter.
Sincerely, _~
G-,u..~~ ,~,-<,-Cl'kL
Carolyn Avalos
Member, San Diego County
Board of Directors
Endangered Habitats League
cc: San Diego County Board of Supervisors
Chula Vista City Council
ic1
FROM SUPERUI$OR G B~ILEV
09.24.1992 11:t13
P. ::!
i)iSTO;;;:~ ~--.~.~ .~~.?
I r ~ : -' '~' :;' i;;~...
.-, .. ,"'''';:
,. .-'
SEP 2 1 1992
JllKJL-OOLZURA aHilNITY l'UlNNnlG GRaJP
. Box 613
Jattul, CA 91935
'. .
September 9, 1992
George Bailey, Chai=
San Diego County Board of Supervisors
1600 Pacific Highway
San Diego, CA 92101
Dear Chaiman Bailey:
I am writing to request the Board's support for an exteoded review period on
the Draft Environmental IIti>act Report for the otay Ranch.
The Jamul-Dulzura Community Planning Group originally asked for a 90 day
review and were disappointed with the decision to limit public review to 60
days. However, we established five sub-camri.ttees to divide the work, and
have attempted to maintain a schedule whereby a thorough analysis of the
docunent and the nine volunes of technical appecdices could be caqlleted on
time. The task has proven iIq>ossible.
This project has the potential to becane an exceptional larxl develO];lT.lEnt. We
all recognize the unique benefits ~rehensive planning can offer on the otay
Ranch. However, these bes1efits can only be assured by adequate review. The
concepts we have cooperatively developed. over the past five years will not
boaa.mo ro~lity unloaa tho implamontin~ p~ooedur~ arQ elQ3r ~ procise.
Environmental impacts IlI.lSt be adequately assessed and proposed mi. tiqations
ItUSt be convincingly supported.
Therefore, the Jarrul-oulzura Carmmity Planning Group has voted unanimously
to request a 60 day exteosion beyood October 7, 1992, for public review. It
has becane clear that without this additional tine, we will be forced to limit
the scope of our review ;:md '-'-'....,;uts on this enormous document.
Respectfully suhnitted,
Mark Montijo, Chair
JJij'
LAFCO
1600 Pacific Highway' Room 452
San Diego, CA 92101 . (619) 531-5400
Ch:lirperson
~1ark J. Loscher
Councilman, Citv of
S3n .\breos
.\1ember.i
Brian P. Bilbr:J.Y
County Board 01
Supcrviso~
Dr. Lillian Keller Childs
Helix Water Disuict
lincH Fromm
Public ....'ember
John .\l3cDonald
Counry Board of
Supervisors
John Sasso
Presidem, Borrego
""':I.(cr District
)0.0 Shoemaker
~:I.\'or, City of
El Cajon
Abbe Wolfsheimer
Council member, City of
San Diego
Alternate ~Iembers
Valerie Stallings
Councilmcmbcr. City of
S:m Diego
Ernest Kornik
52.n .\ligucl (omolid:J.tcd
Fire Protection District
Leonard .\1. :\loore
Councilm:m. City of
Chula Vista
David A. Perkins
Public ~Iembcr
Leon L. Williams
Counry B02rd of
Supervisors
Executive Officer
Jane P ~ferrill
Counsel
Lloyd :\1. Harmon, Jr.
San Diego Local Agency Formation Commission
----
- ':=:--~~-:'--;:::::;~
. .
-- -- -..
-------
September 10, 1992
..--.--.---- --'--. --
Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT: Draft Environmental Impact Report on the Otay Ranch
General Development Plan/Subregional Plan
Dear Mr. Reid:
Thank you for the opportunity to comment on the Draft Environmental
Impact Report (EIR) for the Otay Ranch General Plan Amendment (GPA)
and General Development Plan (GDP). Because the project will involve
changes to gove=ent jurisdictions and spheres of influence, LAFCO will be
a responsible agency for the project. As a responsible agency, LAFCO must
consider the lead agency's environmental document and can typically recertify
it, if information critical to LAFCO's review is included in the document.
A major concern LAFCO staff has with the Otay Ranch ErR pertains to the
deferral of the analysis of program and policy-level issues to subsequent
review .( e.g., impacts to agricultural resources and consistency with relevant
agricultural preservation policies, capability of agencies to provide public
services to the site, the project's consistency with L<\FCO goals of
encouraging orderly development, and the project's growth inducing impacts).
Although the Otay Ranch EIR is based on a programmatic approach to
environmental assessment, which allows for the deferral of certain project-
specific issues to subsequent review, analysis of the issues listed above are
"policy-level" and should not be deferred. The purpose of a program EIR is
"to consider broad policy alternatives and program-wide mitigation measures
at an early stage when the agency has greater flexibility to deal with basic
problems or cumulative impacts" (State CEQA Guidelines, Section 15168
[b][4]). We believe that the lead agency cannot make an informed decision
ij'j/
Douglas D. Reid
September 10, 1992
Page 2
on the GDP and GP A until the analysis of these issues is provided in the program EIR. In
addition, as responsible agency, LAFCO will not be able to recertify the EIR for the
necessary LAFCO actions until the above environmental issues have been satisfactorily
analyzed. This letter covers our co=ents and concerns regarding the Otay Ranch Draft
EIR, and issues that should be addressed in subsequent "tiered" documents.
NOTICE OF PREPARATION
The discussion of the Notice of Preparation indicates that a revised NOP was circulated at
the request of LAFCO to provide additional information about the proposed project
(Section 1.3.1, page .1-19). The final EIR should clarify that the need for additional
information was one of two reasons for LAFCO's request that a revised NOP be prepared.
As discussed in our December 13, 1989, letter, there were two problems with the original
NOP: (1) a project description, location maps, and su=ary of probable environmental
effects were not provided as required by CEQA; and (2) the same NOP materials were not
received by everyone on the mailing list.
PROJECT DESCRIPTION
The project description section of the EIR contains a discussion of the project objectives,
location and setting, land uses, infrastructure, design features, development phasing, and
associated planning documents. The project description should indicate that after the EIR,
GDP and GP A are approved, additional studies will be prepared by the InteIjurisdictional
Task Force. These studies include a resource management plan, service/revenue plan,
sphere study, gove=ent options plan, and regional issues report.
Section 2.6 contains a list of agencies that have discretionary authority over the project.
Section 2.6.2.3 (Subsequent Approvals) should clarify which discretionary actions will be
subject to further environmental review. This section should indicate that an update of the
Chula Vista sphere of influence, which will include resolution of the LAFCO-designated
special study area and possible amendments to the spheres of affected special districts, will
be subject to supplemental environmental review prior to the Sectional Planning Area (SPA)
level of environmental analysis. The lead agency responsible for preparation of the
supplemental environmental document will be the City of Chula Vista.
IAFCO RESPONSIBILITIES
The environmental analysis section of the new town plan contains a description LAFCO's
responsibilities (Section 3, page 3.1-41). This section indicates that LAFCO is "responsible
for approving annexations, formation of special districts and adopting spheres of influence
L)/;
Douglas D. Reid
September 10, 1992
Page 3
for cities." This description is not entirely accurate because LAFCO's discretionary
responsibility also includes the denial and modification of proposals, and the review of
special district spheres in addition to city spheres. The description of LAFCO in the EIR
(first paragraph, Section 3, page 3.1-41) should be replaced with the following:
Delete:
L'\PCO is responsible for approymg Bftae),ation to local jurisdictions or
spedal service districts as well as for E1fl]3re-,":ng the formation of new special
service sistriets ErRS adopting :;pheres of iB:fiuenee for cities. L\FCQ's
fuRetioll5 as outlineE! m tbe Cortese/KamE :'eet indude the followin:;: to
encourage plannee, .....ell orsereE! E!e'lelo]3me13.t, and to discourage tHe
proliferation of :;in:;le ]31iIJ3ose go-:emment ageneies. De-:elopment tBat occurs
adjaeeRt to existmg de':elo]3ment anE! facilities is preferred to "leap fro:;"
de-:eloflme13.t, .....BieH requires the premature extension of facilities ilirough
liRde7'?eI0ped territor)'.
Add:
The Local Agency Formation Commission (LAFCO) is a regulatory agency with
county-wide jurisdiction established by state law (Cortese/Knox Act) to
discourage urban sprawl and encourage the orderly formation and development
of local government agencies. LAFCO is responsible for reviewing proposed
changes of organization of local governments including annexations and
detachments of territory, incorporation of cities, formation of special districts, and
consolidations, mergers, and dissolutions of districts. The Commission is also
charged with developing and updating spheres of influence for each city and
special district within the county. Spheres provide guidance for individual
proposals involving jurisdictional changes, encourage efficient provision of
organized community services, and prevent duplication of service delivery.
Territory must be within a sphere in order to be annexed to a city or district.
The second paragraph in Section 3, page 3.1-41, which describes the LAFCO designated
special study area for the western portion of the Otay Ranch property, should be expanded
to include a brief discussion of the background of the special study area. We request that
you replace this paragraph with the following:
/1'/7
'';I I
Douglas D. Reid
September 10, 1992
Page 4
Delete:
Part Elf the Otay RYler pa:reel Elf Otay RaReh is eurreHtly ee:asidered a oFleeial
study area af LA..FCO t8 smdy the future,jwisaietiGB. of the area. L~CO
&p13rsya! \\ill he aeeaea f'rior to any aerieR to meerporate all af a portiDR Elf
Otay Raneh or te amIe)( it tEl dther the City of SaR Diego or Clmla Vi:;ta.
!'TElae af the Otay Ra-:eefl property is ellrre:etly ',vitain any city's sflherc of
iB.:fllieaee.
Add:
A portion of the Otay Ranch tenitory west of the Otay Lakes (9,000 acres) was
designated a special study area in 1985 when LAFCO adopted the Chula VISta
sphere of influence. The remainder of the ownership was not included within any
adopted sphere or special study area. A sphere determination could not be made
in 1985 for the 9,000 acre tenitory because it was not in the land use element of
the Chula VISta general plan, and there was insufficient information about how
services would be provided.
A request to resolve the study area will be submitted to LAFCO after the City of
Chula VISta and County complete their joint review and adoption of a GP A,
GDP, government options plan and sphere study. Resolution of the study area
will be considered by LAFCO as part of a comprehensive update of the Chula
VISta sphere of influence. LAFCO will also update the sphere boundaries for
special districts that are in close proximity to the city or serve tenitory proposed
to be included in the city's sphere concurrent with the city's sphere update.
AGRICULTURAL RESOURCES
The agricultural section of the EIR contains a discussion of the agricultural resources within
the project site. A brief discussion of whether the proposed Otay Ranch development is
consistent with agricultural preservation policies of the County, Chula Vista, and San Diego
is provided. However, the analysis omits an important agricultural preservation policy
adopted by LAFCO and does not indicate if development is consistent with the LAFCO
policy. LAFCO's policy discourages the conversion of prime agricultural land unless the
affected agency has identified all prime agricultural land within its sphere, effective
measures have been adopted by the affected agency to preserve prime agricultural land, and
adopted prezoning would maintain agricultural land and indicate the anticipated level of
development.
!I&
Douglas D. Reid
September 10, 1992
Page 5
Because one of the purposes of a program EIR is to analyze broad policy issues, the EIR
must analyze the consistency of the proposed Otay Ranch project with all relevant policies,
including the LAFCO agricultural preservation policy. This analysis cannot be deferred, as
stated on page 3.7-25 of the EIR. Below is the agricultural policy omitted from the EIR
that we request be included and analyzed in the final EIR (LAFCO Agricultural
Preservation Policy No.2 (a-c)):
Add:
Annexation or incorporation proposals which would allow or likely lead to the
conversion of prime agricultural land or other open space land (as defined in
Sections 56064 and 56059) to other than open space uses shall be discouraged
by the Commission unless such an action would not promote the planned,
orderly, efficient development of the area, or the affected land use jurisdiction
(either city or county) has accomplished the following:
(a) Identified within its sphere of influence all "prime agricultural lands" as
defined under Government Code Section 56064;
(b) Demonstrated to LAFCO that effective measures have been adopted to
preserve for agricultural use those prime agricultural lands identified in (a). Such
measures may include, but not be limited to, establishing agricultural preserves
pursuant to the California Land Conservation Act; designating land for
agricultural or open space uses on that jurisdiction's general plan, adopted growth
management plan, or applicable specific plan; adopting an agricultural element
to its general plan; and undertaking public acquisition of prime agricultural lands
for the purpose of leasing back such lands for agricultural use; and
(c) Prezoned (city only), pursuant to Government Code Section 56375(a)2),
both territory within the agency's general planning area to be maintained for
agricultural use, and also territory within the annexation area to indicate the
anticipated level of development.
PWLIC SERVICES AND UTILITIES
The EIR contains a su=ary of the infrastructure necessary to extend services to the project
site and discussion of the jurisdictional alternatives available to provide service. A basic
problem with the public services section is that it addresses a number of technical issues
prior to analyzing the broader jurisdictional issues. We feel it is inappropriate to wait until
planning has progressed to the SPA level to begin determining the jurisdictional authority
1/1
Douglas D. Reid
September 10, 1992
Page 6
under which services would be provided. Simply listing the alternatives is not adequate for
LAFCO or CEQA purposes. LAFCO believes that an analysis of preferred jurisdictional
alternatives based on the development scenarios under evaluation (i.e., development within
Chula Vista, the County, or another jurisdiction) should be provided. The program level
analysis should focus on the financial, service, and regional impacts on service availability,
capability, and capacities.
Water Service
The EIR indicates that a number of existing and proposed agencies could provide water
service to Otay Ranch, including: the Otay Water District (WD), City ofChula Vista, City
of San Diego, Sweetwater Authority, a new water agency, or a new city. LAFCO staff has
two major concerns with the water section: (1) the lack of discussion and analysis of the
regional problems associated with an undependable imported water resource, and (2) the
lack of analysis of jurisdictional alternatives. LAFCO must use this EIR to assess the
environmental impacts associated with the jurisdictional changes and sphere
determinations/amendments (which would precede most boundary changes in this area).
Therefore, we request that more detailed analysis be provided either in this final EIR or in
a subsequent document prior to the SPA planning process.
Regional Water Issues
The EIR proposes to address the issue of water availability at the SPA level. However,
LAFCO staff believes that the programmatic structure of this process demands that policy
and regional issues be addressed at the first level of analysis. The proper time to provide
a complete analysis of regional water limitations is in this initial programmatic document
not at a project specific level of assessment. The availability of water and capability of
agencies to provide service is essential information that the lead agencies need to consider
when evaluating the GP A and GDP. In addition, LAFCO must determine the spheres for
all agencies affected by the Otay Ranch planning process prior to approval of a SPA
Therefore, the analysis of impacts associated with the various jurisdictional alternatives must
be addressed either at this level or in a supplemental EIR prior to the SPA preparation __
not at the SPA level, as indicated throughout the water section of the EIR.
Analysis of water availability issues is especially important in light of the County Water
Authority's (CW A) 1992 Strategic Plan, which acknowledges that both sources of imported
water - the State Water Project and the Colorado River Aqueduct - "have grown less
reliable in recent years, as has the Los Angeles Aqueduct ..." The report further states that
available dependable water supplies fall short of projected demand "and the gap is expected
to grow unless measures are taken to improve the availability of dependable supplies."
!;Z)
Douglas D. Reid
September 10, 1992
Page 7
The EIR analysis is extremely deficient in its discussion of the long term availability of
imported water. The EIR should bring forth a detailed discussion of the policies and goals
of both Metropolitan Water District (MET) and CW A Induded in the discussion should
be: (1) METs current and future availability of imported water from the Colorado River
Project and the State Water Project; (2) projected demands and any current plans within
MET for restrictions or limitations to existing or future water users; (3) a discussion of the
allocations from MET to CW A and whether they are finite; (4) how the diversion of water
to the Otay Ranch (and the territory not within MET) will affect the allocation of water to
other CWA agencies; (5) how growth and development in other areas of the County will be
impacted through the commitment of water resources to Otay Ranch; (6) a discussion of
CWA's policies and goals for water allocation; and (7) reasonable alternatives that MET
might implement to resolve the lack of dependable water supply (e.g., restricting the
annexation of territory outside of the METs current district boundary).
Jurisdictional Alternatives
The water section focuses much of the analysis on technical and engineering requirements
for water delivery and storage, and ignores the broader regional policy and jurisdictional
issues. A discussion of local infrastructure seems more appropriate at the SPA level of
environmental analysis, rather than at the program level. An analysis of government
structure alternatives and issues should be provided at this program EIR level of analysis.
It is necessary to identify the proposed service providers based on each of the development
alternatives under evaluation. For example, if the Otay Ranch is developed in the County,
the EIR should indicate whether it is proposed that Otay WD would continue to serve the
territory. If developed in Chula Vista, the EIR should indicate which jurisdiction would
provide water service to the site.
Otay Water District
On page 3.13-17, under the Otay WD alternative, the report states: "However, due to
existing drought conditions, there is no guarantee that an adequate water supply will be
available within Southern California, including the supply to the Otay WD from the primary
water provider, the MET." This statement seems applicable to any potential water agency
that would serve the Otay Ranch because they would all receive imported water from MET.
The EIR states that Otay WD would be a logical service choice except that it is currently
experiencing a water shortage. The statement leads the reader to believe that a lack of
water to serve Otay Ranch is a local agency problem, while it appears that all of the
alternatives have significant limitations and would require the construction of a new CW A
pipeline. Again, the impacts on the larger, regional water supply and delivery system should
be addressed at this state of project review.
~-I
Douglas D. Reid
September 10, 1992
Page 8
The EIR discusses the possibility of detaching large areas from the Otay WD, but it does
not analyze the consequences of detaching the territory from the district. A number of
questions are raised by a detachment: (1) Would detachment disrupt the district's future
plans to serve potential and existing water users within the agency's service area? (2) Would
it create a financial impact on the district that could affect water delivery or planned
upgrades to current users? (3) Would Chula Vista experience financial and/or service
impacts if it began providing water service? (4) What are the policy implications in
expanding the agency membership in CW A? (5) What are the costs to existing users and
could those costs translate into service impacts or a reduction of water supply to existing
users?
City of Chula Vista
The City of Chula Vista alternative discussed on page 3.13-17 proposes dividing Otay WD
into three large areas (no maps were provided to show the proposed division). This
discussion is very confusing. The EIR indicates that the Otay Mesa area and Otay WD
facilities would be "transferred" to the City of San Diego for service. The EIR does not
discuss how facilities would be transferred to San Diego. Would the area annex to San
Diego? Would it remain under Otay WD with contractual service to San Diego? What
impact would this transfer of service have on existing customers, San Diego, and Otay WD?
The EIR indicates that the central area would be under the control of Chula Vista
(assuming the Otay Ranch is annexed to Chula Vista), and that water would be provided
by the South Bay ID and Otay WD. The EIR states that the South Bay ID would become
a subsidiary district of Chula Vista. The EIR should discuss the requirements for
establishing a subsidiary district. For example, at least 70% of a district's land area and
registered voters must be located within in a city in order to be established as a subsidiary
district (Government Code Section 57085). An analysis of the impacts to South Bay ID
customers and the Sweetwater Authority, which wholesales water to South Bay ID, should
also be included. Finally, under this alternative, the northern area would remain within a
fissured Otay WD. What are the financial and service impacts to the Otay WD as a result
of this alternative?
Other Water Service Alternatives
The remaining alternatives outlined in the Draft EIR include annexation of Otay Ranch into
the South Bay ID and Sweetwater Authority, formation of a new water district, formation
of a new city, and the groundwater alternative. The discussion of these alternatives is so
cursory that they cannot be viewed in their present form as realistic alternatives. This
document must provide reasonably researched alternatives that not only address perceived
d-;)
Douglas D. Reid
September 10, 1992
Page 9
benefits to the development of Gtay Ranch, but also address the service, planning, legal, and
financial impacts to the existing agencies and residents. LAFCG policies on adoption of
spheres of influence and jurisdictional boundary changes should also be addressed as they
relate to each alternative.
Mitigation Measures
The EIR identifies proposed mitigation measures for water service. The second mitigation
measure on page 3.13-21 requires that "prior to approval of any SPA Plan for Gtay Rajlch,
it shall be determined which water district will serve the proposed SPA" This is not a
mitigation measure. The determination of which agency will provide water service to Otay
Ranch will be made after an application for one of the alternatives is submitted to LAFCO.
LAFCO has the authority to approve, deny, or modify any proposal submitted for its
consideration. If the jurisdictional determinations are to be made p'rior to any SPA
consideration (which LAFCO believes is appropriate), then this document cannot defer the
analysis of environmental impacts of the jurisdictional alternatives to the SPA EIR.
Sewer Service
The sewer service section of the EIR contains a discussion of a number of ways sewer
service could be provided to the Otay Ranch (i.e., Chula Vista, Otay WD, City of San
Diego, formation of a new sanitation district or city). We have similar concerns about the
sewer section as was discussed in the water section of this letter. The EIR fails to provide
a detailed discussion of regional alternatives to meet future sewage treatment capacity needs
and disposal. The EIR mentions that the outfall capacity for the Point Loma plant will be
reduced to 150 mgd when upgraded to secondary treatment. However, it does not address
the impact this reduction will have on cities such as Chula Vista, which have purchased
excess "contractual" capacity.
The existing conditions section mentions several proposed treatment plants in the South Bay,
but it is unclear whether any or all of the capacity in those proposed plants would be
available for Otay Ranch. The existing conditions section needs to explain clearly what the
current limitations of sewage disposal are, and the potential impact to existing sewer
agencies when the Point Lorna plant shifts to secondary treatment. It must also explain the
timing and phasing of the proposed Clean Water Program.
The sewer service section is also very confusing regarding the discussion of sewer capacity.
The EIR does not distinguish between "physical" and "contractual" capacity. Physical
capacity is an engineering standard related to the capability of facilities to transport and
treat effluent, while contractual capacity is related to an agency's negotiated entitlement to
5:5
Douglas D. Reid
September 10, 1992
Page 10
receive sewer service. The EIR discussion of capacity needs to address and distinguish
between both types of sewer capacity.
Fire Protection
As with water and sewer service, the EIR needs to contain a discussion of fire protection
based on the development alternatives under evaluation in the EIR. With exception of the
extreme northern and eastern territories which are within the Rural Fire Protection District
(FPD), most of the Otay Ranch is outside the boundaries of any fire district. If developed
in the County, the EIR should indicate if the territory is proposed to annex to the Rural
FPD or if a different district must be formed. If detachment from the Rural FPD is
proposed, then the impact on the remaining portion of the district needs to be analyzed.
A similar discussion should be provided for each of the development alternatives under
evaluation. The fire service analysis should focus on response times, capabilities, constraints,
and needed facilities.
GROWTH INDUCEMENT
According to the EIR, the Otay Ranch project will be growth inducing because it will
introduce new services and facilities in territory where limited services are currently
available. While the EIR contains general statements about the growth-inducing aspects of
the project, an analysis of the effects of growth inducement on surrounding territory is not
provided. Typically, growth-inducing impacts are quantified in terms of the amount of
additional development that could be expected in surrounding territory. Maximum build-out
based on the densities allowed under the existing general plans for the surrounding territory
needs to be analyzed. Conclusions drawn from the analysis can then be used to determine
the significance of the growth-inducing impacts. We believe the lead agency needs this
information and analysis to consider the proposed GDP and GP A
ORDERLY DEVELOPMENT
The Otay Ranch EIR must address the relationship between the proposed project and
LAFCO's state-mandated responsibilities. LAFCO's functions as outlined in the
Cortese/Knox Act include the following: to encourage planned, well-ordered, and efficient
patterns of development; to preserve open space and agricultural lands; and to discourage
the proliferation of single-purpose gove=ent agencies. Development that occurs adjacent
to existing development and facilities is preferred to "leap-frog" development, which requires
the premature extension of facilities through undeveloped territory. "Leap-frog"
development can result in the premature loss of open space and agricultural land, growth
inducement, inefficient delivery of services, costly extension of facilities, and strains on
~r
Douglas D. Reid
September 10, 1992
Page 11
regional facilities. The Cortese/Knox Act also states a preference for multi-purpose
agencies (cities) providing urban services over several limited purpose agencies (districts).
In order for LAFCO to use the EIR, it must contain a discussion and analysis of whether
orderly development would occur based on each of the development alternatives under
evaluation. These are issues appropriate for the lead agency's consideration when
evaluating the proposed GP A and GDP, and should not be deferred as "LAFCO issues."
In summary, LAFCO's concerns regarding the Otay Ranch EIR pertain to the adequacy of
the document for consideration of the proposed GDP and GP A, and information that it
must include for "tiering" of future EIRs. The analysis of too many environmental issues has
been deferred to subsequent project-level documents. The EIR also contains a
disproportionate amount of technical and engineering-related information, rather than
environmental analysis on policy and program issues. In particular, we are concerned about:
(1) the lack of analysis on impacts to agricultural resources; (2) whether the Otay Ranch
project is consistent with relevant agricultural preservation policies; (3) capability of agencies
to provide public services to the project; (4) the project's consistency with LAFCO goals of
encouraging orderly development; and (5) the project's growth-inducing impacts. As a
responsible agency, LAFCO can only utilize and recertify the document if it includes
information and environmental analysis critical to LAFCO's review. We request your
serious consideration of our comments so that the deficiencies in the EIR can be addressed
in the final document and similar ones avoided in subsequent "tiered" documents. LAFCO
defers to your judgement (lead agency), as to whether the addition of the necessary analysis
in the program EIR will constitute sufficient new information to warrant a recirculation of
the document for additional review. If you have any questions regarding our comments,
please contact me at 531-5400.
Sincerely,
~~
MICHAEL D. OTT
Assistant Executive Officer
MDO:ih
cc: George Krempl
Bob Leiter
Tony Lettieri
Lari Sheehan
Lauren Wasserman
Bill Healy
Kent Floro
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SEPTEMBER 11, 1992
TO WHOt1 IT t'lAY CONCEF:N,
I AM CONCERNED THAT THE REVIEW PERIOD FOR THE EIR 10
INADEQUATE FOR SUFFICIENT STUDY. I FEEL THAT THE AREA THAT
I S PROPOSED FOR DE\)ELOPt1ENT HAS ~IAJ,IY :3Et'IS I T I t)E ! S:3:JE'='
F.:ELE~)At".JT TO OUR OPEN ~::PACE:=;, HAE:ITAT Pr:;;~E'=;ERt.)ATI cr..! P-t,;O ;-UE
13Ei".JERAL PLAN Ar'1Er'.~Dr1Ej".JT.
F'LEASE E;(TEND t'W AS I L I TY TO UNDERSTAND THE I r.1PL I CAT I oris
fiJITHIt'..J THE It','1F'ACT OF ~=:UCH 8-: e'EI.)ELCiF't"1Ei'.lT _ E><TENDlt',lC3 THE
RE') I EJ,J PER I OD FOR t'lYSELF AND OTHER:=',
THA:"..u< 'YDU,
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CAROLINE E. COULSTON
ATTORNEY AT LAW
141.8 SOUTH El CAMINO REAL, SUITE III
ENCINITAS, CAUFORNIA 92024
(619) 943.1061
September II, 1992
Anthony J. Lettieri
Otay Ranch Project Plarming Office
315 Fourth Avenue, Suite A
Chula Vista. California 91910
RE: Comments by South County Environmental WoIXing Group
Otay Ranch Draft Program Environmental Impact Repon
EIR 90-01 (City of Chula Vista)
Log #89-14-98 (County of San Diego)
SCH #89010154 (State of California)
Dear Mr. Lettieri:
I have been retained to legally represent the South County Environmental Working Group, a
fact finding educational organization formed for the purpose of examining the Otay Ranch Project.
The South County Environmental Working Group is hereby formally requesting an extension of the
public review period for the 4000 page Otay Ranch Draft Program EIR until December 7, 1992,
I need not remind you that the beneficial effect of public participation on the environmental
review process is one of the strongest themes running through the body of CEQA law. One of the
major functions of the EIR is to ensure that all reasonable alternatives are thoroughly assessed. An
EIR serves to demonstrate that the lead agency has in fact analyzed and considered the ecological
impliCations of its actions.
No meaningful consideration of this document, which will have significant impact on the
entire region. can possibly be made in the 60 days alloned by the City of Chula Vista City Council.
The Lead Agency must provide the public adequate time for review and comment on a Draft EIR.
(CEQA Guidelines g 15203). Of course, failure to comply with the CEQA guidelines may constitute
abuse of discretion justifying the issuance of a writ of mandate. Benton v. Board of Suoervisors of
Naoa County, 226 Cal.App.3d 1467, 277 Cal.Rptr. 481 (1991).
The unprecedented scope. complexity and length of the EIR requires an extension of the
(--:-7
,:::)
South County Environmental Working Group
Otay Ranch Comments
September 1~ 1992
2
review period. The CEQA Guidelines specifically provide for a 90 day review period except in
"unusual circumstances." (CEQA Guidelines ~ 15105). This document is 4000 pages long, whereas
proposals of unusual scope or complexity should "normally be less than 300 pages." (CEQA
Guidelines ~ 15141). The 23, 088 acre size of this project and the 4000 page length of the EIR
clearly qualifies as "unusual circumstances." The suggested 60 day extension of the review period
provides a reasonable balance of the interests of the applicants to move expeditiously and the public to
adequately respond to the EIR.
It is particularly imponant in this case that sufficient review time be given since this is a
Program ErR which will have long lasting effects. All environmental documents on later parts of the
program need only focus on new effects not considered in the Program EIR. (CEQ A Guidelines ~
15168(d)(2)). Documents penaining to subsequent projects can incorporate by reference all materials
from the Program EIR. Therefore, the Program EIR acts as an analytical superstructure for
subsequent analysis and must provide an ecologically sound basis for later projects.
The transcript of the July 30, 1992 hearings indicates that the decision to limit the review
period to 60 days was based in part on review periods granted for recent local EIRs. The EIRs
discussed, including the Black Mountain EIR and Central Mountain Update, are all documents of less
than 500 pages. Funhermore, these projects often concerned only one or two salient issues.
Comparisons between this EIR and those of General Plans are funher misleading in that a project EIR
will necessarily be more detailed in the specific effects of the project than will be an EIR on the
adoption of a general plan. (CEQA Guidelines ~ 15146(a)). The OlaY Ranch EIR is unlike the EIRs
mentioned at the hearing as it concerns the largest project in California and is an ali inclusive
manuscript addressing all issues.
The limited review of the EIR which has been possible to date indicates that this Draft EIR is
not a comprehensive document as required by CEQA. (CEQA Guidelines ~ 15120). First, discussions
. with Baldwin staff have indicated that an additional "staff recommendations" document will be
submitted to the Planning Group this month providing yet another alternative. Naturally, such a
document should be made part of this EIR in order that all proposed alternatives can be examined
simultaneously. If, subsequent to public review significant new information, such as the proposed staff
recommendations, is made available then the agency must issue a new notice and must recirculate th.e
,5}j
South County Environmental Working Group
Otay Ranch Comments
September 11, 1992
3
EIR for additional commentary and consultation. (Pub. Resources Code, g 21092.1; See also Sutter
Sensible Planning. Inc. v. Board of Suoervisors 122 Cal.AppJd 813, 822 (3d DiSl 1981). Efficiency
demands an extension of the present co=ent period in order that the forthcoming alternative can be
thoroughly considered.
Second, the document alludes to an upcoming Wildlife Corridor Study, which only became
available 30 days after the review period began, and to a Resource Management Plan Phase II which
will only be available if this EIR becomes certified. As much of the New Town Plan appears to rely
on these studies as the basis for the EIR analysis it is clear that no reasoned decision can be reached
on the basis of the current document. The public and the decision makers cannot be expected to view
these documents in isolation from one another and still fulfill the goals of CEQA.
Third, the EIR directly makes reference to substantial changes in the San Diego County
General Plan. The General Plan Amendments are not due for public review until the end of this
month. Again, the documents must be reviewed at the same time in order to meaningfully analyze
consistency of the ErR with the amendments.
Fourth, the Draft EIR is incomplete in that it does not yet include correspondence between the
applicant and the applicable agencies. A request has been made, pursuant to the California Records
Act of 1968 (Government Code gg 6250 - 6265), that all documentation in the form of letters, repons
and all forms of written correspondence exchanged during the processing period of the Otay Ranch
Development ErR be submitted as official filings to become part of the EIR' s permanent record. (See
Letter from Pat Parris to Otay Ranch Joint Planning Project (Aug. 19, 1992)). The attorney's office of
the City of Chula Vista has indicated an unwillingness to comply with the request and will not supply
the information. Recent case law indicates the prudence in continuing to insist on the inclusion of
these materials. (Del Mar Terrace Conservancv v. City of San Diel!o. San Diego Sup. Ct. # 537406
on aooeal Ct. App. 4th Dist. # 0015851) (Court held that, even though correspondence between
applicant and city indicated intent to thwart the CEQA process, the intent of the documents could not
be assessed by the court since the documents were never made pan of the CEQA record for the
preliminary decision makers to review.) Until these documents become part of the EIR it will remain
only a partially complete document.
<--'"/
".J (
South County Environmental Working Group
Ota} Ranch Comments
September 11, 1992
4
The South Coast Environmental Working Group intends to participate in the public process
and thoroughly review and analyze the Draft EIR. Indeed, members have already begun the massive
undertaking. However, the unprecedented range and content of the document and the fact that the
document is incomplete make it clear that USeful examination will not be possible in only 60 days. To
preserve the integrity of the process the citizens of San Diego County must be given the opportunity to
fully and carefully analyze the EIR.
For all the above reasons, we are hereby formally requesting an extension of the comment
period until December 7, 1992.
. /
/~L~l
Caroline E. Coulston ~
Attorney for South County Environmental Working Group
cc: Mayor Tim Nader, City of Chula Vista
George Bailey, Chair San Diego County Board of Supervisors
Clerk San Diego Board of Supervisors
Christine Kinney, .Attorney for California Resources Agency
(1)
-
....
September 12, 1992
Mayor Tim Nader
276 Fourth Avenue
Chula Vista, CA 91910
Dear Mr. Nader:
Since the release of the Otay Ranch Draft Program
Environmental Impact Report for public review I have been
studying the sections relating to groundwater, an area in
which I have some experience and a good deal of concern. I am
a geologist by education (though not by profession) and I
participated in the drafting of the recently adopted county
Groundwater Ordinance, as John Peterson of the Department of
Planning and Land Use can attest.
On the subject of Otay Ranch groundwater, I am very concerned
about some potential problems that the EIR does not address -
at least not that I can find. The areas which concern me are:
1) There are a number of references to the lOa-year
floodplain and what should be done to avoid encroachment,
or to avoid impacts where encroachment is allowed. It is
also stated that each plan will increase impermeable
surface area by some amount (57 percent, in the case of
the New Town Plan). However, I do not find any discussion
of how much the area of the lOO-year floodplain will be
expanded by the increased runoff; or whether, in fact, the
lOa-year flood will become a la-year flood because of
increased runoff.
2) Section 3.9.2.2 makes some statements which I simply do
not understand about groundwater recharge in the river bed
making up for reduced recharge elsewhere; there is
apparently some leap of logic here which surpasses my
knowledge of groundwater hydrology.
3) The discussion (section 3.9.3) of the projected downstream
effects of increased runoff of fertilizers and pesticides
from developed areas is minimal, and refers to a 1991
study which must be analyzed to understand the mitigation
proposed.
4) I find no discussion of saline inflow into the groundwater
dependent areas of the project due to lowering of the
water table from increased pumping and decreased recharge;
is this a potential problem?
1
SE;:J ~
&7/
/~
"
/
,/
It is possible that all' these questions are addressed in one
or more of the five prior studies referenced in paragraph
3.9.1, or in other documents mentioned throughout the text,
and I intend to review them as quickly as I can. The problem
is time. The Board of supervisors and the City Council
allocated a very limited period of time to review a document
the size of the otay. Ranch EIR. Upon initial examination of
almost any section of the EIR, the reader finds, as I did in
the case of groundwater, that there are several other
documents that must be studied in order to make a fair and
rational assessment of the EIR.
At your joint meeting on July 30, you agreed that the review
period for the EIR could be extended if warranted. If my
experience in studying the groundwater issue is any
indication, such an extension is clearly necessary if you
want to have a meaningful review of this EIR.
Sincerely,
~~
Clark Waite
P.o. Box 247
Descanso, CA 91916
cc: George Bailey, Anthony Lettieri
2
!oJ.
September 12, 1992
Anthony Lettieri
General Manager
otay Ranch Joint Planning Committee
315 Fourth Avenue, suite A
Chula vista, CA 91910
r~'~'l ~_~}~~1; j -~7' [] ~:\1
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Dear Mr. Lettieri:
since the release of the Otay Ranch Draft Program
Environmental Impact Report for public review I have been
studying the sections relating to groundwater, an area in
which I have some experience and a good deal of concern. I am
a geologist by education (though not by profession) and I
participated in the drafting of the recently adopted County
Groundwater Ordinance, as John Peterson of the Department of
Planning and Land Use can attest.
On the subject of otay Ranch groundwater, I am very concerned
about some potential problems that the EIR does not address -
at least not that I can find. The areas which concern me are:
1) There are a number of references to the lOa-year
floodplain and what should be done to avoid encroachment,
or to avoid impacts where encroachment is allowed. It is
also stated that each plan will increase impermeable
surface area by some amount (57 percent, in the case of
the New Town Plan). However, I do not find any discussion
of how much the area of the lOa-year floodplain will be
expanded by the increased runoff; or whether, in fact, the
lOa-year flood will become a la-year flood because of
increased runoff.
2) Section 3.9.2.2 makes some statements which I simply do
not understand about groundwater recharge in the river bed
making up for reduced recharge elsewhere; there is
apparently some leap of logic here which surpasses my
knowledge of groundwater hydrology.
3) The discussion (section 3.9.3) of the projected downstream
effects of increased runoff of fertilizers and pesticides
from developed areas is minimal, and refers to a 1991
study which must be analyzed to understand the mitigation
proposed.
4) I find no discussion of saline inflow into the groundwater
dependent areas of the project due to lowering of the
water table from increased pumping and decreased recharge;
is this a potential problem?
1
t;_:1
It is possible that all these questions are addressed in one
or more of the five prior studies referenced in paragraph
3.9.1, or in other documents mentioned throughout the text,
and I intend to review them as quickly as I can. The problem
is time. The Board of Supervisors and the City Council
allocated a very limited period of time to review a document
the size of the otay Ranch EIR. Upon initial examination of
almost any section of the EIR, the reader finds, as I did in
the case of groundwater, that there are several other
documents that must be studied in order to make a fair and
rational assessment of the EIR.
At your joint meeting on July 30, you agreed that the review
period for the EIR could be extended if warranted. If my
experience in studying the groundwater issue is any
indication, such an extension is clearly necessary if you
want to have a meaningful review of this EIR.
sincerely,
Clark Waite
P.o. Box 247
Descanso, CA 91916
cc: George Bailey, Tim Nader
2
w
September 12t 1992
,~ ~ ~ i2 ~"I7r.=> '""-,'
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Hon. Brian P. Bilbray
Board of Supervisors - District 1
.. CHULA VISTA
COUNCIL MEMBERS:
Hon. George F. Bailey
Board of Supervisors - District 2
Shirley Grasser-Horton
Jerry Rindone '
Leonard Moore
David Malcolm
Hon. SUBan Golding
Board of Supervisors - District 3
Mayor Tim I.M. Nader
City of Chula Vista
276 4th Avenue
Chula Vista, CA 91910
Hon. Leon L. Williams
Board of Supervisors - District 4
Hon. John MacDonald
Board of Supervisors - District 5
County Administration Building
1600 Pacific Highway
San Diego, CA S~lOl
Mr. Anthony J. 'Lettieri, General Manager
otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
..XH"NSION Of TIM!:. TO REVIEW ENVIRONMENTAL. IMPACT REPORT
OTAY RANCH PROJECT - HEARING DATE: SEPTEMBER 16, 1992@S P.M,
As a citizen of San Diego County and a p~oponent of
ecologically sound community development I ~equest that the
public ~eview pe~iod of the Dtay Ranch Envi~onmental Impact
Repo~t (EIR) be extended an additional sixty days to the date of
Oecmeber' 07. 1992.
It is impe~ative that the EIR ~eview pe~iod allow fo~
tho~otJgh and complete analysis of the ecological impacts of th,,,
p~oject. Without such allowance, violation of the Cal ifo~n'a
Envi.cnmental Qu~1 ity Act ICEQA) guidel ;nes may be alleged.
CEQA was
part i c i pat! on
the wisdom and
enacted primarily for the benefit
in the environmental review process.
foresight to grant this request for an
of public
Pleas", h",vp'
extension.
Respectfully Submitted,
~dL~
.3/ ::r-Y' ~~ fr
4a/J ~--L-L...C)?J / L /7 ~ /
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September 12, 1992
Anthony Lettieri
General Manager
Otay Ranch Joint Planning Committee
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
~:~~-~------_. ~-_..--;
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Dear Mr. Lettieri:
Since the release of the Otay Ranch Draft Program
Environmental Impact Report for public review I have been
studying the sections relating to groundwater, an area in
which I have some experience and a good deal of concern. I am
a geologist by education (though not by profession) and I
participated in the drafting of the recently adopted County
Groundwater Ordinance, as John Peterson of the Department of
Planning and Land Use can attest.
On the subject of Otay Ranch groundwater, I am very concerned
about some potential problems that the EIR does not address -
at least not that I can find. The areas which concern me are:
1) There are a number of references to the lOa-year
floodplain and what should be done to avoid encroachment,
or to avoid impacts where encroachment is allowed. It is
also stated that each plan will increase impermeable
surface area by some amount (57 percent, in the case of
the New Town Plan). However, I do not find any discussion
of how much the area of the lOa-year floodplain will be
expanded by the increased runoff; or whether, in fact, the
lOa-year flood will become a la-year flood because of
increased runoff.
2) section 3.9.2.2 makes some statements which I simply do
not understand about groundwater recharge in the river bed
making up for reduced recharge elsewhere; there is
apparently some leap of logic here which surpasses my
knowledge of groundwater hydrology.
3) The discussion (section 3.9.3) of the projected downstream
effects of increased runoff of fertilizers and pesticides
from developed areas is minimal, and refers to a 1991
study which must be analyzed to understand the mitigation
proposed.
4) I find no discussion of saline inflow into the groundwater
dependent areas of the project due to lowering of the
water table from increased pumping and decreased recharge;
is this a potential problem?
1
t: b7
It is possible that all these questions are addressed in one
or more of the five prior studies referenced in paragraph
3.9.1, or in other documents mentioned throughout the text,
and I intend to review them as quickly as I can. The problem
is time. The Board of Supervisors and the City Council
allocated a very limited period of time to review a document
the size of the otay Ranch EIR. Upon initial examination of
almost any section of the EIR, the reader finds, as I did in
the case of groundwater, that there are several other
documents that must be studied in order to make a fair and
rational assessment of the EIR.
At your joint meeting on July 30, you agreed that the review
period for the EIR could be extended if warranted. If my
experience in studying the groundwater issue is any
indication, such an extension is clearly necessary if you
want to have a meaningful review of this EIR.
Sincerely,
Clark Waite
P.o. Box 247
Descanso, CA 91916
cc: George Bailey, Tim Nader
v.
2
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Sept. 12, 1992
: r~ ~~ r;~--~ '= U \'.171 ''5' It;::
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u~1 SEP: 6 J@i
I
To Members of the County of San Diego and City of Chula
Vista Planning Commissions,
This is a request from the Chaparral Greens of East County
to extend the review period for the EIR regarding the Otay
Ranch/Baldwin project by at. least another 90 days.
Our group has been worKing dil igently to help represent the
thinKing in our community regarding this development. It is
one of the largest proposed developments in the country, let
alone our county and from the 1 imited time which we have had
to study thE- program, I......"? h.:,\}e many concerns and quest ions.
The Chaparral Greens feel that the extraordi nary r,ature of
this program is more than adequate reasoning for an
extension of the r~view period. Our group has been
represented at most County and City meetings to gain
c 1 ar i f i cat i on an d tog i ve ou r i n put, bu t we fee 1 t hat the
short period for review has left us frustrated, especially
with our publ ic representatives.
As voting citizens we are greatly annoyed that the only
voice that seems to g~t recognition is that of the Baldwin
Corporation; whose short term involvement with our community
cannot compare with the responsibil ity which those of us who
1 ive and worK here will have to endure.
Please respond to our request by granting another 90 days
for us to worK together to insure that as many people as
possible will ',,,,in' in the future of this proposed
development.
Sincerely,
~10~{~:~
Chaparral Greens
tt
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Se p t. 13, 1992
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Dear Sirs and Madams,
I have concern over the short time allowed for reading the
ErR regarding the Otay Ranch project. I bel ie<.Je that an
extention of review period is appropriate due to the length
of campl icated materials involved in ex~dning and time to
respond to such a huge- project.
I am requesting that more time be given so that information
and questions regarding this program can be explored to the
satisfa.ction of concerned citizen':'. I think th.at at least 3
more months be allowed for the reading and digesting of this
mat-er i a.l .
I appreciate your attention to this matter.
~O"#r~
Hall~iams
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September 13, 1992
Dr. Richard Wright
County of San Diego
Planning Commission
5201 Ruffin Rd., Suite B
San Diego, CA 92123-1666
.-.-----
SUBJECT: Written comments and questions for the Commissioners at
the Joint Workshop on Sept. 16, 1992.
Commissioner Wright:
The agenda for the Joint San Diego County I City of Chula Vista
Planning Commission Workshop to be held on Wednesday evening,
September 16, 1992 includes several items of interest to me.
Unfortunately, there is a conflict with our regular Valle de Oro
Community Planning Group meeting and I will be unable to attend
the workshop to make my comments in person. With this note, I
would convey to you some of my concerns hoping that you and
others will be able to address them on the record. I will obtain
a copy of the minutes of the Workshop as soon as one is
available.
Agenda Item III: Public Comment
Several issues have
review of the DEIR
procedural in nature,
a category of rumor
clarification on these
come to my attention during the initial
for the Otay Ranch Project. Some are
some are informational, and some fall into
control. I would like to receive
matters - for the record.
Issue: "Lead Agency".
Review of the DEIR informs me for the first time that no part of
the Otay Ranch Project is within either the city limits or the
"sphere of influence" of Chula Vista. The following citations of
the state CEQA Guidelines and portions of the Public Resource
Code provide for the determination of the "Lead Agency" for the
purpose of preparing the environmental documentation.
Section 15367 of the Guidelines
"Lead Agency" means the public agency which has the principle
responsibility for carrying out or approving a pro;ect.
page one of six
/1'
Section 15051 of the Guidelines - Criteria for Identifying the
Lead Agency.
(b) If the project is to be carried out by a nongovernmental
person or entity, the Lead A~ency shall be the public a~ency with
he rea test responsibility for supervising or approving the
project as a woe.
(2) Where a city prezones an area, the city will be the
appropriate Lead Agency for any subsequent annexation of the
area and should prepare the appropriate environmental document
at the time of the prezoning. The Local Agency Formation
Commission shall act as a Responsible Agency.
(c) Where more than one public agency equally meet the criteria
in subsection (b), the a~ency which will act first on the project
in question shall be the Lead A~ency.
(d) Where provisions of subsections (a), (b), and (c) leave two
or more public agencies with substantial claim to be the Lead
A~ency, the public agencies may by agreement designate an agency
as the Lead Agency. An agreement may also provide for cooperative
efforts by two or more agencies by contract, join~ exercise of
powers, or similar devices.
Section 21067, Public Resources Code
"Lead Agency" means the public agency which
responsibility for carrying out or approving a
have a significant effect upon the environment.
has the principle
project which may
Questions:
Given the above Guidelines and Code sections, by what authority
did the County delegate the responsibility of Lead Agency to the
City of Chula Vista? The MOU dated August 1, 1989 acknowledges
the abnormal arrangement without justifying it. What "studies"
are underway byLAFCO regarding this project area?
Issue: "Tiering" of the EIR and the proposed GPA.
Several Sections of the State CEQA Guidelines address
of "tiered" EIRs:
the matter
Section 15385 of the state Guidelines
\
"TIERING" refers to the coverage of general matters in broader
EIRs (such as on general plans or policy statements) with
subsequent narrower EIRs or ultimately site-specific EIRs
incorporating by reference the general discussions and
concentrating solely on the issues specific to the EIR
subsequently prepared. Tiering is appropriate when the sequence
~f EIRs is:
page two of six
~
a) From a general plan, policy, or program ErR to a program,
plan, or policy EIR of lessor scope or to a site-specific EIR.
b) From an EIR on a specific action at an early stage to a
subsequent EIR or a supplement to an EIR at a later stage.
Tiering in such cases is appropriate when it helps the Lead
Agency to focus on the issues which are ripe for decision and
exclude from consideration issues already decided or not yet
ripe.
Section 21083.3 of the Public Resource Code
(a) If a parcel has been zoned to accommodate a particular
density of residential development or has b.en designated in a
community plan to accommodate a particular density of residential
development and an environmental impact report was certified for
that zoning or planning action, the application of this division
to the approval of any subdivision map or other project that is
consistent with the zoning or community plan shall be limited to
effects upon the environment which are peculiar to the parcel or
to the project and which were not addressed as significant
effects in the prior environmental impact report. If a
residential development project is consistent with the general
plan of a local agency and an environmental impact report was
certified with respect to that general plan, the application o~
this division to the approval of that residential development
project shall be limited to effects on the environment which were
not addressed as significant effects in the prior environmental
impact report. Nothing in this section affects any requirement to
analyze potentially significant off site impacts and cumulative
impacts of the project not discussed in the prior environmental
impact report with respect to the general plan. Section 15152.
Tiering(c) Tiering under this section shall be limited to
situations where the project is consistent with the general plan
and zoning of the city or county in which the project would be
located.
Discussion:
This section recognizes that the approval of many projects will
move through a series of separate public agency decisions, going
from approval of a general plan, to approval of an intermediate
plan or zoning, and finally to approval of a specific development
proposal. Each of these approvals is subject to the CEQA process.
Question:
I am hearing this week that the 300 page EIR for a proposed
General Plan Amendment will be made available to members of the
public on or about September 22, 1992 for a 30 day review period.
How can this sequence of events be squared with state CEQA
Guidelines regarding a tiered project EIR being appropriate in
cases where the proposed project is consistent with an existing
page three of six
7~
General
proposed
enormous
Plan? Are we now expected to review and comment on a
GPA EIR at the same time we are wading through the
DEIR on Otay Ranch? Is this feasible? Reasonable?
Issue: Additional alternatives to the project.
I am told there have been informal offerings
alternative to the proposal. This "alternative"
been prepared and "completed" late in the day on
of an additional
is said to have
Sept. 9, 1992.
Question:
Will this be presented
review? What exactly is
members of the Project
period of public review of
to members of the public for formal
this "alternative" being called by
Team? How will this matter affect the
the DEIR on the proposed project?
Issue: More information available on Wildlife Corridors.
I am told that an updated version of the Wildlife Corridor Study
became available early in September. I have not received it and
formally request that I be sent a copy.
Question:
How does the over 30 day delay in this information getting to
members of the public affect the period for public review of the
environmental documents?
Issue: Clarification of what body will actually make the decision
to extend the period of public review - or not to extend it.
I am .challenging the legitimacy of the City of Chula Vista as
"Lead Agency" on this project. Some have suggested that the Chula
Vista Planning Commission will make the decision regarding
extension of the public review period. If the City of Chula Vista
intends to continue as Lead Agency, can we assume that the Chula
Vista City Council will make the call? At what public meeting? I
am asking for formal notice and an agenda.
Issue: Clarification of legal "indemnification".
At the Joint Workshop of the City of Chula Vista and the County
of San Diego where the determination was made for a 60 day
review, a matter of legal responsibility in matters of
environmental documentation arose. The Chula Vista City Attorney
assured the County Board of Supervisors that the City of Chula
Vista was responsible and that Baldwin Co. would "indemnify" tbe
City. The Supervisors asked for, and seemed to receive, the same
"indemnification" from the Baldwin Co. representatives present.
page four of six
73
Question:
What is the specific nature
Should Baldwin Co. somehow
some type of bankruptcy,
affected?
and extent of such "indemnification"?
abandon the project or be forced into
how will such "indemnification" be
Issue: Unpaid bills rumored.
It is rumored that some of the required environmental studies and
fieldwork have been unfunded or payment has been withheld. Is
this true? What specific cases can be made public? Does this
affect the status of the proposal?
~genda Item IV. B. Public Comment of the DEIR
My comments at this stage
preparing detailed written
will submit them at a later
must be
comments
date.
general in nature. I am
for review and response and
Being forced to assume a 60 day period for review has altered
what could (should) have been a careful' and reasoned review into
a rushe~ and rather frantic attempt in some cases to cover the
bases. The review period must be extended and not merely 15
days at a time. It is crucial that this enormous and future
determining project receive adequate review by members of the
public and by the responsible decision-making agencies.
Here, I reintroduce my letter dated
determination of adequate period
additional citation of the state
the length of. the usual Summary in
July 23, 1992 (attached)
for public review and I add
CEQA Guidelines pertaining
an EIR.
re
an
to
Section 15123. Summary
(c) The summary should normally not exceed 15 pages.
The Summary section in the DEIR for Otay Ranch runs to 21 pages.
As an additional justification for time extension, I point out
that numerous studies and papers are cited and incorporated by
reference into the body of the DEIR. There must be a fair
opportunity for the public and the decision-makers to review
these supporting materials and to comment on their adequacy and
relevance.
Since the project depends on approval of a General Plan
Amendment, and CEQA Guidelines require the EIR to address the
issue of consistency with the existing General Plan provisions,
how can the public or the decision-makers involved make a fair
assessment of this project until a General Plan Amendment is
page five of six
7q
fully processed,
Amendment should
Baldwin proposal.
reviewed, and
not be viewed
implemented?
as a mere
A General Plan
detail within the
I am that the time eriod for ublic review be
suspen e uring consideration of the EIR for the General Plan
Amendment and that the length of public review be reconsidered
when the final decision has been made on that GPA.
I will submit detailed comments on the DEIR at a future date, in
the meanwhile, as an example of its inadequacy, I point to
supporting data and determination of wildlife corridors for the
mountain lion population on the project site. I am told that
proposals for radio tracking and full study were submitted to the
Project Team by resource agencies and that these proposals were
turned down. Is this true? What specific mountain lion studies
have been done? Where can I find the science? Do two recent
sightings of "mountain lion sign" constitute a study? How are
these "corridors" determined in the absence of such science?
In .the Appendix A-3, Felis concolor (Mountain Lion)
apparent status . --1--1--. Is it the position of
Team that Mountain Lions enjoy no protection?
is given no
the Project
Boiled down, my comments at this
~ime allowed for full review
sequencing of these proposals.
point are:
and there
there must
must be a
be more
proper
Agenda Item V.
I support the request by the South County Environmental Working
Group for complete documentation in the administrative record of
any and all correspondence between and among all public agencies
and the proponents of this project regarding this project and
formation of task forces and teams to work on it.
I continue to follow this project closely and will look to the
administrative record for answers to my questions.
Daniel Tarr
11524 Fuerte
El Cajon, CA
619 588-4863
Farms Rd.
92020
~J
~
Sincerely,
cc: State Office of
Diego County Board
members, Otay Ranch
Planning Commission,
Planning and Research, Members of the San
of Supervisors, Chula Vista City Council
Project Team, Chair of the Chula Vista City
South County Environmental Working Group.
page six of six
7~
Palomar Audubon Socie~-::c ,--
P.O. Box 2483 - '.' -~=-'_:~_:.~ ==--=--=-=.
Escondida, CA 92033
,....--. ,...
....- '"' ....
'J'-'
Sept. 13, 1992
Anthony Lettieri
otay Ranch Project
315 4th Avenue, Suite A
Chula Vista, CA 91910
Dear Mr. Lettieri:
We are asking that the review period for the Draft Environmental
Impact Report for otay Ranch be extended. The DEIR is the
largest we have ever seen. The current October 7 deadline for
public comment is insufficient for adequate review. We believe
that a 90-day extension beyond October 7 is much more reasonable.
Sincerely,
~~
Kenneth Weaver,
Conservation Committee
cc: Mayor Tim Nader
Supervisor George Bailey
7~
~
University of 0an Die80
:-------
':~1 i~_ (~_:~ fJ ~:-!:' .~ ~.
.;:;:.' 2 i
- .~:
-"
Department of Biology
September 13, 1992
Tony Laterrie
General Manager
Otay Ranch Project Office
315 4th Street
Chula Vista, CA 91910
Dear Mr. Larerrie,
I am a population biologist at the University of San Diego
and have been doing research on the biology of vernal pool animals
since 1979.
I have recently reviewed an EIR on the Otay Ranch area
prepared by Ogden Environmental. in association with Michael
Brandman and Associates, among others. There are sornevery serious
problems with the sensitive species inventory and considerations
sections. Two sensitive soecies of invertebrates are not seriouslv
addressed and one species of vertebrate is not addressed at all:
The reasons for these statements are as follows.
MEA knew of the research going on at USD on the eubranchiopods
(fairy shrimp, tadpole shrimp and clam shrimp) of San Diego County
and of my dissertation on spadefoot toads. In 1990, on two days
notice, we were asked to prepare a summary of the life history of
fairy shrimp and spade foot toads and to include what was known
about their occurrence in the J25 and J30 series pools on Otay
l1esa. !l.t that time it was, stated that there was neither time nor
money for an actu~l survey of the area.
The report stated that two species of fairv shrimo were
present. Streoto~eohalus woottoni was present in J30. ~his'is the
rarest species of fairy shrimp and at the time this was one of only
seven pools in which it was known to occur. The species has been
proposed for listing by the USF&WS (F.R. 56(218) :57503-57509).
Branchinecta sandieaoensis was also known to be present in J30 and
in J25 as well.. This species is endemic to the San Diego area. A
petition to list it as endangered has been submitted to the USF&WS
(D., Hogan', pers., comm.).
At the time no soecific information was available on the
occurrence of spadefoot"toads in these pools. However, due to the
drought few successful breedings had been seen in Southern
/7/
( .
Alcala Park. San Diego. California 92110 619/260-4729
California since the mid 1980's and in many areas the species was
considered to be extinct. The area was considered appropriate
habitat for the toads. This species is considered a California
Species of Special Concern (F.R. 47(251):58454-58460).
The EIR contains some but not all of this information. There
are the following problems.
1) The report on sensitive faunal elements is listed among a
large number of reports that resulted from extensive surveys. The
description of the report does not reflect the fact that although
the species were discussed, species occurrence data was only
requested for two pool complexes. Thus, the report was not the
result of a comprehensive survey.
2) The information on the occurrence of the two species of
shrimp is included. However, no effort was made in the interim to
determine if more information was available. On the contrary,
since 1990 Streotoceohalus woottoni has been found in one more pool
(J29) and Branchinecta sandiecroensis has been found in several. A
clam shrimp, Cvzicus californicus has also been found in J30. This
species is a California endemic and this is the only known
population in San Diego County.
These data are in press and will appear in the Transactions of
the wildlife Society shortly (Simovich and Fugate, 1992). The data
were however, presented in a poster at the wildlife Society
meetings which representatives from both of the above mentioned
companies attended.
3) Also over the interim, Dr. Denton Belk has identified
several fairy shrimp specimens for John Brown of MEA. Several of
these are ~. sandiecroensis from the Otay Ranch. Some were from
Proctor Valley which had not been sampled previously. (Dr. Belk
periodically sends his voucher records to usn and vise versa, such
that the two computer data bases remain compatible.) These data
are not reported in the EIR.
4) ~. sandieaoensis is referred to in the EIR as the "vernal
pool fairy shrimp". This is incorrect. The vernal pool fairy
shrL~p is ~. Ivnchi which is not known from San Diego County.
5) In the ErR, although mentioned, these three species are not
on maps and their concerns are not specifically addressed. For
example, waterfowl are very important to fairy shrimp. The birds
carry eggs between pools providing a mechanism for gene flow
between fairy shrimp populations. If open space areas are not
l~rge enoug~ to promote waterfowl usage, the shrimp populations
w~ll become ~solated and vulnerable to extinction, even though the
pools may remain.
.6) Spadefoot toads are mentioned in the EIR only on a list of
sens~t~ve species potent~ally present. In point of fact, there has
been successful breeding in several pools since 1990, and thus not
78
all populations in the area are extinct. It is critical that the
concerns of these toads be considered. For example, spadefoot
toads burrow deep in the ground for most of the year. However,
their burrowing sites are in upland areas and not around the pools
in which they breed. Thus, unless open space is designed properly,
roads or other obstructions could separate burrowing and breeding
habitat and cause the death of many toads and finally the
extinction of the few remaining populations.
In conclusion, I feel that information on several sensitive
species, one actually proposed for listing, was either ignored or
not included in the EIR. The concerns of these species, which are
different from those of plants or endangered birds, were not
considered. Considering the status of the species involved, I find
these significant omissions.
References can be made available upon request.
If I can be of any assistance feel free to contact me.
Sincerely,
7/~~~
Marie A. Simovich, Ph.D.
cc. Nancy Gilbert
Tom Oberbauer
Chris Nagano
Robin Stribley
Anne Ewing
Robyn Stribley
"77
~~~ /3/1"172.
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,---------___",
September 13, 1992
Anthony]. Lettieri
Otay Ranch Project
315 4th Ave., Suite A
Chula Vista, CA 91910
Dear Mr. Lettieri
I am extremely concerned about the short public review period for
the Otay Ranch Project. This project will affect many of us who live
and work in the South Bay/Chula Vista area. It seems that there is a
real effort to try and "push it through" vvithout allovving reasonable
time for citizens and agencies to comment.
I have been a schoolteacher for the Chula Vista Elementary School
District for 16 years. I cannot understand this effort to give only 30
days to read and understand a 2400 page document, especially when
many of us must use a public library copy. This project will be
important to our community, and ALL of us need to feel that we
were allowed an appropriate amount of time to learn and comment.
At a minimum, 120 days should be given.
Sincerely,
-1/ 1/_" .
fi-1'f-/cfiZ1'7'!.-l-t I;'A
Kim Hamilton, Teacher
Chula Vista Elementary School District
84 East] St.
Chula Vista, CA 91910
cc: Tim Nader, Mayor
City of Chula Vista
275 4th Ave.
Chula Vista, CA 91910
c
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,J
P..C12
Septemoer 13, 1992
Anthony J. Lettieri
Otay Ranch Project Planning Office
315 Fourtb Avenue, Suite A
Chula Vista, CA 91910
RE: Public Comment Period, Draft Environmental Impact Report
Otay Ranch Development
Dear Mr. Lettieri,
I am a member of the South Coast Environmental Working Group, a
coalition of concerned citizens examining issues related to the
proposed Otay Ranch Development. We recognize the need for re-
.ponsible public participation Hithin the California Environmental
Quality Act revieH process, and would like to take this oppor-
tunity to comment on the review period that hes been granted for
the Draft Environmental Impact Report,
The Draft EIR reflects tbe scale of this proposed development in
its legnth and complexity, It is our desire to provide irnput
into thi. process within the legal intent of CEQA (Article 1,
Section 15002-j), After reviewing portions of the Draft ErR, it
has become clearly evident that an extension of the review pgriod
is necessary in order to assess the adequacy of th~s document
under CEQA.
A"minimum of 60 days, bgyond the origional comm~nt period "dead-
line~-Ts-necessary in order. to give this document a fair and
thorough analysis. Inc~uded are SOme issues that need clarific-
ation.
1) RESOURCE MANAGEMENT PLAN
While the RMP is intended to be the equivalent of the County's
Resource Protection O~dinance (1992 Work Program Report from
AICP General Manage~, April 29, 1992); it i,s difficult to see
how ordinance protection can be applied to a RMP that 'tdoes not
define the amount of a key rBsource that should be preserved".
There seems ~o be a direct conflict betwQQn the intentions of the~e
two statements.
Obj~ctj,ve 114 of the RMP stat~g that it is an objective to "Qg-
tablish functional connections to on-site resources and in-
/'
1.(/',
~\ c:::r-
P.03
tQgrate the management preserVQ into ~ large~ re6ional system.
Thi. Btatement i. reinforced in the Draft EIR and yet ~here is
no cross re.ference hQtween the various alternatives in the Draft
EIR and the goals~ criterra or preserve dasign of either the
MSCP or the South County NCCP.
A preserve system as defined in a Final EIR must surely 'e tn-
tegratgd wiht these programs. The HSCP has overlapping juris-
dictional concerns with the proposed Otay Ranch development
and is eVen being prepared by the sarna biological consul~ant
(OGDEN), and ye~ there is no tangilble reference to coordin-
ation of preserve d~9ien in ~he Dr.aft EIR. Without this infor-
mation it is impossible to objectively ~Bsess the impacts of
thQ various alternative plan~ on a re3ional preserve s~st~m.
Additionally, Table 1.1-1 states that regional wil.llife corridors
t;ould be significantly impacted and that part of the mitiga~ion
for this impact would be the implimentation of the RMP. This
;mitiga~ion is confusing in that it is not clear which of the
altor~atiYes meet RMP standards.
2) Seotion 3.9-14
CHANGE IN SURFACE HATER FLOW RATES
Due to the inc~ease in impermable surface area, increased ~un-
off would be significant. This section states that drainage
facilities would be aligned with' creek bottoms"and would be left
open "where possible'l. Th~ impacts wo~ld be a"significant in-
crease in erosion and siltation, and would be addressed by h~dro-
logic "studies" at the SPA plan level (J.9.3 PrOpOSQd Mitigation).
The implication is that if the l'studies" sho~ an increas~ in
erosion and siltation that a hydrOlogist can--- AFTER the EIR
is certified--- find that all of the tributaries should be
chanelized. This would of course eliminate th~se tributaries
as natural wildlife corridors. ,How does this information figure
into a preserve system that would be certified BEFORE these
"studies" t~ke place?
3) Section 2.3 -1.5 UNIYERSITY COHPONENT
This section, ffhile stating the reasons (briefly and generally)
fer this proposed siting, does not describe impacts to a propased
preserve system and yet this area has some of the highest concen-
tration of priority 1&2 sQnsitive plants and animals (various
maps and tables within the DEIR) on the Otay Ranch property.
Also mentioned is that the amount of land reservQd for thi~ use
totals "approximately" 400 acres. This is a vague QualifQr, open
to con~i~Qrable interpretation. Ha3 there been any commitment
from a university relating to the amount of acreage needed to
fulfill their anticipated acreage needs?
2.
~
P.04
4) Tao1~ 1.1-1
PUBLIC SERVICES AND UTILITIES
The mitigation for impacts to Water Availa~111ty and Supply
include a reference to a water-;;;laimatI;;-p~;gram~-Have-P1ans
beQn developed for this program? When will it go on line? Will
it be ab-le to accommodate the gradual and eventual buildotit?
It is important to have this information in order to assess the
significance of the mitigation.
Thcs~ questions represent a small sampling of issues related to
the adequacy of the Otay Ranch Draft ETR. In order to identify
issu~s, compare alternatives and assess mitigations it is
necessary that the pUbllc be granted an extension of the revisw
period.
Thank you for your consideration.
Michael Beck
P.O. Box 841
Julian, CA 92036
(619) 765-1469
ce: George Bailey
Tim Nader
~
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de Treville
Environmental Engineering
4131 Normal Street . San Diego. CA USA 92103-2654
(619) 296-1192
FAX (619) 260-0266
September 14, 1992
'rD' l.~ @ l~ o\~n~ 11",\'
Ii! I '
,Ii'\ SEPI6 ::11,:
,U\\ 'iL),
'l1 IV
Mr. Anthony J. Lettieri
Otay Ranch Project
315 - 4th Avenue, Suite A
Chula Vista, CA 91910
Dear Mr. Lettieri:
Please extend the comment period of the DEIR for the Otay Ranch
Project by at least 30 more days. The sheer magnitude of the
2400 page draft requires greater scrutiny and more time.
Two issues of .concern are:
1) Water reclamation
2) The coastal sage scrub destruction, and the unique life forms
which live in this habitat.
:;t;;;a~
Susan de Treville
Environmental Planner
cc: Tim Nader
George Bailey
S.D. Co. Bd. of Supervisors
fl:
@ Recycled Paper
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THE GREEN PARTY
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September 14, 1992
!
Board of Supervisors
County Administration
1600 Pacific Highway
San Diego, CA 92101
Center
OTAY RANCH PROJECT - REQUEST FOR EXTENSION OF TIME TO REVIEW THE
DRAFT ENVIRONMENTAL IMPACT REPORT BEYOND OCTOBER 7, 1992
I am writing as a concerned citizen of Jamul and on behalf of the
Chaparral Greens to ask that you help to effectuate an extension of
time beyond the 60-day review period, that is, beyond October 7th,
for the public to participate and reyiew the draft EIR lest you go
against the quintessential CEQA process of WIDE PUBLI,C INVOLVEMENT.
While studying the Guide to CEOA in conjunction with the Otay Ranch
draft EIR I note that our California Supreme Court, in landmark
cases repeatedly emphasizes the importance of public participation.
Although we know that our courts generally defer to the ultimate
political decisions of you, our elected officials, we also
recognize that our Supreme Court says CEQA should be scrupulously
followed so that the public will know the basis on which its
responsible officials either approve or reject environmentally
significant action and will be able to respond accordingly to
action with which it disagrees. It seems that the EIR process was
designed to protect not only the environment but also informed
self-government. Please do not deny your consti tuents this
opportunity for informed self-government.
Since the EIR process enables the public to determine the
environmental and economic values of their elected officials, this
procedure allows citizens to take appropriate action come election
day should a majority of voters disagree. The 13,000 votes our
nascent Green Party environmentalist candidate for Board' of
Supervisors received in the June primary as a result of our grass-
roots campaign tells me that your constituents deserve an "ear"
that developers' contributions cannot buy. Please give us your
ear, too... Please listen:
5r~7
c. i
city of Chula vista council Members
OTAY RANCH PROJECT
September 14, 1992
Page 2
. .
. .
Contrary to the myth that those of us requesting participation are
"little old ladies who haye nothing better to do with their time
than attend hearings,!' you should know that we are a multicultural
gende:::-and-agenbala:'lced group OZ ~ommunitycitizens who care deeply
about our environment and our government.
Contrary to the myth that those o~us whom you might pejoratively
label . "environmentalists" care more about birds than people (a
stupid, uninformed statement!) you should know that we care very
much about the economy. Any thoughtful person knows we need
balance here. We look to you our leaders to help create that
stability. I
I was appa~led to hear (during an otay Ranch workshop) Mr. Jamriska
jokingly tell Mr. Arbuckle that he "would. give him a few more
units" when Arbuckle paid-him a compliment. I was appalled to hear
(during the July 30 hearing) Mr. Bilbray interrupt Mayor'Nader, who
was proposing at least a 9o-day review period for the draft EIR,
remark: . "But' she's stacked a lot better" (referring. to
councilwoman Horton). This kind of public sexual harassment when
discussing the size of the draft EIR is not a joking matter. Our
entire Eco-system is at stake, here.
Our laws ensure that members of the public hold a "privileged
position" in the CEQA process. Such status reflects both a belief
that citizens can make _important contributions to environmental
protection and to democratic decision-making. PLEASE GIVE US THIS
OPPORTUNITY, NOW by granting us another 90 days .for ,review.
I'd like to thank the Otay project staff for their cooperation.
They are well aware of our diligence in reviewing the EIR and our
need for an extension of time to complete the review.
(?~
CAROLYN Z. O'PATRY
Member, Chaparral Greens
P.O. Box 1009
Jamul, CA 91935
cc: Anthony Lettieri, General Manager
OTAY RANCH JOINT PLANNING PROJECT
:?X
SAN DIEGO AUDUBON SOCIETY
",091 ~1QnC:~Jr\ CL:/D. eTC. ~~ . ~A"r n!5GiO, C'\ 92117 S1SlNB37t20
ber 14. 1992
---
--~, '~; :~~~ [i 0 ",il~ 17>!
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I:
thony J. Lettieri
Otay Ranch Project
315 4th Avenue, Suite A
Chula Vista, CA 91910
,- '5
v:-.- ;
norma Su/hvan
5858 SCI'ifpd St.
.san ::bie~o, ea. 9212:1
;~'
,:-.-'
Subject: Draft EIR. Otay Ranch Project
Dear Mr. Lettieri,
Again we ask for an extension of the public review period for the DEIR for
Otay Ranch. The deadline is now October 7. This simply is not enough time
to review a project so large, complex, and innovative. The document, as you
know, is 2400 pages long, and, now that we have it, we find it is not an easy
document to analyze, what with the many alternatives, appendices, etc.
Major land use decisions are involved, with a chance to ponder and evaluate
critical new ideas, for the benefit of us al1. The decisions wiH affect the
quality of life for ALL San Diego County residents, now and forever. Such
decisions simply cannot be analyzed responsibily in 60 days.
Further, we find many, many knowledgeable people are eager and willing to
comment on the DEIR. We have many experts within the ranks of our
membership. We are, thus, sharing our copy of the document, which saves
money and trees for us all. but necessitates more time for review.
We ask for at least 90 days beyond October 7.
Thank you for your consideration.
!,{.h~ ~((lJ,"---
Norma Sullivan, Conservation Chair
CC: George Bailey, Chairman, Board of Supervisors
Tim Nader, Mayor, City of Chula Vista
i;
S6l
8
FISH AND WILDUFE SERVICE
FISH AND WILDLIFE ENHANCEMENT
Southern California Field Station
Carlsbad Office
2730 Loker Avenue West
Carlsbad, California 92008
Yl!i!~<;l.States Department of the Interior
.- -
- .
Anthony J. Lettieri, AICP
General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, suite A
Chula Vista, California 91910
September 14, 1992
Re: Review of the Environmental Impact Report for the Otay Ranch, San Diego
County, California
Dear Mr. Lettieri:
The u.S. Fish and Wildlife Service (Service) is presently reviewing the
Environmental Impact Report (EIR) for the Otay Ranch. We are concerned that
we will not be able to adequately review this large document and provide you
with thorough and complete comments on topics within our area of technical
expertise and jurisdiction by law prior to the October 7, 1992, deadline.
Based on the exceptional length of this document and the complexity of the
subject project the Service recommends that the comment period deadline be
extended to allow a thorough review of this unusually complex project. The
Service requests that the comment period be extended for 90 days. We believe
this is reasonable given the size of the EIR, the complexity of the project,
and the number of technical appendices.
The project site is biologically extremely important. The proposed project
will result in significant and unmitigated impacts to federal and. State listed
endangered species, federally proposed endangered species, federal candidate
species for listing as endangered or threatened, and habitats of concern to
the Service, including wetlands. As stated by the EIR, significant and
unmitigated impacts will occur to sensitive uplands and wetlands including
vernal pools, seven state-listed endangered plant species, five sensitive
plant species, least Bell's vireo, coastal cactus wren, California
gnatcatcher, Quina checkerspot, Riverside fairy shrimp, regional raptor
populations, wildlife corridors and over 50 other sensitive species4 We
strongly recommend that additional time be allowed to adequately review the
subject document4
We appreciate your consideration of this request 4 If you have any questions
or comments. please contact Nancy Gilbert of this office at (619) 431-9440.
Sincerely,
Richard Zembal
Deputy Field Supervisor
cc: CDFG: La Mesa, CA (Attn: T. Stewart)
County of San Diego, San Diego County, CA (Attn: Chairman Bailey)
City of Chula Vista, Chula Vista, CA (Attn: Honorable Mayor Nader)
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THE CITY OF
SAN DIEGO
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CITY ADMINISTRATION BUILDING. 202 C STREET. SAN-D,EG8, CAL,PfJRN-M<921OI
PLANNING
DEPARTMENT
Development and
Environmental Planning
Division
236-6460 Mr. Douglas Reid
Otay Ranch Joint Planning project
315 Fourth Avenue, suite A
Chula vista, CA 91910
september 14, 1992
RE: OTAY RANCH DRAFT ENVIRONMENTAL IMPACT REPORT
Dear Doug:
Thank you for the opportunity to review and comment on the Draft
EIR for the otay Ranch project. The following comments are
submitted for your consideration.
1. In the Transportation Section, the table on page 3.10-1 and the
symbols on Figure 3.10-1 appear to be inconsistent. The table
lists a level of service E on Southbay Freeway between Reo Drive
~~d Woodman, while the figure appears to show a level of service
D for that segment. In addition, the legend shows evenly spaced
heavy dashed lines as the symbol for LOS D, but a different
symbol appears to be used on the figure.
2. In the Libraries section, the text is missing which would
complete the City of San Diego Existing Conditions discussion at
the top of page 3.13-57.
3. Page 3.13-67, in the Recreation Impacts section, the EIR states
urbanization would result in a loss of waterfowl hunting which
would be a significant and unmitigated impact. However, this
impact is not listed in Table 1.1-1 which is the Summary Table
of Significant Impacts and Mitigation.
4. Landform and Visual policies Section
a. Page 3.2-20, section 3.2.1.5:
Resource Protection Ordinance
introductory paragraph for the
A reference to the
should be included
section.
City'S
in the
b. A discussion of RPO should precede the paragraph on the
Hillside Review Overlay Zone. The Hillside Review OZ contains
guidelines for development when development is permitted on
/-.
if
steep slopes. The RPO protects steep slopes from significant
alteration by regulating the amount of encroachment by
development. Thus RPO regulates the amount of development on
steep slopes, and HROZ regulates the design of the
development. The discussion of the HROZ is adequate.
5. Land Use Impacts
a. Section 3.1.1.3, Planning Considerations for the City of San
Diego, should include a discussion of the City Lakes
Recreational Development Plan-1986, which was adopted by the
City Council in February 1987. The plan provides
recommendations for recreational uses at the City-owned
reservoirs, including Lower Otay.
FOllowing are some of the key General Recommendations for the
reservoirs:
1. The current program of recreational activities
on the City Lakes should be continued on a year-
round basis.
2. All recreational development of City Lakes should
preserve and protect the natural environment.
5. City Lakes should be protected by the planning
process to prevent further encroachment by housing,
commercial development and. other incompatible
developments in the areas surrounding the City
Lakes, much of which is in the land use planning
jurisdiction of the County or in federal ownership.
The plan identifies Lower otay as one of the world's premier
bass fisheries, and recommends fishing to be continued as the
major emphasized recreational activity at the site. In
addition, the plan identifies the two-day-a week waterfowl
hunting program as among the most popular hunting programs in
southern California, and recommends continuation of the
program.
b. Section 3.1.2.2, Land Use Impacts related to Displacement of
Adjacent Land Uses, should state that hunting would be
precluded by implementation of the New Town Plan because
urban uses are incompatible within about 1/2 mile of hunting
areas. The value of Lower Otay for waterfowl
conservation/hunting has regional and statewide significance.
Maintenance of existing outdoor recreational uses on
reservoirs is a City Council policy and adopted operations
plans include continuing waterfowl hunting opportunities on
Lower otay. Therefore, the loss of this recreational use
would be a significant unmitigated land use impact. Table
1.1-1, Summary of Impacts and Mitigation should reflect this
land Use impact.
c;(j
6. The Biology section does not contain a description of waterfowl
use on the reservoir or adjacent lands. What is the
significance of Lower otay to waterfowl migrations? How would
that significance be affected by the proposed development
according to the New Town Plan or the alternatives? What
impacts would the proposed plan have on waterfowl habitat?
Because wetland areas are at a premium, particularly in the
coastal areas of the Pacific Flyway, the report should analyze
the impact of the proposed project and alternatives on migrating
waterfowl. Both direct and cumulative impacts whould be
addressed.
In addition, the report should include an analysis of impacts on
fish habitat. How would proposed development affect habitat
quality in terms of shading from structures or potential changes
in water temperature? How would pollution and contamination be
controlled from sources such as airborne fallout from pesticide
and fertilizer spray applications, or trash blown or thrown into
the water?
Thank you again for considering the above comments. If you have
questions, please contact Janet Myers at 236-7714.
Sincerely,
~~
Ellen Mosley
Senior Planner
cc: Jim Brown, Water Production Division, Water Utilities
Department -.::i::
E. Michael Stang, Community Planning Division, Planning
Department
Leonard Wilson, Engineering Design Division, Water utilities
Department
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OFFICE OF THE MAYOR
TIM NADER
C1lY OF
CHULA VISTA
September 15, 1992
Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Planning Office
315 Fourth Avenue, Ste. A
Chula Vista, CA 91910
RE: Otay Ranch Project Draft Environmental Impact Report
Dear Mr. Reid:
At its meeting of September 2, 1992 the University of
California at Chula Vista (UCCV) Task Force unanimously voted to
make the following comments in regard to the Draft EIR on the Otay
Ranch Project:
None of the project alternatives appear to show the
university site as described by Chula Vista City Council
in Resolution #16360, city of San Diego Resolution #R-
279768 (adopted April 20, 1992) and County of San Diego
Board of Supervisors Resolution #56A (dated November 5,
1991). These resolutions, while including the 400 acre
site west of lower Otay Lake shown on some alternatives,
are not confined to that site, but are explicitly phrased
as "including" that area. To attract a quality four year
uni versi ty with acceptable environmental impacts will
probably require significant expansion of this acreage to
allow more flexibility as to the siting of buildings and
facilities.
We therefore strongly recommend that the proj ect
description include approximately 1,000 contiguous acres
for a university site, including the 400 acres designated
in the New Town Plan proposal. This more accurate
project description of the university component of Otay
Ranch should reduce the biological impact analyzed in the
draft EIR, in that it is not necessary to build an entire
university facility within the 400 acres identified in
the New Town Plan.
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Douglas D. Reid
September 15, 1992
Page 2
We appreciate your consideration of this important matter in
the interest of our,community's future.
Sincerely,
.]Z:' A.<<~~
Tim Nader
Mayor of Chula Vista and
Chair, UCCV Task Force
c:\wps 1 \UCCV\OAAFT.EJR
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GROSSMONT UNION HIGH SCHOOL DISTRICT
POST OFFICE Box 1043' LA MESA, CAliFORNIA 91944-1043' (619)465-3131 . FAX (619)460-0963
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Planning and Assessment
FAX (619) 462-5721
CDmmitted 10 Excelenctl
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September 15,1992
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Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT:
DRAFT ENVIRONMENTAL IMPACT REPORT
OTAY RANCH PROJECT
Dear Mr. Reid:
Thank you for the opportunity to review the above-described document. Table 3.13-8, Current Enrollment should
be updated to Fall, 1991. At the time that report was filed with the County Office of Education, the District's 9-12
grade enrollment was 18,082 and special education enrollment was 742. A total of 19,466 students are currently
enrolled for the 1992-93 school year.
On page 3.13-50 in Table 3.13-11, please change the name of the Grossmant School #2 to Steele Canyon High,
the General Location to State Highway 94, and the Estimated Opening Date to January, 1997.
The District's student generation factors are currently being verified. Resuits of this verification study might
change the rates listed in Table 3,13-12, Sludent Generation Rates Per Housing Unit.
Table 11 of the Long-Range Masterplan for Educational Facilities in Otay Ranch estimates the number of
students generated by village by District at 1,272 for Grossmant not 928 students as listed in Table 3.13-13 of
the DEIA. What happened to these 344 students?
Grossmont currently operates ten comprehensive high schools, none of which are buiit to house 2500 students.
Our eleventh high school, Steele Canyon, has been planned and designed to house 1800 students. If
compliance with this current District practice of housing less than 2500 students on a single campus were to be
provided by the developer, the Otay Ranch build-out would require .5 of a high school not .4.
In this climate of shrinking State and local revenues available for building needed schools, full cost mitigation is
an extremely important component of the developer's approval to build. The Grossmant District sincerely
appreciates the Baldwin Company's commitment to 'fully mitigate the impact of Otay Ranch on all affected school
districts. .
Sincerely ,
Daniel J. chen
Director Planning and Assessment
GOVERNING BOARD MEMBERS
Thomas P. Davies Antonio (Tony) Orosco Sr.
June M. Mon Kenneth R. Whitcomb
Maynard R. Olsen
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SUPERINTENDENT
Jo Ann Smith
SWEETW A TEn
C omm unity
Planning
Group
15 September 1992
To: City of Chula Vista Planning Commission
County of San Diego Planning Commission
Subj: Draft Environmental Impact Report (DEJR) on the Otay Ranch
General Development Plan and Subregional Plan.
From: Sweetwater Community Planning Group
The Sweetwater Community Planning Group requests an extension of the DEIR
public review process until after 15 November. After an initial review of the rather
overwhelming documentation and some questions posed to the Joint Project Team
representative at the groups regular meeting of 1 September 1992, the following
motion was passed unanimously with 10 members present and voting:
The DEJR for this project does not deal with the California Gnatcatcher as an
endangered species. The U.S. Fish and Wildlife Service is due to make a
determination on the bird's status in a few weeks. The California Department
of Fish and Game decision not to list the species was set aside by judicial action
last week.
If either of these agencies act to list the Gnatcatcher the DEJR will not be
adequate and the project will require redesign. Rather than go forward at this
time it would be prudent to continue the work on this until after 15 November
to allow USF&W and CDF&G to deal with the Gnatcatcher problem.
An additional point the Planning Group would like to raise is that of the County
abandoning its responsibility for Lead Agency on this DEJA. This project is com-
pletely outside of the civil jurisdiction of Chula Vista and only minimally within the
Chula Vista Sphere of Influence. The Planning Group would be much more
comfortable if the planning and development standards of the County were being
applied to this project.
dA-L~
John Hammond
Chairperson
9<7
P.O. Box 460, Bonita, California 91908-0460
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September 15, 1992
Anthony Lettieri
. otay Ranch Project
315 4th Avenue, suite A
Chuln vi~ta, CA 91910
Re: DEIR for otay Ranch Project
Dear Mr. Lettieri:
We request an
Many factors
quireroent.
extension of the public review period to 90 days.
point to the necessity to observe this CEQA re-
consider the creation of a new town -- the core of this 23,000
acre project. Many of these acres are sensitive habitat. Addi-
tional acres are prime prospects for restoration. surround these
acres with fast-growing San Diego county and you have nothing
less than an "unusual situation" (per CEQA Guidelines).
When the pUblic is faced with an Environmental Impact Report of
over 2400 pages (well in excess of the 300 maximum recommended by
CEQA) it's "unusual".
A request for all correspondence between the applicant and all
entities is outstanding.
The mapping is too poor to support making judgements on a pro-
posed preserve. Failing to map a watershed or area containing
sensitive habitat before designing a project is common but not
tolerable. preserve assessment and its mapping should be done
first.
public
review
largest
input is the heart of CEQA. Please
period to encourage the best possible
remaining tract in San Diego county.
extend the public
project in this
, president
cc: Tim Nader, Mayor
Geor~e Bailey, Chairman
San Diego ~oaru ~f cupcrvi~orR
100 VMtn f1 Camino R~al. Suite 411 . ETlctnitJu. C4. . 92024
[;c/
GROSSMONT UNION HIGH SCHOOL DISTRICT
POST OFFICE Box 1043' LA MESA, CALIFORNIA 91944-1043' (619)465-3131 . FAX (619)460-0963
Planning and Assessment
FAX (619) 462-5721
Committed 10 Excellence
Since 1920
'.-'-
--.
September 15, 1992
Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT:
DRAFT ENVIRONMENTAL IMPACT REPORT
OTAY RANCH PROJECT
Dear Mr. Reid:
Thank you for the opportunity to review the above-described document. Table 3.13-8, Current Enrollment should
be updated to Fall, 1991. At the time that report was filed with the County Office of Education, the District's 9-12
grade enrollment was 18,082 and special education enrollment was 742. A total of 19,466 students are currently
enrolled for the 1992-93 school year.
On page 3.13-50 in Table 3.13-11, please change the name of the Grossmant School #2 to Steele Canyon High,
the General Location to State Highway 94, and the Estimated Opening Date to January, 1997.
The District's student generation factors are currently being verified. Resuits of this verification study might
change the rates listed in Table 3.13-12, Student Generation Rates Per Housing Unit.
Table 11 of the Long-Range Masterplan for Educational Facilities in Olay Ranch estimates the number of
students generated by village by District at 1,272 for Grossmant not 928 students as listed in Table 3.13-13 of
the DEIR. What happened to these 344 students?
Grossmont currently operates ten comprehensive high schools, none of which are buiit to house 2500 students.
Our eleventh high school, Steele Canyon, has been planned and designed to house 1800 students. If
compliance with this current District practice of housing less than 2500 students on a single campus were to be
provided by the developer, the Otay Ranch build-out would require .5 of a high school not .4.
In this climate of shrinking State and local revenues available for building needed schools, full cost mitigation is
an extremely important component of the developer's approval to build. The Grossmant District sincerely
appreciates the Baldwin Company's commitment to 'fully mitigate the impact of Olay Ranch on all affected school
districts. .
Sincerely ,
Daniel J. chen
Director Planning and Assessment
GOVERNING BOARD MEMBERS
Thomas P. Davies Antonio (Tony) Orosco Sr.
June M. Man Kenneth R. Whitcomb
Maynard R. Olsen
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SUPERINTENDENT
Jo Ann Smith
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GRANVILLE M. BOWMAN
DIRECTOR
(519) 694-2212
FAX (619) 268.Q461
LOCATION CODE S50
<rrount~ of ~an ~i.ego\
COUN"t.-'LENGINEEA
COUNTY AIRPORTS
r..nll....TV Rt"'ldn CQMMLSSIONEA
TRANSPORTATION OPERATIONS
COUNTY SURVEYOR
FLOOD CONTROL
LIQUID WASTE
SOLID WASTE
DEPA~TMENT OF PUBLIC WORKS
5555 OVERLAND AVE. SAN DIEGO. CALIFORNIA 92123-1295
September 15, 1992
FROM:
Lauren Wasserman, Director
~a~tment of Planning and Land Use
J<~ ~~, Deputy Director
Division of Solid Waste (0383)
(0650)
. TO:
SUBJECT:
otay Ranch EIR
The Department of Public Works has reviewed the draft Environmental
Impact Report for the Otay Ranch Project. We find that the
discussion, impact determinations and proposed mitigations for
solid waste recycling related efforts are satisfactory. However,
we believe that the EIR does not fully address the issue of
adequate landfill capacity for the proposed development.
The EIR acknowledges that the County is currently attempting to.
site new landfills in the south county area, and that two of three
proposed sites are within the otay Ranch project area.
otay Ranch will generate 194,753 tons per year of solid waste at
build-out, according to the draft EIR. The EIR states that "the
otay Landfill is expected to meet the project's refuse disposal
needs in the short term... ...and additional landfill space will
ultimately be required. The future county site, when selected and
implemented, will alleviate this problem." The EIR goes on to
state that "Until that time, this issue is considered to be a
significant impact".
The EIR, while stating that there is a significant impact, does not
propose any mitigation measures for the issue of landfill capacity.
The Analysis of Significance section goes on to conclude that
"Impacts to solid waste disposal services are considered
significant at this level of analysis. However, implementation of
the above mitigation measures at the SPA level will mitigate
project-related solid waste impacts to below a level of
significance". The Department of Public Works does not believe the
EIR to have adequately addressed the "significant impact" to
landfill capacity in the area since there are no Mitigation
Measures listed.
II'!
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Mr. Wasserman
-2-
September 15, 1992
Developers cannot assume that the County will be successful in
finding new sites to provide for future capacity. The siting and
permitting process has become so controversial and lengthy that
presuming the successful selection and construction of a new
landfill is perilous. A development of this magnitude should not
begin construction until the additional capacity needed to support
the development is assured.
The Solid Waste Division believes that the County and the
developers should share the responsibility for finding new landfill
capacity to support future development. To this end, we recommend
that the Department of Planning and Land Use require the addition
of the following Proposed Mitigation measures:
. The proposed proj ect shall cooperate to the fullest
extent possible in the investigation of the two sites
within the Project area under consideration as
replacement landfill(s).
The Board of Supervisors is to have selected a new
landfill site and the County is to have obtained all
local and state permits required to build the facility
prior to any tentative maps being approved for any phase
of the proposed Project.
These mitigation requirements will assure that new landfill
capacity will be available for the project at the time of need.
They will alos prevent the otay Ranch development from utilizing
existing capacity before knowing if the region can meet the
requirement of the State law (AB 939) to have a minimum of 15 years
capacity in the solid waste disposal system.
We believe these changes in the EIR should also be adequately
reflected in the General Development Plan.
If you have any questions please call Joe Minner at (S.C. S59)
974-2711.
WAW:KAL:jm
cc: Lari Sheehan
Bill Hoeben
City of Chula vista
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Septemoer 15, 19'7'2
Anthony .J. Lettieri
Otay Rancn Project
315 4tn Ave.~ SUlte A
Chula Vista. CA 91910
Dear Mr. LettIeri
1 am very concernea about the shor~ time for pubi lC comment
an tne Otay Ranch Projec~. Tnls project will aff9ct many o~
l~lS ~.o.,tIIO 1 ive an1j lrJor~:: In the South Bay/CrlLll a Vista. -2re2.. It
S':2ems that trJere t":. .:.. r"'ea i '=:+ fort t':J try .:..nd II pUSh it
~;-lt-'au.:;nd \t'n~nOLi"i: a.i i DWlng reasonaoi e time fc.r citizens .3.nd
agencies to cwmment.
As 2 reSldent of the South Bay area~ I knew that this
prOjEct wi11 02 lmportant to our cnildren and community.
HL~ of us neea to feel that we were allowed an approprla~e
3mQUn~ of tlme ~o learn, reflec~~ and comment.
Sincereiy,
~~
cc: Tim Naoer, Mayor
Clty of Chula Vista
275 4th Ave
Chula Vista~ CA 91910
cc: George Bailey, Chalrman
5an DlegO County Bcare of Sucervlsors
1600 Paciflc Hignway
San Dlego, CA 92101
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September 16, 1992
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Mr. Anthony J. Lettieri
Otay Ranch Project
315 4th Ave, #A
Chula Vista, Ca. 91910
Dear Sir:
I am writing to express concern regarding the length of time allowed
for review of the Draft Environmental Impact Report (DEIR) for Otay
- Ranch. Due to the complexity of this proposed project and its impact
upon the residents of the Southbay, I request that the review period
be extended beyond October 7.
As a 15 year resident of Chula Vista, and as a new homeowner in
Eastlake Greens, I am particularly concerned that the quality of life
in our city be protected. I appreciate your consideration of my
request.
CC Tim Nader, Mayor
City of Chula Vista
275 4th Avenue
Chula Vista, Ca. 91910
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Sep 10.92
10;23 No.006 P.02
Shllt Of Celllornla-Bullne... Transportallon and Hou81ng Agency
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DePARTMENT OF CALIFORNIA HIGHWAY PATROL
~02 Pacr(i~ Hi9hway
Ban 01e90, CA 92110
(*,~9) 296-6&U
P!T! WILSON, Governor
.
September 16, 1992
File No, 645.aaOO.A9697
St.t, Cle&xlngnouSe
1400 r.nth St~aat. Room 121
Saoramento, CA 9~8l4
Refereficel SCE t89010154
We ~v, been proYi~ea & copy ot the Dratt Environmental Impact Report for tho
Otay Ranoh Plon Area. Upon review, we believe this plan may have the tallow.
in9 impact on the f1iqhway Fatro1.
· When the arta is totally b~i1t out. 50,733 dwelling unite. commerciol
aavelopm..nt &it.s llnd r"creatlona1 ar..oa will ."Ilult in an ..aH,uted
population qrowth o! approximately 150.000 perBona on 2~,oea 4cre~,
· Th.. Ohy Ranoh PlAnning 're.m h ,,~p"Qting the uninoorl'orat4>d &~... of
ata)' llaneh, w.."t at the atOlY 1..)(.... to beeome incQrporated by the
eit1.. at Chula Vista end SOIn Dieia, Thi. woul~ leave the eree within
the projcQt east of the Otay Lak... ~nincQrporat.d, keep1n9 ,~p juria-
dietion lor trattio reapOnQib1Iltie.. Ba.e~ Qn the rel1dential
dwelling. and other planned IlUS for thi" unJ.ncorporu...d ar"., thio
will -iinit1"all)' inere.va tHP respon.,ib111ti"..
e Ther+ aro 31 tr...way mil.... within the Otay R~nch projeot Study. lt i.
UUmated that bet"..n 19' to 5H of thn.. 31 ",l.lu wH1 operate at
1I01\llllas in e~ce8a of the maximum reoommtl"d"d All~' volum". (LOS f), Th..
"'D~' vol umco p.rcentagea vary I)....d on the on-.i h ..lterna ti ve.. pro.
pOied.
- The "....via.t ACT volum_ on Sl<-i2~ i. predH:t.~ to' b" tram GlI-~4 to
east of "H" nre.t. Sl\NOAG h.. n"ommemled that SR-1H hoO an ili9ht
lane trceway with two rav"r!ible MOV l.ne!. ~he ino~e444d AbT vOlum.."
0" 1-eos and sa-S4 are not ador"".ed .paoifically, but this prcject
will certainly incr.... the.. l\OT'.. w.ll al)ove the ma~1murn ~.oommenda-
tiona. l\ Ca1trtna a~rvey or I-e05 ha. alreAdy ahown a 62' 1nor....e in
the AbT volume (at Sa-54) 81n~w thQ develop~nt of the I.at Lak. Ar."
in Chula "ish, '1'hh .xiat1n9 ~'Yelopm~nt i. loeate<l \le.t of thi.
Otay Raneh Project.
" TufU.:! eoUhiona wit.hin CliP jllrhdIot.lon "t thia pro;jact may in-
ore.a. du. to oonatruotion-r.lated oon9..tion.
)1>-7
CHP S~N DIEGO-645
TE,-'
..;,cC :.. 5 . '~.2
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~
. .
state Clearinqhou..
1',;. 2
S.pteMber l!, 1992
, While it i8 impossible to determine the .xa=1: impact thi. development
will have on our reeource., .... =.n look at cur el<periencea wi th the
amall.r proj9ct, i..~ ~ake Area. A& not.d above, AD~'a ~ n.i9hborin;
freeway. .n4 County roads leading to and from hev. nece..itat.d
redeployment of el<hting CHI' ofUcen into theu ar.... 1'01:' thi.
project, Ot.y !'Ian.,h, at a minimum .... will need another two pc>siU.,"a
on the morning shift, anll ."oU,." u,o potition. cn the altel:'l\oon
.hUt, tg covel:' the antioipated iner.... ~n fervic. need.. '1"hia it
taxin; into conei4eratign non-fi,ld time dUe to re9ular day. ~ff, .ide
time, and va"atd.on.. The.. four !,ceition.. 'oIoll1d be .ooed to the
Command'. guideline .trangth.
~\J:);N' ~a1n
Commander
.00' Border Iliviaion
Office of Speeial Project.
/(11
. ...--,
:1TY:_F CHr;LA ' . -,",
'76 Fourth f.'::'
:hul~ Vine .:-
L.UV1"l"',", --
r~.nl Ruffin Road
. - --.' 'po CA92\23
,.1. ~ .
.''- '-\1'.1. PLAN
MEETING.
lciG~ f ...
., .
Marc~a Jones
370 Andrew Avenue
---"Leucadia, CA 92024
... ~},/"l~__-_
~>'.',o.''''''- ---' 7"-' .,eptember 16, 1992
OTAY R/'.l~('
GPA 90-04 (Co '
EYHlBIT II /
. Mr. Anthony J. Lettieri
Otay Ranch Project
315 Fourth Avenue, Suite A
Chula Vista, CA 919106
Re: OTAY RANCH DRAFT PROGRAM EIR
Dear Mr. Lettieri:
The purpose of this letter is to provide you with my. comments on
the Draft Environmental Impact Review of the Otay Ranch development
proposal by Baldwin Company.
I am particularly concerned about water-related issues. Initially,
in the context of our scarcity of water here in San Diego County, where
is ttle water going to come from to supply the development of these
three properties?
Once the water is made available, where will it go and in what
condition?
In the water resources and water quality element, I see that
three geologic formations have low permeability: Linda Vista,
Sweetwater, and alluvial deposits. All are found either along the Otay
River Valley - near or in the flood plain by the looks of the maps - and
in areas of the Proctor Valley parcel where development is planned.
I notice in the Wilson Engineering section (volume III) of
the Otay Ranch Technical Reports, on the latter property there
will be constructed a "world-class" golf course overlooking Lower
Otay Reservoir. Such a project would surely cause large-scale
removal of vegetation and runoff, while adding untold quantities
of herbicides and pesticides to the drainage system. On the
former property, residences, a university, and commercial/industrial
development - all linked by highways, including an eight-lane 125 _
will add to impermeability and polluted water runoff.
On the San Isidro parcel, 5,200 "low-density estates" will
contribute their share of lawn chemicals and petroleum-based
pollutants, as well as solvents, detergents, heavy metals and other
contaminants cited on page 3.9-4 of the DEIR.
Page 143 (volume VI) of the Technical
ground water can also be influenced by the
covers a multitude of possibilities and is
the problems that loom over this project.
be the rule throughout the document.
Reports say, "The quality of
project." This statement
not useful in clarifying
Unfortunately, this seems to
/t?
THE CITY OF
(&19) 423-830rJ
~^X (619) 429-9770
IMPERIAL
8EACH
825 IMPERIAL BEACH ~OULEVAR[) . IMJ'!:RIAL BEAC.H, CALlfOKNIA 91932
S~ptcmber J6, J992
Anthony J. Lettjorl
Dtay Kanch ~~oject Planning
315 Fourth AVe., Suite A
(~ula Vista, CA 9]910
Dear Mr. Lallieri:
I am a member of the City Council of Imperial Beach. As you are well aware, my city is
likely to be inunedistely affected by the proposed Otay Ranch project. 111erefore, I am very interested
in having the opportunity to properly review the Program EIR. Unfonunately, I will be unable (0
accomplish this goal in 60 days. I alll re4uesting that you extend the comment period for an
additional 60 days.
I am particularly concerned because the project may have a detrimental impact on the entire
region's water, solid waste disposal and circulation infrastructUre. I--unllennore, the l'rognlITl ETR
makes the a~sumpliOIl that the County General Plan will be amended to fit with the project. If so. it is
only proper dlat the propOsed amcndmems to the General Plan be reviewed in together with the EIR.
It will only he possible 10 properly analyze the EIR if you extend the public comlllent period.
Sincerely,
~ ~-('. ~~-~
M..rti C. Goethe
Mayor Pro Tern
City of Imperial Rench
Ill)
Gw~ United States
~ 'J. Department of
Agriculture
Soil
Conservation
Service
332 S. Juniper, Suite 110
Escondido, CA 92025
619-745-2061
September 17, 1992
Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
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RE: DEIR for the Otay Ranch Project
Dear Mr. Reid:
The Soil Conservation Service (SCS) is pleased to respond to
your July 31, 1992 letter concerning the' above project. The
following are points to be considered in the final report.
1. The provision for soil erosion control on slopes of 15
percent or greater.
2. The provision for stockpiling and reusing topsoil for
later use in revegetation (RE: PG 3.5-21).
3. The effects of disruption of natural drainage patterns.
4. Planning options that would address community education
on sedimentation control practices and rehabilitation
measures.
5. Provide a complete description of the planning area.
This should include current and planned land use
designations, the number of acres in agriculture
production, soil classifications, cropping history, and
whether the site is considered prime agricultural land.
The Greater Mountain Empire Resource Conservation District
and the SCS has information on drainage recommendations and
erosion control measures that may help you in preparation of
the final EIR.
17Y\ 'lI
JACKSO
Conservationist
(j The Soil Conservation Service
is an agency of the
V::::tI United Slates Department of Agriculture
/I!
\~
'It us. Go"rnment Prlntln1J Of1l0:8: 1 t.:J-420.'~1/1 57&
SEP-17-92 THU 14:ae
p.a2
State of California
Business, Transportation and Housing Agency
Memorandum
To:
STATE CLEARINGHOUSE
Date: September 17, 1992
Attention: T. Loftus
File: 11-80-125
0.0/11.2
From: DEPARTMENT OF TRANSPORTATION
Dlatrlcl 11 Planning
Subject: Pr09ram EIR for Otay Ranch. 8CH 89010154
Caltrans District 11 comments are as follows:
The Environmental Impact Report (EIR) notes the need for the ultimate widening of
Interstate 805 (1-805), State Route 905 (SR.905), and State Route 125 (SR.125) to 10
lanes. The EIA acknowledges that these widenings are beyond the scope of the
Transportation Concept Reports (TCR's) for I-80s and SR-905 but fails to point out that the
TCR's discuss the possible use of the median for Light Rail Transit (LRT) projects by the
Metropolitan Transit District Board (MTDB). In the case of I-80S, LAT placed in the median
between H Street and State Route 54 (SR-54) will preclude 10 lanes in this segment. For
SR-905, if LRT is built in the corridor, the ultimate freeway size would only be six main lanes
and two High Occupancy Vehicle (HOV) lanes.
State Route (SR-94) needs further analysis. The proposed traffic volumes between
SR-54 and Otay Lakes Road should be discussed as well as the subsequent Level of
Service (LOS) for that portion of SA-94. In addition, the Millar Ranch Road/SR-94
intersection should be studied for the possible need for a grade separated interchange.
The portion of SR.94 from Millar Ranch Road to SR-54 will most likely be a four lane, not a
six-lane, freeway. That possibility needs to be studied along with the Millar Ranch
Road/SR-94 intersection analysis.
The projects shown on pages 6-2 and 6-3 should be included in the traffic analysis fer
SR-94. Widening SR.94 from Otay Lakes Road to it's junction with SR-54 in Rancho
San Diego may be necessary. The overall length of that widening should be assessed as
well as reasonable termini for the environmental document. If such widening is more than
minimal length, Caltrans would be the lead agency for the environmental document.
Caltrans, however, has no funds available for such a project.
While the EIR does not present noise study specifics, it indicates impacts will not be fully
mitigable for sensitive noise receptors along SR-125. We request the City and the
developer assertively inform prospective residents about these impacts. We urge that
deeds for homes include such disclosure and buyers sign agreements that they will not
seek remedy from Caltrans or California Transportation Ventures (CTV) as such remedy
would not be feasible. We recommend the City and the developer adopt locational and
structural criteria that will mitigate noise impacts to the maximum extent practicable.
Several of the ranch alternatives show areas for park land adjacent to SR-125. By
identifying this use adjacent to the roadway we understand the City believes SR-125 will
not substantially impair intended uses within the park. We request park land not be
dedicated to a public agency prior to a route adoption for SR-125. Under Section 2.6.2.1
J/-I-
'SEp.-17-92 THU 14:02
STATE CLEARINGHOUSE
September 17, 1992
Page 2
P.03
and Section 2.6.2.2 it should be noted that the location for SR-125 Is subject to approvals
from Caltrans, the Federal Highway Administration (FHWA) and a route adoption by the
California Transportation Commission (CTC).
Our contact person is Charles Stoll, Senior Transportation En ine~:...~J) 688-6136.
-:R - /.- dM-
BILL DILLON. Chief
Planning Studies Branch
/1;]
FR'ENOS.O'
BATIgUlios LA~OON
p , 0, BOX 2 7 3 6" L g' U C. A D, I A, C' A, L I FOR N I A 9 2 0 2 4
September 17, 1992
liD rn@rgow~Jm!
!Ii\\ 'SEP21 ':;111;
!U IJ 1101
1 J '
Mr. Anthony Lettieri
Otay Ranch Project
'315 4th Avenue, Suite A
Chula Vista, CA 91910
RE: Drafi EIR for Otay Ranch Project
Dear Mr. Lettieri:
lye
for
respectfully request an extension of the public
the above project.
"
review period
The Environmental Impact Report of 4000 pages (including the,
appendices) is more than 10 times the number of pages recommended
by CEQA (300 pages). ',The project covers 2300 acres, and will be
a ci ty. ,unto, itself" when completed. ' Rare.. threatened and
endangered species ~nhabit these .cres, some of which are covered
with plant ,and wildlife, communities.on the edge of extinction.
San, Diego County will be greatly altered by, this project. It is
unique and unusual in every aspect, and, qualifies in every vay
for an extension beyond the usual 45 - 90 days. The intent of
CEQA is that public officials and p~blic citizens be provided
adequate time to review and digest the proposal, to imagine the
project, visit the site, and consider ~he impacts. In this case,
even ninety days imposes a hardship. We ask for 180 days.
'Review
mapping
project
regional.
program,
regional
of this project has also been hampered bj inadequate
and by the proponent's failure to spell out how the
coordinates with the MSCPand other attempts at planning
preserves. If the county is serious about its MSCP
this project must include and be included in the
perspective.
A good project cannot be rushed. We ask you to
public review period to 180 days and allow this
unusual project the time it takes to make it
good project, but a best possible project.
extend the
exceptionally
not just a
m:iJ
Dolo", Wel~
Conservation Chair
cc: Tim Nader
George Bailey
)/t
Q
United States
Department of
Agriculture
Soil
Conservation
Service
110
332 S. Juniper, Suite
Escondido, CA 92025
619-745-2061
September 17, 1992
Douglas D. Reid
Environmental Review Coordinator
Otay Ranch Project Office
315 Fourth Avenue, suite A
Chula Vista, CA 91910
, [Ii:::' ~
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.-.---'
RE: DEIR for the Otay Ranch Project
---!
Dear Mr. Reid:
The Soil Conservation Service (SCS) is pleased to respond to
your July 31, 1992 letterccncerning the above project. The
following are points to be considered in the final report.
1. The provision for soil erosion control on slopes of 15
percent or greater.
2. The provision for stockpiling and reusing topsoil for
later use in revegetation (RE: PG 3.5-21).
3. The effects of disruption of natural drainage patterns.
4. Planning options that would address community education
on sedimentation control practices and rehabilitation
measures.
5. Provide a complete description of the planning area.
This should include current and planned land use
designations, the number of acres in agriculture
production, soil classifications, cropping history, and
whether the site is considered prime agricultural land.
The Greater Mountain Empire Resource Conservation District
and the SCS has information on drainage recommendations and
erosion control measures that may help you in preparation of
the final EIR.
,py''h
JACKS 0
Conservationist
, /t~j
/ IS .......:V
(J The Soli Conservation Service
is an agency of the
~ United States Department of Agriculture
if U~ Go,,"'nm.,., Prlntl", Off1~t 1,,3--UO.!J't157.
F~OM SUFERUISOR a BRILEY
109.24.1992 11104
P. ~
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F~OM ~~ERUISOR G BAILEY
139.24.1992 1119:5
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September 19,1992
1702 Yale St.
Chula ' Vista,
c.n.
91913
Mayor Tim Nader
City of Chula Vista
276 4th Avensue
Chula Vista, CA 91910
Dear Mr. Mayor,
I ~uld like you to know that there is a great deal of concern in
the ccxrrnunity with regards to the planning for the otay Ranch project. If
the review period for the Environmental Impact Report is limited to the
existing period, there is a high probability for litigation. I ~lOuld
suggest that if the review period takes 90 days or ,mat ever additional
time is necessary to thoroughly study the report, it ~uld be time well
spent to mollify the public's apprehensions.
Sincerely,
Robert E. Tugenberg
cc: Tony Lettieri
1/1
,
,
CROSSROADS
RESIDENTS WORKING TO KEEP CHULA VISTA A NICE PLACE TO LIVE
:"",1 Freno
:>resident
-'.
(~~-~ ~.~-~":7~:>, !
;;1 )
, .
'I i
':::-jj -~/ I
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Jill Robens
lice.President
'1 L.;/,
'\
\ :
Nill Hyde
r rcasurcr
September 20, 1992
UUI
:i,...
I~
.",~mbc~
Lowell Blankfort
Supervisor Brian Bilbray
Members of the Board of Supervisors
County of San Diego
1600 Pacific Highway
San Diego, CA 92101
Alan Campbell
Subject: Ot"y Ranch Environmental Impact Report
William Cannon
Jc:nri.ie Fulasz.
Our members have begun the review process of the subject document
and the overwhelming amount of information requires greater
scrutiny of this project. . Since development of this land will
affect every aspect of our lives in the South Bay for the next
several decades we do not believe that the present allotted time
is sufficient to cover this report.
George. Gillow
Jerry Griffith
Tom pasqua
Frw SCOlt
Therefore CROSSROADS re~uests an extension of this public review
time of at least an additional sixty days at the very minimum.
The huge impact of this development on the City of Chula Vista
and the unincorporated area makes an extension of paramount
importance.
Peter W Itry
Cuy Wright
Thank you.
=~~
Carol Freno
Tony Lettieri, General Manager
Otay Ranch Joint Planning Committee
v--
P. O. Box 470 . Chula Vim. CA. 92012 . pnone 421,3773
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Dan Silver . Coordinator
1422 N. 5weetzer Avenue #401
Los Angeles, CA 90069-1528
213 .654. 1456
.
.
ENDANGERED HABITATS LEAGUE
Dedicated to the Protection of Coastal Sage Scrub and Other Threatened Ecosystems
Sept. 23, 1992
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Douglas Reid
Otay Ranch Project Planning Office
315 Fourth Ave., Suite A
Chula Vista, CA 91910
RE: Otay Ranch draft program EIR (EIR 90-01, Log 389-14-98, SCH #890 10154)
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Dear Mr. Reid:
The Endangered Habitats League is a coalition of 36 conservation groups dedicated to land
use solutions. Our main concern is with regional ecosystem planning. Undoubtedly, Otay Ranch
is at the heart of the South County Reserve envisaged by both the San Diego Oean Water Mulitple
Species Conservation Program (MSCP) and by the State of California Natural Community .
Conservation Planning (NCCP) program. It is our understanding that both Chula Vista and San
Diego County are formally committed to the success of these programs, and the adequacy of this
document under the California Environmental Quality Act may prove pivotal in enabling us to meet
our conservation objectives. Our preliminary comments are as follows: .
1) A grossly inadequate range of alternatives is presented.
A clear differentiation between environmental impacts of the various alternatives is not
made. The names given to them (Phase II Progress Plan, Fourth Alternative, Project Team
alternative, etc.) are confusing. The goal of each alternative relative to the next - other than the
environmentally preferred alternative - is not clear. Furthermore, the bulk of the alternatives-
Phase I, Phase 2, Fourth, Project Team - are very similar to eoch other in tenns offootprint and
general design. As minor variations on a single theme, they provide a repetitious pattern of
development impacts, and do not present the public or the decision-makers with an adequate range
of project design options.
There should be, for example, a variation in approach to environmental consequences
amongst the alternatives, and different creative designs of the project to minimize impacts. But a
look at the alternatives reveals a consistent treatment of the resources and little real difference
between them. For example, the acres of development for several of the alternatives are
remarkably similar (10,498, 9,815, 9,646, 9,631).
Similarity among alternatives is very evident in terms of important environmental impacts.
In the area of reduction in coastal sage scrub habitat the following similarities are found: Phase 1
38%, Fourth 32%, Project Team 32%, Low density 32%, Phase II 32%. There is thus an
insufficient range of alternatives presented for the most sensitive habitat on the property. Lack of
variation among the alternatives is also evident for reductions in cactus wren habitat: Fourth 25%,
Project Team 25%, Phase II 25%.
Further evidence that the range of alternatives provided is inadequate lies in the summary
lists of sensitive habitats for which impacts are "significant and potentially unmitigable". These
lists are almost identical for the Fourth, Project Team, Phase I, Low Density, and Phase II
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alternatives. Impacts characterized as significant and unmitigable in all of these alternatives include
those to the highly sensitive California gnatcatcher and cactus wren.
The relentless similarity of the alternatives to each other is also evidenced by their similar
mitigation plans. For example, "Mitigation measures for the Fourth Alternative generally follow
those for the Phase I . . ." and mitigatic;m measures for Phase n in Table 4.9.4-2 are similar to
those suggested for the other alternatives. The same exact language for mitigation measures is
used for Project Team , Low Density, Phase I, and Phase n, and the reader is repeated asked to
cross-reference to another alternative to find identical mitigation measures.
The scope of mitigations required also demonstrates the inadequate range of options
presented. For example, for Phase I, Project Team and Fourth alternatives, impacts to the
California gnatcatcher and cactus wren are all considered unmitigable without "major project
design" changes.
There is also no differentiation between the alternatives as to which provides for a viable
regional preserve system, and which do not Decision-makers need this information clearly stated,
as it is perhaps the most important biologic parameter of all.
To summarize thus far, most of the alternatives are not meaningfully different in
environmental tenns, and this is reflected in the uniformity of their biologic impacts and the
uniformity of mitigations proposed .
The EIR compares the alternatives to Resource Management Plan (RMP) goals, but the
repetitious project designs are found to fail to meet RMP standards in the exact same ways. Thus,
identical language is used in the "Compliance of the Alternative with the RMP" sections for Project
Team, Fourth, and Phase I, and Phase II.
Conspicuously absent from this range of alternatives is an alternative which clearly meets
goals of the projecr's own Resource Management Plan. There is not even an alternative presented
which, after incorporating recommended mitigation measures, is found to definitively meet the
RMP standards.
The environmentally preferred alternative is not analYsed in terms of the RMP, and we thus
do not know whether it meets these goals. Furthermore, it may not be economically feasible, and
may be a "straw man". It is thus a flagrant shortcoming of this ErR that, after so much work, not
one single alternative is presented to the public which is found to meet the standards of the RMP,
definitively protects key resources, and positively contributes to a viable South County reserve
system.
This deficiency must be corrected before there is an adequate range of alternatives for
review. We need viable, serious alternatives which protect ecosystems and populations of
sensitive species in the long tenn. These alternatives should not be hinted at in "recommended
mitigation measures", but spelled out, analysed, and mapped as formal project alternatives.
It would be helpful if measures specified in Table 3.3-7 mitigation measures 10 and 11
were actually brought forth in a formal alternative. Also, an alternative needs to be developed
based upon the Environmental Alternative but perhaps with additional density added in non-key
resource areas or via consolidation with adjacent development This alternative should satisfy
RMP goals and preserve biological diversity while still being feasible for the applicant.
Another alternative which must be presented to the public and decision-makers involves a
design which fills in the large gap which exists between the Environmental Alternative and the
Phase n alternative in tenns of project design and land use. This alternative should begin with
Phase II and modify it in ways which ensure protection of key resources while maintaining
economic and planning feasibility.
The main elements of a modified Phase II should include: 1 )Reconfiguration of the Otay
River development footprint to pull back from important habitat adjacent to Salt Creek;
2)Elimination of the university site in Salt Creek; 3)Reconfiguration of the Otay River footprint to
better protect wildlife corridors, for example into Poggi and Wolf Canyons; 4)Realignment of
roads across the Otay River; 5)Redesign on Proctor Valley to widen wildlife corridors and pull
back from sensitive habitats; 6)Clustering and reduction in lot size in eastern San Y sidro to better
protect resources; and 7)Elimination of all development south and east of Otay Lakes on the San
Y sidro parcel.
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This last modification, to remove development including the village from the entire area
southeast of the Lakes, is essential to meeting project resource protection and RMP goals and in
meeting regional conservation needs. This area, like Salt Creek, is extremely high in sensitive
species and connectivity value. "High-end" homesites are better placed on the Proctor Valley
parcel above the resort, where fine vie)"s would result .if overiill density maintenance is required
for economic or other reasons, it can be compensated for in other development areas, or possibly
increased above a I: I ratio where a}J}JLV}Jriate from a planning perspective.
To conclude, we are extraordinarily disappointed that with the flexibility inherent within
23,00 acres and several thousand acres of degraded lands, the EIR has presented to decision-
makers a series of alternatives very similar in their environmental impacts and which do not meet
basic regional conservation goals. If an adequate range of alternatives, as outlined above, is not
feasible, analysis to that effect was not provided.
2) Mitigation measures do not reduce impacts to insignificance and are inadequate
in specificity.
In terms of mitigating damage to biologic resources, the EIR is never able to provide an
alternative nor mitigation measures which definitively reduce the most important impacts to
insignificance. As seen in the summary lists referred to above, almost all impacts to sensitive
resources remain significant and unmitigated. And unfortunately, when mitigations are discussed,
there are so many vague qualifiers, such as "potentially", that the decision-maker cannot make clear
and meaningful choices.
To illustrate these deficiencies, both Phase I and Fourth alternatives are said to "come
close" to the RMP. What does "come close" mean in a quantitative sense? Is it close in terms of
percentages of habitat conserved or in regard to long-term biodiversity in the region or some other
parameter? The analysis does not provide adequate specificity of standards.
Following this, it is said that the alternative can, "With some modification. . . potentially
allow maintenance of long term biodiversity". Vague qualifiers such as "some" and "potentially"
must be eliminated and more certainty given to the environmental consequences of various
proposed actions.
3) Adverse environmental impacts are not adequately disclosed.
As one example, impacts of extensive large lot and estate homes were not adequately
disclosed in terms of edge effects, feral animals, motor vehicles, etc. Interdigitating large lots with
habitat has risks and impacts which were not adequately discussed.
A major deficiency in this regard is failing to disclose impacts to regional multi species and
coastal sage scrub conservation. Please see cumulative impact comments below.
4) Impacts and mitigating measures are not consistently assessed relative to the
baseline of existing conditions. Net losses are thus not adequately disclosed.
The error was made of assuming that a partial set-aside compensates for impacts to the
existing resource base. For example, in Table 1-6 Biology, mitigation measures for the California
Gnatcatcher, cactus wren, vireo, and fairy shrimp are repeatedly defined as "preservation of
existing habitat" or "preservation of habitat in open space". Mitigation should only be discussed
as replacement, improvement or off-site protection of resources. If partia1 set-asides are
inappropriately employed as mitigation measures, net losses relative to existing resources are not
disclosed. This basic error must be consistently corrected throughout the EIR.
5) Cumulative environmental impacts are not adequately disclosed. There is
failure to include a reasoned analysis of the cumulative impacts of the project in a
form clear to decision-makers. (Guidelines section 15130(b)(3))
As an indicator of its inadequacy, the cumulative impacts section of this EIR is only 54
pages out of thousands. It is far too brief and cursory for this massive project which will impact
the entire South County regional ecosystem. In fact, discussion of cumulative cultural resources is
far more detailed and complete than the biological cumulative impacts section (12 pages vs 6
/--) !(
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pages). This again demonstrates the insufficiency and superficiality of the biology discussion.
In analysing the 31 nearby projects, it is insufficient to assume a 20% open space .
dedication without analyzing where that open space dedication would occur, i.e., the degree of
habitat fragmentation which would cumulatively result. Thus, much more information is needed in
the way in which open space dedications from other projects inter-relate to the Otay Ranch
proposals. Similarly, data for impacts to absolute numbers of sensitive species is insufficient. For
species such as gnatcatchers, there should be an analysis of habitat quality and fragmentation
considerations in addition to the raw numbers of pairs, which is the only parameter provided. In
summary, adequate judgements on cumulative impacts cannot be made by simple percentages.
To take an example of insufficient treatment of cumulative impacts, the New Town plan
causes 64 % of the coastal sage scrub impacts among the various projects, 30% of California
gnatcatcher impacts and 66% of cactus wren impacts. To state that total impacts would
"significantly decrease key regional resources" and "significantly reduce the populations" of
California gn~tcatchers and cactus wrenching is insufficient analysis. The most important
information needed by decision-makers concerns regional impacts to a future South County
multispecies reserve and coastal sage scrub reserve system. The cumulative impacts analysis
entirely neglects this vital consideration and instead bombards the decision-maker with statistics
which do not lead to intelligent conclusions.
As another example, the Phase I alternative, in relation to neighboring projects, causes 32 %
of coastal sage scrub impacts, 20-25 % of California gnatcatcher impacts, and 50% of cactus wren
impacts. The EIR then states that 50-60% of regional California gnatcatchers would be impacted
by Phase I and related projects, and 25-30% of cactus wrens in region wold be impacted. Again it
is insufficient to simply state that this is a "significant" effect on populations. A discussion of how
this impacts project goals in terms of preserving key regional biologic resources is needed. We
need to know, in clear and unmistakable terms, what is the cumulative impact to formation of a
South County reserve system, a process in which both Chula Vista and San Diego County are now
engaged. A few statistics do not form a cogent and meaningful analysis.
To improve this serious deficiency, we would have to know, for example, what is the
probability of a viable reserve system given all the surrounding developments now approved or
pending if New Town, or another alternative, goes forward. Will New Town, or other
alternatives, prejudice the long-temi viability of regional biologic resources, and if so, to what
extent? And if regional multispecies goals are to be met, what modification of the proposed
alternatives or mitigation measures are required? These deficiencies in the incomplete and
extremely superficial cumulative impacts section must be corrected or the most important
environmental consequences of this huge project cannot be evaluated.
6) Mitigation measures for cumulative impacts are insufficiently analysed,
without sufficient clarity, and are not supported by reasoned analysis,
The only discussion of mitigating cumulative regional impacts is limited to a short
paragraph in section 6.5.3. It states that cumulative effects of Phase I and the Environmental
alternative can "potentially" be mitigated. The vague qualifier "potentially" does not provide
sufficient clarity. The EIR goes on to state in very general terms what is necessary for mitigation,
and refers the reader to other sections for details, However, when the reader does cross-reference
to the measures specified in other sections, the information found is deficient in major ways.
Section 6.5.3 states that it is necessary to "protect key resource areas. . .onsite". When
section 4.2.4.2 is cross-referenced for details, however, only an incomplete and vague analysis is
found. We find, for example, that RMP requirements would only be "partially" fulfilled by Phase
I and furthermore, that the "RMP does not define the amount of a key resource that should be
preserved", It goes on to further equivocate "with some redesign and modification, the Phase I
plan could potentially achieve RMP policies and goals". We need much clearer information; an
analysis based on "partially" and "potentially" is inadequate. Without clear definitions and clear
standards and criteria, informed decisions on mitigating regional cumulative impacts simply cannot
be made.
Required is a clear statement of thresholds and standards for adequate mitigation of
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cumulative impacts, and these are missing. We are essentially "given the run-around" with a series
of "maybe's". Additionally, the modifications proposed in Table 4.2.4-7 which describe these
potential measures are never given tangible form in a mapped alternative plan and are thus never
presented in a way easy for decision-makers to evaluate. Such a presentation is needed
Also according to section 65.~, mitigation for cumulative impacts is also supposed to "tie
these areas together onsite and with adjacent off site areas to create a viable. . . preserve." The
specific mitigation measures to connect habitat areas are never given in a sufficiently detailed
manner to allow an informed decision. The discussion is entirely inadequate.
The document goes on to make conclusory statements that "Restoration of sensitive habitats
. . . will provide mitigation for the loss of habitat and sensitive species due to development" This
is a conclusory statement not backed up by reasoned analysis or specific proposals for coastal sage
scrub habitat A detailed analysis, including specific sites, restoration techniques, probabilities of
success, population estimates after restoration, etc. is necessary.
The conclusion that cumulative impacts to key resources "can be mitigated" is also not
backed up by any analysis or discussion whatsoever. The conclusion that the Phase I plan
"partially mitigates" is also not backed up in this section, and indeed, is not supported anywhere in
the document
We are also not told whether cumulative impacts were reduced to the extent feasible.
The cumulative biologic impacts section is grossly deficient and does not provide adequate
information to decision-makers, and yet is the most vital consideration. The most important
regional cumulative impacts of Otay and surrounding projects on a potential reserve system are not
adequately disclosed. Because they are not disclosed, they are not given adequate analysis in terms
of potential mitigation or required project modification.
A completely new discussion on the cumulative impacts and mitigations for Otay Ranch
and associated projects is necessary.
7) The document does not contain a sufficient degree of analysis to provide
decision-makers with information to allow them to intelligently take into account
environmental consequences (San Bernardino Valley Audubon Soc. vs. San
Bernardino (1984) 155 Cal.App.3d 738, 751). The criteria that the EIR must
provide "a sufficient degree of analysis to provide decision-makers with
information with enables them to make a decision which intelligently takes into
account environmental consequences" (Cal Code Regs., tit. 14, section 15151) is
not met.
This deficiency is evident in many sections, and is documented in the cumulative impacts
comments above. Other examples include the following:
For most of the alternatives presented, an "Analysis of Compatibility with Adjacent Natural
Areas" section is left out This is one of the most critical areas of or decision-makers to consider,
and all alternatives should provide an in-depth discussion of this parameter. Similarly, the
"Preservation of Key Resource Areas" section is missing from most of the alternatives studied.
These areas should be covered for all alternative.
The analysis in "Reduction of Sensitive Habitats" 4.2.4.1 subtracts coastal sage scrub
impacts in "restricted development areas". However, this may not justified if there are large edge
effects and indirect impacts on habitat in these "restricted" areas. Thus, full impacts to 1372 acres
of coastal sage scrub has not had sufficient analysis. The table 4.2.4-3 is also highly technical and
does not present the public with a clear idea of impacts.
There is an insufficient degree of specificity in the crucial area of the Resource Management
Plan (RMP). The document does not provide decision-makers or the public a clear and specific
picture of how RMP standards can be met because the RMP "does not define the amount of a key
resource that should be preserved". Thus, for example, when the EIR states that Phase I "comes
. close" to RMP standards, but needs "modification", we have no idea what this actually means in
real and specific terms.
If a goal of the project is to "preserve large blocks of key biological resources", we need to
know in a l7Ulpped fashion what meeting that goal actually requires. To rely on criteria such as
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70% of existing gnatcatcher habitat or 80% net pair protection does not tell us how the land
protected needs to be configured, what type of slopes or elevation ranges need preservation, or
whether adequate dispersal will take place. The EIR is grossly deficient if it cannot tell us in a
specific, readily understandable fashion what is required, in terms of actua1lines on a map, how its
own RMP goals can be met .
In general, the RMP is not adequately integrated into the analysis of alternatives, and it
appears that alternatives were developed independent of the RMP. If the RMP gave us specific
environmental constraints on a map, and then showed where development could occur consistent
with RMP goals, then this would constitute more sufficient analysis for decision-makers and the
public who are concerned with ecosystem and reserve protection.
S) Decision-makers cannot discern with a reasonable sense of surety that the
proposed mitigation measures will indeed ameliorate the problems proposed by
the project. A complete analysis of feasible mitigation measures is not given.
In tables such as 4.2.4-5, a repetitive series of proposed mitigation measures is given. The
analysis is deficient in that we are not told if these measures, upon implementation, would or
would not satisfy RMP goals or protect key biologic resources in the long term. No data or
reasoned analysis is provided which tells decision-makers whether the measures proposed would
or would not ensure the survival of various sensitive species or keep a regional reserve system
functioning. The series of mitigation measures is never put together in a readily comprehensible
format, such as a map, which would facilitate intelligent decision-making.
9) The document is not clear and comprehensible.
As documented above, a range of alternatives with differing environmental consequences is
not presented in a clear or orderly fashion. The names are confusing and the most important data,
such as impacts to a reserve system or key biologic resources, are not presented in an intelligible or
accessible manner. Superficial statistical analyses are frequently substituted for the type of cogent,
meaningful analyses which would be of most use to the public and decision-makers.
10) Adequate thresholds or standards for significance/insignificance are not
clearly established and they are not based upon biologically correct assumptions.
We do not know what is meant by "significant" or "insignificant" throughout this
document. Is this standard being applied for populations, a future reserve system, or exactly
what?
The closest ideas provided are in the "Key Resource Areas", which are mapped. These
areas are obtained by drawing lines around clusters of sensitive species - "circumscribing", as the
document calls it - and the EIR states that these boundaries will form the basis for decisions on
adequacy of different alternative plans. Are these assumptions biologically correct? Simply
drawing lines around clusters of sensitive species does not guarantee the viability of their
populations in the long term. Foraging territories, dispersal, genetic resources, and physiographic
variables such as slope, distance from the coast, soil type, elevation, vegetation type, disturbance
regime, etc., all need to be taken into account, but are not Without analysis of this type, the EIR
is incomplete and deficient
Thus, if thresholds for significance are based only on this clustering analysis, this
constitutes a gross oversimplification of biologic needs, and thresholds must be reconsidered in a
more holistic and comprehensive fashion. Decision-makers need to know what specific areas on a
map are necessary to preserve biodiversity on the Ranch in the long term, and not just to what
extent proposed development infringes on clusters of sensitive species. In table after table (Eg, 3.3
5,3.3-8,3.3-10,4.2.4-6), impacts are analysed in terms of percent impact of each sensitive habitat
or each key resource area. This approach is over-simplistic, and does not account for the various
physiographic factors enumerated above.
Decision-makers also need to see how alternatives compare with actual mapped preserve
designs. They cannot be expected to turn percentages of impact into a clear understanding of how
good a preserve design the alternative actually represents.
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The terms significant or insignificant and mitigable or non-mitigable are thus not defined in
a meaningful manner or given clear and understandable thresholds, or a clear and meaningful
presentation. As a result, decision-makers do not know, after reading this document, whether
regional ecosystem functions will be pompromised or preserved by the various plans and
mitigations offered.
11) Studies should not be deferred.
Wildlife corridor studies and results need inclusion in this EIR for review. Table 4.24-5
Road impact analysis is deferred. This needs to be done at this stage to provide adequate decision-
making.
12) Project goals are not met.
Section 2.5.1: A goal is "to provide for long term protection... of the diverse and
sensitive. . . resources". As noted in above comments, we are not given sufficient information to
judge whether this goal has been met as the RMP lacks specificity. Also, the cumulative impacts
analysis does not adequately treat regional reserve goals. Not one single alternative is shown to
meet RMP standards.
13) Off-site alternatives are unjustifiably dismissed and the range of off-site
alternatives proposed did not adequately focus upon eliminating significant
environmental impacts or reducing adverse impacts to insignificance (Section
15126 (d) CEQA Guidelines). Alternatives instead were selected on the basis of
other project goals. Adequate fiscal analysis was not presented.
It is unreasonable to base alternative site selection upon single contiguous sites of over
20,000 acres in size, which are extremely rare. Other alternative site options need consideration,
especially in that Otay Ranch is actually 3 discontiguous parcels, and alternative sites should also
be looked at in these terms. One option not explored in the EIR is a development site of a few
thousand acres and another mitigation site, but not contiguous. The criteria used of one single
huge site unreasonable forecloses feasible alternatives, and this requires further analysis.
The alternative site analysis was also faulty in that all factors were given equal weight in
determining whether one was environmentally preferable. Thus, biological impacts were equally
weighted with noise or light and glare. For this reason, the conclusions reached, that the
alternative sites were not environmentally preferable was the result of a superficial and self-serving
analysis. A more detailed and reasoned analysis is required rather than a single table which grossly
oversimplifies the issues. The biological impacts should receive far greater weight than some of
the others.
The statements that the off-site alternatives were all infeasible due to multiple ownerships
was conclusory and not backed up by adequate fiscal analysis. Compared to other sections.of the
EIR, this section was in general brief and superficial.
14) Description of environmental setting (Section 2.2) is deficient in that regional
significance of the site, for example to regionalmultispecies reserve planning, is
not fully disclosed.
This section should clearly state the importance of Otay Ranch to the regional ecosystem, to
a future reserve system, to regional wildlife movement corridors, and to maintenance of wildlife
populations. .
15) Growth-inducing impacts are not adequately disclosed or analysed.
To give one example, what will be the growth-inducing impacts of bringing road, water,
sewage and other infrastructure to the area south of the Otay Lakes? This should be analysed in
terms of inholdings in that region and effects on natural resources and BLM wilderness.
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While we thank you for this opportunity to comment, we must state for the record that our
review and analysis has been limited and hindered by the short comment time alloted. We have
only been able to review small number of potential issues, and not in sufficient depth. Entire areas
of the E1R have been omitted from th~ comments. Furthermore, there has been insufficient time
for our scientists to evaluate in sufficient detail the adequacy of the mitigation measures proposed
or the adequacy of impact disclosure. We thus reiterate our request for an additional 60 days to
review this massive and frequently unclear document.
Thank you for your consideration.
Sincerely,
6___ ~
Dan Silver
cc: San Diego County Board of Supervisors
Chula Vista City Council
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ENDANGERED HABITATS LEAGUE MEMBERS
Laguna Hills Audubon Society
Palomar Audubon Society
San Diego Audubon Society
Los Angeles Audubon Society
Buena Vista Audubon Society
Pomona Valley Audubon Society
Palos Verdes Peninsula Audubon Society
Pasadena Audubon Society
Sea and Sage Audubon Society
EI Dorado Audubon Society
Sierra Club San Diego Chapter
Sierra Club Angeles Chapter
Friends of Penasquitos Canyon
Shoreline Study Center
Carlsbad Arboretum Foundation
Cottonwood Creek Conservancy
Ecology Center of Southern California
Friends of the Hills (UC Irvine)
Defenders of Wildlife
Orange County Fund for Environmental Defense
Laguna Canyon Conservancy
Mountain Defense League
Save Our Coastline 2000
Laguna Greenbelt, Inc.
Friends of Batiquitos Lagoon
Friends of the Tecate Cypress
San Diego Biodiversity Project
Rural Canyons Conservation Fund
Friends of the Santa Ana River
Tri County Conservation League
Los Alamos Neighborhood Association
California Native Plant Society
Committee for the Environment (Orange County Bar Assoc.)
San Bernardino Sage Friends
Save Our Forest and Ranchlands
Friends of the Foothills
/)/)
CNTY. DPW DESIGN ENGIN TEL:619-694-2499
uc t lJl,92
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MEMO
DATE:
September 25, 1992
'1'0:
Bill Hoeben, County Review Coordinator
Pat Klock, Liquid Waste /?)z. .la.1<.
FROM:
SUBJECT:
Otay Ranch Draft EIR
------------.--------------------------------------------....---..------
-----------------------------~---------------------------~-------
The comments for tlle Draft EIR are the same as those for the June
17, 1992 review of the Facility Implementation Plan. But the EIR
should not be used to solve this problem.
A new development has occurred since the inception Of this project.
It had been assumed that the wastewater treatment facility at the
confluence of Salt creek and otay River would be constructed by San
Diego Metro under the auspices of the Clean Water Program. This is
no longer a valid asswnption. Can the developer afford to
construct a WWTP or will it have to be done by a municipal entity?
If, in these difficult economic times, no one can afford the
construction then lots of septic tankS will have to be the solution
and less dense development will be required.
RECEIVED
SEP 28 100')
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ENGIl...........
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The Baldwin Company
Craftsmanship in building since 1956
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September 29, 1992
Mr. Doug Reid
Environmental Coordinator
OTAY RANCH PROJECT TEAM
315 4th Ave
Chula Vista, CA 91910
Re: Draft EIR on the Otay Ranch
Dear Mr. Reid:
The following are the comments of the Baldwin Vista Associates on
the Draft EIR for the Otay Ranch. In general, we felt the EIR was
adequate and complete. The comments contained herein are intended
to clarify and contribute to the completeness of the document.
Each comment is numbered and begins with the page number to
facilitate responses to these comments. Transportation, circula-
tion and access will be addressed in a separate letter from Urban
Systems Associates.
Thank you for the opportunity to comment.
Sincerely,
(- - c;::. ,\
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Gregory T. Smith
President
11~
Enclosure
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11975 El Camino Real . Suite 200 . San Diego, CA 92130 . (619) 259-2900
EIR COMMENTS
1. Page 2-2-2.2.1: states rock mining quarry is 137 ac: pg.
3.1-2 -3rd full paragraph states 150 acres - we believe the
site is approximately 137 acres.
2. Page 3.1-45: third full paragraph: text states that,
"providing access to this area could have significant impacts
to the protected open space and proposed wilderness area that
surrounds it." This needs clarification. The New Town Plan
does not propose access to the adjacent BLM owned lands.
Public access to these lands already exists via the Minnewawa
and Otay Truck Trails. An access road would also be con-
structed to the small, non-contiguous parcel. However, an
easement and dirt road for this purpose already exists. In
short, no access beyond that already existing would be
provided. In addition, no protection exists for this open
space beyond that provided by the Forest Service, Sheriff's
Department and California Department of Fish and Game. Such
"protection" is provided to all land in the area regardless of
ownership. Please revise the draft EIR.
3.
Page 3.1-47 last paragraph: The New Town Plan
development is not inconsistent with existing RCA's.
3.1-31, the RCA overlay requires "special attention",
consideration and special environmental analysis".
this has been done and is consistent with the RCA's.
proposed
Per page
"careful
All of
4. Page 3.1-57 41"7: The property has already been surveyed a
number of times to establish the location of sensitive
resources. The composite preserve included in the RMP con-
sidered these resources in establishing the Preserve boundary,
to assure significant and representative areas were saved.
The RMP includes policies for preservation, enhancement and
protection of resources. In addition, the Biology section of
the EIR contains a detailed, exhaustive list of species,
specific mitigation measures and requirements for more focused
surveys. These afford additional protection. The intent of
the RCA's is implemented by all these measures. The imposi-
tion of such overlays at this point in time provides no
additional protection and will cause pointless unnecessary
future confusion. This mitigation measure should be deleted.
5. Page 3.2-31 - 3.2.3.2: It is infeasible to require the
GDP/Subregional Plan to propose guidelines regarding amount
and kind of remedial grading to be done in the river valley as
this area is the subject of a separate regional park planning
effort. Such guidelines should be included in the regional
park plan.
1
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6 Page 3.2-33: The draft states "Any cut and fill slopes in
excess of 15 feet shall be identified." This refers to the
entire Otay Ranch. The heading of this section refers to
visual impacts in areas visible to a large number of people.
To identify "any cut and fill slopes in excess of 15' in
height" is over burdensome for a SPA plan whose the reference
encompasses the entire ranch. The intent appears to be to
protect vista viewed by many people. There are currently no
regulations for reviewing slope heights at the SPA level. The
draft EIR should be clarified through use of the following
language: "Any cut and fill slope in excess of 15' in height
visible from scenic corriders and vistas shall be identified."
7. 3.2-34: "The GDP/Subregional Plan will require..." should be
changed to "The GDP/Subregional Plan will identify...". A SPA
should more appropriately identify and describe processes for
future discretionary actions.
8. Page 3.3-43: With respect to the four sensitive butterflies,
it should be noted that none were found during directed
searches at the appropriate time of year in 1992.
9. Page 3.3-65 through 3.3-67; Figure 33 - 6a-c: Footnotes are
necessary on these three figures stating that the boundaries
shown are generalized and do not precisely delineate either
resource presence or absence. The statement in the text is
not enough to convey this when one is actually looking at the
map.
10.
Page 3.3-71 to 3.3-75:
corridor differs from
importance or width.
difference.
It is unclear how a regional wildlife
a local corridor either in function,
Please revise the text to explain the
11. Page 3.3-89; #7A: Recommendations regarding Palomar Street,
Orange Avenue and University Avenue are either infeasible, or
already accomplished on the land use plan. Palomar Street is
located on a mesa, well away from Poggi Canyon. Orange Avenue
is located in the bottom of and on the south side of Poggi
Canyon, away from undisturbed habitat, and just missing the
south slopes, to avoid grading. The University Parkway
crossing is necessary for access to the university site.
In general, roads are located where it is feasible to build
them with the least amount of grading (least habitat distur-
bance). It is also necessary to meet specific safety stan-
dards. Relocating a road may result in more grading and
habitat destruction, or result in unsafe conditions. In
either case, road relocation is infeasible.
2
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12. Page 3.3-88; 2.g.: It is unclear where the Jamul Access Road
is located. Only one crossing of Jamul-Dulzura Creek is
proposed, in its existing location. Access to all developable
areas of the San Ysidro parcel is provided after. the road is
located south of the creek.
13. Page 3.3-89; 7b and 7g: This measure should more appropri-
ately be applied to CalTrans or the ultimate builders of SR-
125. SR-125 is a separate project from Otay Ranch and is the
subject of a separate environmental review.
14. Page 3.3-90; 12c: This measure is infeasible as traffic
studies show expansion beyond two lanes is necessary for
public safety. Existing Otay Lakes Road cannot be used as it
does not meet safety criteria for the volumes projected with
or without an Otay project.
15. Page 3.3-90; 7.d: It will not always be feasible or even
possible to enhance/restore habitat prior to impact, specially
in the first five years of the project or if unforseen impacts
occur. (The later would be handled under separate CEQA
review. )
16. Page 3.3-93; 25-28: The loss of raptor foraging is already
recognized as being unmitigable. The recommended measures
will not mitigate the impact. They are also infeasible as
they seem to require huge areas of otherwise developable land
to be left as open space to the point that the stated project
objectives cannot be met.
17. Page 3.3-95; #30: This measure should more appropriately be
applied to the agency that builds SR-125. (See comment #13.)
18. Page 3.3-125; #11: There is no rationale for the stated 10:1
ratio. It is excessive and infeasible. All areas of suitable
habitat with existing stands of trees are being preserved and
little or no restorable habitat is available. Only small
areas, mainly in drainage swages into which seeds have washed,
would be impacted, usually by infrastructure crossings. Such
areas would not be good restoration areas because of the lack
of concentration.
19. Page 3.4-24: There is no nexus between cultural resources on
Otay Ranch and the requirement for an interpretive center or
museum. Such a facility is not required for "mitigation".
The requirement that Otay Ranch, alone, build any such
facility goes far beyond the impact of the project and has no
rational basis. CEQA requires nexus between impacts and
mitigation. The mitigation measure should be deleted or
revised to reflect a regionally funded program and, therefore,
regional participation in establishing the facility.
3
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d
20. Page 3.7-2: Since the passage of Proposition 13, property
taxes have increased very little, having little impact on farm
income. The statement to the contrary in the draft EIR should
be corrected or deleted.
21. Page 3.7-10: Sources available to us do not show any Soil
Conservation Service (SCS) designation of Farmland of State-
wide Importance. The text, however, references the SCS method
of determining Statewide Importance. Please provide the
source of this information. If SCS lets each state make their
own determination as to Farmland of Statewide Importance, then
the text and graphics (Figures 3.7-2a,b &c) must be revised to
show there is no land 50 designated by SCS.
California Department of Conservation (CDC) criteria for
designation as Prime Farmland appear to be much more detailed
and specific to California than the SCS methodology. A broad
variety of physical and chemical parameters are used. The CDC
methodology also recognizes that for land to be productive, it
must have a dependable water supply. This more detailed
methodology is more useful in evaluating whether land will
ever support agriculture, especially given the astronomical
construction costs of the necessary water system. These costs
(see page 3.7-20) are 50 high that they would never be re-
couped out of farm revenues. Why are the more general SCS
classifications used to determine agricultural suitability
when the CDC system provides a more accurate assessment of
existing conditions? The use of the SCS methodology and
definitions is not mandated by CEQA.
22. Page 3.7-18: The County does not count Otay Ranch in the
168,317 acres of land currently in agricultural production.
The draft EIR adds Otay Ranch land to the above figure to
determine a potential 3% 1055 of land suitable for agricul-
ture. This does not provide an accurate estimate of 1055.
This estimate can only be accurately calculated if all
currently uncounted land in barley production is added to the
168,317 acres now in production countywide. Similarly, the
draft EIR includes a calculation of 5% of land suitable for
coastal dependant crops. This, too, is inaccurate unless all
potentially suitable land is added to that now in production.
Please correct the calculation to provide more accurate
estimates.
23. Page 3.7-26; Mitigation Measure #3: The area designated for
a community garden in the southwest portion of the Otay River
Parcel is indeed a suitable location. However, since the
river valley is currently the subject of a regional park
planning effort, it would be more appropriate and feasible to
have exact size and location determined as part of that
effort. This is not a SPA determination. We do not under-
stand how a community garden is mitigation.
4
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24. Page 3. 8-11~ Proposed Mitigation: The proposed mitigation
measures are not feasible. Extraction of all mineral re-
sources would result in unacceptable biologic and landform
impacts. At best, these measures would cause project inter-
ruptions that would. result in delays in completing road and
other infrastructure systems needed by area residents.
25. Page 3.9-12: The draft EIR assumes that all developed areas
would be covered with impermeable surfaces resulting in an
increase of 57%. The draft EIR points out that this is, "...a
conservative assessment of impacts." This is a severe under-
statement of a qross overstatement that needs to be revised
and clarified. One hundred percent coverage of any site with
impermeable surfaces is never allowed by any zoning code.
Indeed, when requirements for buffers, landscaping and open
space are added in to any site plan, it becomes difficult to
achieve 50% coverage even in an industrial area. Assuming 50%
coverage would result in a conservative estimate. Assuming
100% coverage of all developed areas is a gross overstatement.
The EIR should be revised. (Note: this applies to all
alternatives.)
26. Page 3.11-21: The first bullet calls for the elimination of
incompatible uses. The analysis section, however, calls for
site specific analyses to determine whether air quality and
associated health hazards would exist (Page 3.11-12). The
proposed mitigation measure should be revised to reflect the
analysis section.
27. Page 3.l2-27~ Rock Quarries: The draft EIR states that noise
levels from quarries may be significant anywhere within 9300
feet (1 3/4 miles) of the quarry equipment. This is so
inaccurate as to be ludicrous. Noise measurements are not
necessary at this time. The fact is that the quarry is
located in the river valley well below most of the Otay River
Parcel. The draft EIR should take this into consideration,
even using general guidelines when barriers and intervening
topography are present. The requirement for noise studies
anywhere within 1 3/4 miles of a quarry is unnecessary and
should be reduced to a distance more reflective of actual
existing conditions such as 500 feet.
28. Page 3.12-32: The measures suggested under "Exterior Noise"
are not feasible as they run counter to the village concepts
already accepted by the Interjurisdictional Task Force. These
should be deleted. The following revised sentence will
suffice: By considerinq the site's natural topoqraphy and
usinq appropriate site planninq techniques. it is often
possible to reduce and possibly eliminate noise impacts.
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29. Page 3.13-21: The third bullet states "Following the deter-
mination of which jurisdiction will provide water to Otay
Ranch. . ." This seems to anticipate a single jurisdiction will
provide water to the entire ranch. Given the jurisdictional
alternatives discussed previously, this may not be the case.
The third bullet should be revised to state: "Following the
determination of which jurisdiction will provide water to a
proposed SPA..."
30. Page 3.13-29: This comment is similar to the one above with
respect to water, and applies to the second bullet. The
second line of the second bullet should read, "...a proposed
SPA in Otay Ranch, a Sewer Mater Plan..."
31. Page 3.13-31: The first bullet requires an Integrated Waste
Management Master Plan to identify and reserve specific site
and to specify financing methods and facility timing. This is
not feasible or appropriate for a master plan covering several
decades, when site criteria and financing methodologies will
undoubtedly change. The mitigation measure should be revised
to read: ".. . The Integrated Waste Management Master Plan
shall include criteria for site selection and for the prepara-
tion of financing and for the preparation of facility phasing
plans, both of which will be done at the SPA level."
32. Page 3.13-37: An additional bullet should be added to more
clearly define the requirements of individual SPA's: - "Each
SPA shall address the requirements of the master plan."
33. Page 3.13-42: See number 31 above. This first bullet should
be revised to read: "The master plan shall address facilities
requirements of the service provider and shall include
criteria for establishina equipment needs. site selection and
location, and fundina mechanisms. This will allow the master
plan to be specific to the service provider and to function
well over the life of the project.
In order to clarify individual SPA requirements, the second
bullet should read: "Each SPA shall address the criteria and
requirements of the master plan includina a Public Facilities
Financing and Phasing Plan."
34. Page 3.13-44: See number 29 above. The first bullet should
be revised to read, "The master plan shall address facilities
requirements including criteria for determinina facilities for
hazardous material..."
35. Page 3.13-58: See number 31 above. The first bullet should
be revised to read, "The master plan shall include criteria
for site location. site and facilitv size..."
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The second bullet should be revised to clarify individual SPA
requirements: "Each SPA Plan shall address applicable
portions of the master plan and shall include a..."
36. Page 3.13-61; Figure 3.13-10: The crosshatched area on this
figure does not represent the Interjurisdictional Task Force's
proposed park area. It represents an area wi thin which a
regional park may be established, in effect, a different
focused area. Please correct the title of the figure or add
a clarifying note.
37. Page 3.13-66: The draft EIR states that the proposed project
is 501 acres short of required regional park acreage. The
draft bases this conclusion on the County's goal of 15 acres
per 1000 people for regional parks. This confuses the
achievement of a goal with the actual requirement. The County
has no requirement for dedication of regional park land. The
regional park system is to be achieved using a variety of
methods. Few, if any, projects are ever required to dedicate
15 acres per 1000 or an equivalent amount of money. Such a
requirement would likely violate the Quimby Act and Subdivi-
sion Map Act both of which establish land dedication require-
ments. This clarification would be reflected in the draft
EIR. It should also be noted that the New Town Plan provides
approximately 11.7 acres of regional park per 1,000 people,
nearly double the ratio that is currently provided.
38. Page 3.13-68: The fourth bullet requires the preparation of
a Parks, Recreation and Open Space Master Plan. As described
in #31 above, the requirement to include two jurisdictions,
specified site locations and landing mechanisms is too
detailed for a master plan that will be implemented over
several decades. This bullet should be clarified to state:
". . . in accordance with the required parkland acreage re-
quirements of the affected iurisdiction. The master plan
shall include criteria for facilities requirements. site
selection and location and fundina mechanisms..."
This clarification will enable the master plan to stand the
test of time while still being responsive to changing societal
needs.
39. 3.13-81: The third bullet references pre-school and school-
age children and the need for increased youth services.
Please clarify why this reference is included in a section on
senior services.
40. Page 4.2.2-4; #3 and #5: The draft EIR (Page 3.11-21) calls
for elimination of potentially incompatible projects. See
comment #26 above as it also applies to the Phase 1 alter-
native. With respect to the reference to Section 3.12, see
comment #24 as it applies to this alternative.
7
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41. Page 4.2.2-5; #7: See comment #4 as it also applies to this
alternative.
42. Minor ridgetops and knolls are seldom regarded as being
significant landforms. Statements such as these are inaccu-
rate and should be deleted.
43. Page 4.2.4-2; Table 4.2.4-1: This table states there are a
total of 9,595.8 acres of coastal sage scrub on the property,
while Table 3.3-6 states there are 10,305 acres - which is
correct? Which table was used in calculating impacts? This
is especially important as other documents, including the RMP,
relied upon Table 3.3-6.
44. Page 4.2.3.4: This section applies the mitigation measures in
Section 3.2.3.2 to the Phase 1 alternative (Page 3.2-32).
Several of these measures have already been incorporated into
the design of the Phase 1 alternative, notably the first,
second and fourth bullets, and the second full paragraph of
Section 3.2.3.2. This should be noted in the draft EIR.
Also, see comment #5 as it also applies to this alternative.
This section applies the mitigation measures in Section 3.2.3
to this alternative. This should be revised since both the
project design and proposed GDP accomplishes these measures.
See comment #7 as it also applies to this alternative.
45. Page 4.2.4-13-17; Table 4.2.4-5:
1. The "no net loss" statement is inaccurate as an approved
HCP can (and have) allowed a net loss. (See HCP' s for
Coachella ringed-toed lizard and the San Bruno silverspot.)
2.b. It may not be feasible to preserve areas where birds
have been seen previously but do not now occupy, and still
meet the project objectives or restore the river valley.
Condition 2a and 2f will protect existing birds while allowing
objectives to be met. 2.b. is confusing at best and should be
deleted.
2.e. The reference to SR-125 should be deleted as it is not
part of this project and will be the subject of further
environmental review.
3. This "no net loss" statement is unfounded as neither the
State or Federal government regulate the take of a cactus
wren. In addition, cactus wren are not endangered in the
major portion of their range. This statement should be
deleted.
8
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4. This measure needs to be more specific. A description of
the necessary redesign must be included so this measure can be
responded to.
5. See comment #10.
7. Such realignments are not feasible for reasons already
discussed in #11.
8. The RMP already commits to retention of 80% upon comple-
tion of the required restoration program. This statement is
unnecessary.
9. The infeasibility of #7 has already been discussed in
comment #11.
10. This measure is infeasible and is already discussed in
comment #44.
13&14 (Table 3.3.7). Directed searches for Quino Checkerspot
and three other sensitive butterflies were negative and none
were found.
15-17 (Table 3.3.7). See above comment.
25-28 (Table 3.3.7). See comment 16.
29 (Table 3.3.7). See comments #16, 44 and 47.
30&31 (Table 3.3.7). This measure mitigates
not the project considered in this document.
subject of separate environmental review.
SR-125 which is
It will be the
46. Page 4.2.4-15; Table 4.2.4-6: In reviewing the discussion of
impacts to grassland and the associated Table 4.2.4-4, it is
difficult to determine significance. The addition of another
column labeled "Mitigation Implementation" (similar to that
for coastal sage scrub) would be helpful to determine where
mitigation should be done and the exact acreage.
47. Page 4.2.4-30-42; Table 4.2.4-8:
1. Redesign to minimize or avoid impacts to coastal sage
scrub beyond what is proposed may not be feasible when
requirements for roads or other facilities are considered.
Simply moving roads may not reduce the size of the area that
must be graded. The Phase 1 Progress Plan avoids the majority
of coastal sage scrub. Where this was not feasible, efforts
were made to limit disturbances to edges, keeping existing
habitat blocks intact. This should be noted in the EIR.
9
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i /
1.b. The recommended elimination of low density, large lot
homes seems to be a rather extreme measure for such a small
area. No sensitive resources are located here that are not
already protected elsewhere on Otay Ranch. The drainage being
crossed is very small and is not a regional corridor. This
measure should be eliminated or revised to require further
study at the time of development.
1.d. The relocation of Otay Valley Road is not feasible from
either a traffic circulation or grading standpoint. A
significant amount of grading would be required, disturbing at
least as much natural habitat.
l.f&g. These appear to be incomplete or missing. We reserve
the right to comment on these two measures when we see them in
their entirety.
l.h. Such criteria are already included in the RMP.
1.i. See US.
2. See comments made previously on #1 above. Proposed
measures for maritime succulent scrub are similarly infeasi-
ble.
5. See #16.
8. This measure requires redesign to preserve areas where two
vernal pool plants were seen historically, roughly 10 years
ago. Neither has been seen since; in spite of a comprehensive
vernal pool survey. This measure seems to be unreasonable and
accomplishes nothing since the plants do not appear to be
present. It should be revised to eliminate the unreasonable
requirements.
This measure also goes on to state that 42 acres out of 332
acres of vernal pool restorable area are being preserved by
the Phase 1 Progress Plan. The draft EIR does not state that
the majority of the 332 acres is so disturbed that restoration
would have a very low likelihood of success, nor does it state
that the 42 acres is adequate to mitigate the small losses
that would occur. It is impossible to determine the appro-
priate acreage of actual vernal pool surface area that would
be impacted by the Phase 1 Progress Plan although it appears
to be approximately 1~ acre. Certainly this can be replaced
within the 42 acres available for restoration with plenty of
restorable area left over. The draft EIR should clarify these
points.
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48. Page 4.2.4-22: The university is not the subject of this EIR
as noted in the project description - either the description
should be revised or this reference to the university should
be deleted. References to SR-125 are not appropriate.
49. Page 4.2.4-23: See comment #10.
50. Page 4.2.4-27: The paragraph on Key Resource Areas should be
deleted. It is not part of the RMP. The amount of each ~
that is retained is irrelevant as the boundaries are very
loosely drawn and include large amounts of both sensitive and
insensitive land. What is relevant is whether the Phase 1
alternative meets the goals of the RMP.
51. Page 4.2.4-45; Table 4.2.4-4: California Orcutt Grass: The
term "wetter year" should be defined. Searches for this
particular occurrence of California Orcutt Grass have been
conducted for three years and it has not been located. This
same definition is needed for little mousetail and Greene's
ground-cherry. Much money has bee expended looking for
something which has not appeared. Every repeat study simply
adds to the final housing cost. This measure exceeds the
"reasonableness" rule on which much of CEQA is based.
52. Page 4.2.4-46: Variegated Hassesenthus: The proposed
mitigation measure seems to ignore the fact that the 70% to be
preserved includes huge numbers of plants on thousands of
acres that will be protected through the RMP. The amount
preserved is larger than many existing populations on other
properties and is large enough to be viable over the long
term. The proposed measure does not enhance the viability of
the plant. It does, however, make it more difficult to
achieve the stated project objectives. The measure is
infeasible and unnecessary.
53. Page 4.2.4-46; San Diego goldenstar: It is not feasible to
preserve 80% of goldenstar in the Phase I Progress Plan. The
necessary redesign would not allow the project objectives to
be met.
San Diego Navarretia: The proposed mitigation requires the
preservation of a highly disturbed area where this particular
plant has not been seen for several years. This does not seem
to be fair or feasible.
54. Page 4.2.4-49; Munz' Sage: See comment #49. San Diego Sun-
flower: See comment #49.
55. Page 4.2.4-50: Ashy Spike Moss: If the impacts are not
significant, than the recommendations are unnecessary. This
should be noted in the draft EIR.
11
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56. Page 4.2.4-51: The third bullet requiring the relocation of
Otay Valley Road is infeasible as it does not meet traffic
needs nor reduce grading. In spite of bridging the canyon,
the grading necessary would impact large areas of habitat in
the main and easterR area of Wolf Canyon.
It is also infeasible to delete Alta and La Media Roads
(fourth bullet) as circulation goals cannot be met. Both
roads are necessary from a regional standpoint irrespective of
whether Otay Ranch is ever constructed.
The fifth bullet references a university which is not part of
this project. The project description states separate discre-
tionary actions and environmental analysis would be necessary.
57. Page 4.2.4-52: The third bullet recommends removal of a
proposed residential area that is not close to any wildlife
corridors. This bullet should be removed. Any potential con-
cerns about this small, very low density area should be
handled by a specific study at the SPA level.
The requirements set through the fourth bullet are too broadly
stated. Both corridors are in open space on the Phase I
alternative. The draft does not document why wholesale
deletion of developable areas (these are largely chaparral) is
appropriate for these two corridors. It would be more
appropriate to establish the necessary width of these corri-
dors in the Phase II RMP and implement them at the SPA level.
The phrase about gnatcatchers is redundant and was already
made in the sensitive animals table.
Specific design studies and incorporation of specific corridor
width recommendations (RMP Phase II) would also be more
appropriate with respect to Corridor 11 (fifth bullet).
The sixth bullet references a "finger of development across
Corridor 8". Such a "finger" is not found on Figure 4.2-1
which shows a necessary road connection. The draft EIR should
be corrected.
58. Page 4.2.4-52: The Analysis of Significance states that
impacts to vernal pools and alkali meadow are significant and
unmitigable. In fact, the recommended mitigation measures are
feasible. The draft should be revised to reflect this.
59. Page 4.2.5-11: See comment #19.
60. Page 4.2.8-1 thru 4: See comments 21-23.
61. Page 4.9-1 thru 2: See comment #24.
12
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62. Page 4.2.12-1 thru 12: See comment #26. With respect and
Phase I Progress Plans, the Land Use policies (pg. 4.2.12-9)
are already incorporated into the project design to the
maximum extent feasible. As densities decrease, the distance
to recreation and commercial areas necessarily increases. The
EIR should reflect this beyond just using asterisks to
demonstrate potential infeasibility.
Most of the Sitting/Design policies are also incorporated into
the project design. It is, however, infeasible to eliminate
potentially incompatible projects. Such impacts, should they
ever exist, are more properly handled by site specific studies
at the SPA level when the status of the offsite incompatibi-
lity (e.g. quarry) and the actual project designs are known.
This mitigation measure should be revised. See comment 26.
The EIR should note that the Transportation-related Management
Sections (pg. 4.2.12-10) are the responsibility of the
jurisdiction. The Phase I alternative does not prohibit or
make it difficult for a government to carry out these duties.
63. Page 4.2.13-20 thru 22: See comments 27 and 28 as both apply
to this alternative.
64. Page 4.2.14-2 through 4.2.14-5: Wastewater and sewer service,
integrated waste management, police protection, fire protec-
tion and emergency medical service, schools and libraries.
See comments 30-35 as they also apply to this alternative.
65. Page 4.2.14-6: See comment #37 as it relates to regional
parks. See comment #38 regarding clarification of language
requiring a master plan.
66. Page 4.3.2-1: See Comment #3 and 4 with respect to RCA's as
it also-applies to this alternative.
67. Page 4.3.4-6: See comments #51-55 regarding sensitive plants
as these comments are also valid for the fourth alternative.
68. Page 4.3.4-5: The first paragraph under the heading Proctor
Vallev parcel, references the project Team Alternative rather
than the Fourth Alternative. It should be corrected. The
paragraph regarding wildlife corridors should also be clari-
fied. The requirement to set back should be modified to
include reference to the width established by the final
wildlife corridor study required for the RMP - Phase 2.
69. Page 4.3.4-6:
A. Least Bells' Vireo: See comment #45 - part 1 and 3.
B. Coastal Cactus When: see comments #45 - part 3.
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C. California Gnatcatcher: See comments #45 - part 7 and 8,
#10 and #45. Also comment #47.
D. Quino Checkerspot: Directed search in 1992 was negative
even though this butterfly appeared in other areas from
which it was previously known.
70. Page 4.3.4-7: Wildlife Corridors: See Comment #57. This
measure also recommends development be drawn back from
corridor #3. Since the wildlife corridor map Fig. 3.3-7 shows
two corridor #13, this is confusing. The draft and/or figure
should be clarified.
71. Page 4.3.4-7: Alkali Meadow is listed in the significant
potentially unmitigable section. It should be revised and
moved to the significant but mitigable section as relatively
minor changes at the SPA level can eliminate most impact.
72. Page 4.3.4-8: It is stated that impacts to Otay tarweed, San
Diego goldens tar and snake cholla are significant and unmiti-
gable. In fact, the majority of the existing populations,
often including thousands or hundreds of thousands of indivi-
duals, are preserved in large blocks of open space. Long term
viability is assured. The use of a simple percentage saved
vs. percentage developed does not seem to be an appropriate
measure in this instance. The draft EIR should be revised.
73. Page 4.3.5-10: Cultural Resources: Comment #19 also applies
to this alternative.
74.
Page 4.3.8-1
agricultural.
through 4: See comments #21-23 regarding
They are applicable to the Fourth Alternative.
75. Page 4.3.9-1: Mineral Resources: See comment #24 regarding
the infeasibility of the recommended mitigation measures.
76. Page 4.3.12-1: Air Quality: See comment #62.
77. page 4.3.13-1 through 6: See comments 27 and 28 as they also
apply to the Fourth Alternative.
78. Page 4.3.14-1: Water Availability and Demand. Wastewater and
Sewer Service, Integrated Waste Management, Police protection,
Fire Protection and Emergency Medical Service, Schools,
Libraries, parks - Recreation and Open Space: See comments 29
- 38 as they apply to the Fourth Alternative.
79. Page 4.4.2-1: The Impact Analysis states the project Team
Alternative (PTA) is incompatible with Chula Vista's plans for
a 4 year university. The land use statistics (Table 4.4-2)
show a 384 acre university site. Please explain the incon-
sistency.
14
/~JL
80. Page 4.4.4-5: All recommendations to pull back from wildlife
corridors are too general. A reference should be added
requiring the recommendations of the wildlife corridor study
(RMP Phase 2) to be adhered to at the SPA level.
81. Page 4.4.4-6: Sensitive plants: See comments t51-54 as they
also apply to this alternative.
Sensitive Animals: See.comment t44, 45, 8, 11 and 13 with
respect to Least Bell's vireo, cactus wren and gnatcatcher.
Directed searches for Quino Checkers pot in 1992 were negative.
82. Page 4.4.4-7: See comment t58 and 72 with respect to alkali
meadow.
83. Page 4.4.4-8: See comment t51-55 with respect to sensitive
plants.
84. Page 4.4.5-10: See comment t19.
85. Page 4.4.8-1 through 4: See comments t21-23.
86. Page 4.4.9-1: See comment t24.
87. Page 4.4.12-1: Air quality:
applies to the PTA.
88. Page 4.4.12-1 through 6: See comments t27 and 28 as they also
apply to the PTA.
See comment t62 as it also
89. Page 4.4.14-1 through 5: Water Availability as Wastewater and
Sewer Service, Integrated Waste management, Police protection,
Fire Protection and Emergency Medical Service, Schools,
Library Service, and Parks - Recreation - Open Space: See
comments 29-38 as they also apply to this alternative.
90. Page 4.5.4-3: In general, see comment t47 on Table 4.2.4-8,
pp. 4.2.4-30-42. As noted previously in comment 47-1d, it is
infeasible to move Otay Valley Road.
It is also stated that vernal pools, J-29, J-30 and J-31 are
designated for residential development. This is incorrect.
The land use plan (Fig. 4.5-1) clearly shows the land use
category and open space. The text should be corrected.
91. Page 4.2.4-4: Table 3.3-11:
Otay Tarweed: This alternative leaves huge populations
untouched in Otay River Valley. See comment t72.
California Orcutt Grass: See comment t51.
Least Bells' Vireo:
1. The "no net loss" statement is inaccurate as pre-
viously mentioned.
15
(if 7
2b. This measure is infeasible and unnecessary as
previously mentioned.
2e. Delete reference to SR-l25.
2g. Realignment of roads is infeasible as previously
mentioned.
Cactus Wren
4. Statement misrepresents status of cactus wren which
is widely distributed. It should be revised as
stated previously.
5. Statement is inaccurate as this alternative does
not propose a university in this location.
California Gnatcatcher
See comments previously made on suggested measures 4-7
and 7, 10 and 11. (Comments #11, 45 and 47).
92. Page 4.5.4-5: Analysis of Significance: It is not clear
whether the recommended measures would completely mitigate the
impacts of this alternative. Given the impacts to the Otay
River Parcel and the unknown potential for impacts to the
Proctor Valley and San Ysidro parcels it appears that, at the
very least, impacts at level of planning are significant and
unmitigated. Please clarify the draft EIR on. this point.
93. 4.5.5-10: See comment #19.
94. Page 4.5.8-3: Mitigation Measure #2: See comment #23.
95. Page 4.5.4-1: See comment #24.
96. Page 4.5.12-2: All measures under Land Use policies are
potentially infeasible given the L & LM designations and
resultant low population. The last two measures under
SittinalDesian policies on this page are potentially infea-
sible for a landowner. They should be applied to individual
project builders at a much later time.
97. Page 4.5.12-3 & 4: Transportation
Actions: See comment #62.
related Management
98. Page 4.5.13-1 through 5: See comments #27 and 28.
99. Page 4.5.14-1: See comment #29.
100. Page 4.5.14-2: Wastewater and Sewer Service, Integrated Waste
Management, Police Protection, Fire Protection and Emergency
Medical Service, Schools, and Library Service: See comments
28-33 as they apply to this alternative.
16
1;11/
/ TJ
101. Page 4.5.14-6: The land use table shows this alternative
would provide 772 acres of parks (assured to be combination of
local and regional), approximately 353 acres less than the
combined amount that is stated as the demand. This alterna-
tive does not provide regional parks at the desired ratio
stated in the County General Plan. This should be stated in
the Draft EIR.
102. Page 4.6.2-1: This alternative only provides enough land for
a community college or small private university (see project
description). This conflicts with Chula Vista's goal regard-
ing a 4-year university. The draft EIR should be revised to
reflect this incompatibility.
103. Page 4.6.4-4-6; Proposed Mitigation: The draft EIR generally
applies to the measures defined in Section 4.2.4.2. See
comments 45 through 47, and 52 through 55 as they also apply
to this alternative.
104. Page 4.6.4-6; Analysis of Significance: See comments
regarding Otay Tarweed (#72), San Diego Goldenstar (Comment
#53) as it applies to these plants, raptors (#16), and
wildlife corridors (#57) as they also apply to this alterna-
tive.
105. Page 4.6.5-10: See comment #19.
106. Page 4.6.8-1 through 4: The draft EIR states that existing
cattle grazing and barley cultivation would cease under the
Low Density Alternative. This is not exactly true with
respect to cattle grazing, which could continue throughout the
Proctor Valley and San Ysidro Mountain parcels since private
ownership of undeveloped areas could continue. See also
comments 19-22 as they apply to this alternative.
107. Page 4.6.9-1 and 2: See comment #24.
108. Page 4.6.13-1 through 6: See comments 27 and 28.
109. Page 4.6.14-1: See comment #29.
110. Page 4.6.14-1 through 9: See comments 30-38 regarding
clarifications in requirements for master plans.
Ill. Page 4.7-4; Table 4.7.4-2: The amount of coastal sage scrub
listed in this table (10,366 acres) does not match the amount
listed in Table 4.7.4-1 (9895.9 acres). Please correct this
discrepancy.
17
/49
112. Page 4.7.4-5 through 8; Table 4.7.4-3:
1. This
project.
measure references SR-125
It should be deleted.
which
is
a
separate
2. The "no net loss" statement is incorrect.
#45.
See comment
3 . a. Realignment of a. road is not always feasible. See
comment #11.
4. See previous comments regarding SR-125. See comment
#45.2b with respect to revegetation prior to impacts.
5. See previous comment #16
finding of non-significance
reduction in foraying habitat
with respect to raptors.
is inconsistent with a
(see page 4.4.4-13).
The
50%
6. SR-125 is not part of this project. It is the subject of
separate environmental analysis and discretionary actions.
The comment should be deleted.
113. Page 4.7.4-13: References to SR-125 impacts should be
deleted. It is also not clear whether impacts to raptors are
significant. Irrespective of the "point of occurance" data,
it eems that a 50% reduction in the amount of fields and
grasslands would significantly impact the number of raptors
now using the property. Not as many raptors will be able to
find food and the population will decrease. Additional
discussion of areas preserved and points of occupance are
confusing. The draft should be clarified to make it easier to
understand the significant impact.
114. Page 4.7.4-14: See previous comments on SR-125.
115. Page 4.7.4-15: The draft references the need for two roadways
with respect to Otay Lakes Road. This is confusing as there
would not be two roads. The existing road would not meet
engineering standards. It would be abandoned upon completion
of a new road. This comment also applies to page 4.7.4-29
where it is recommended that Telegraph Canyon Road and Otay
Lakes Road be consolidated. The draft EIR should be revised
and clarified.
116. Page 4.7.8-1: It is stated that all cattle grazing and barley
cultivation would cease. This is correct for the Environmen-
tal Alternative and reflects concerns raised by biologists
about agricultural impacts. Mitigation measures 1 and 4 (page
4.7.8-3) are infeasible as they conflict with the proposed
cessation of agriculture. In the case of measure 4, animal
keeping could result in more lot clearing, reducing the amount
of natural habitat that is otherwise available. Measure 5 is
18
/.("1'
.',.) ,
also infeasible for two reasons. First, the JPA overseeing
the Otay Valley Regional Park planning effort is planning this
area. Inclusion or exclusion of agricultural uses is their
decision. Secondly, much of the areas with "suitable agricul-
tural soils are already recommended for restoration in the
biology section of the draft. They are not available for
agricultural use.
117. Page 4.7.8-4: Analysis of significance: This section only
addresses the Otay River Parcel. Land with agricultural soils
would also be impacted on other parcels. In fact, as stated
in the project description, the Environmental Alternative
would eliminate existing agricultural uses and the potential
for a future use. More land would actually be removed from
agricultural consideration than would occur on other alterna-
tives. The impact on agriculture is more severe. The draft
EIR should be revised to reflect these facts.
118. Page 4.7.901: This section should point out that it will be
infeasible to extract mineral resources given the potential
biologic impacts. This inherent conflict can only be resolved
by the decision makers. See comment #24.
119. Page 4.7.12-9: Under Land Use Policies, the first bullet
should have the single asterisk (*) added. The Fourth bullet
is infeasible as this alternative does not provide a balanced
mix of housing and employment opportunities. Under
Siting/Design Policies, the last three bullets are not
appropriate at this time. They should be applied much later
when specific users are known. The draft EIR should be
revised.
120. Page 4.7.12-10: Under Siting/Design Policies, the fourth
bullet should have the double asterisk (**) added as the
overall population of this alternative is too low to support
mass transit. See comment #62 regarding Transportation _
related Management Sections.
121. Page 4.7.13-12: See comment #27 with respect to quarries.
Also, the mitigation measures do not include all of the
recommendations with respect to exterior or interior noise
reduction techniques that were included for other alterna-
tives. Since noise standards will be exceeded in many areas
of this alternative, these mitigation measures must be added
for the Environmental Alternative. Alternatively, if these
measures are not valid and appropriate for this alternative,
then the draft EIR should address why such measures are
appropriate for other alternatives that will result in similar
conditions.
19
1057
122. Page 4.7.14-1 through 4: Wastewater and sewer service,
integrated waste management, police protection, fire protec-
tion and emergency medical services, schools and libraries.
See comments 30-35.
123. Page 4.7.14-5: The Environmental Alternative includes no
regional parks nor is a replacement for regional parks. The
draft EIR does not address this apparent conflict with County
goals for regional park acreage. The JEPA effort is indepen-
dent of this alternative. The draft must be revised to
address the lack of regional parkland provision by this
alternative. Should the draft EIR find that the ongoing JEPA
effort is sufficient for this alternative, then similar
findings must be made for the other alternatives.
124. Page 4.8.4-1: The last paragraph on this page does not
objectively state all possible impacts of the Otay Ranch
remaining undeveloped. It is equally true that the land will
become more valuable for development and the economic pressure
to develop will be significant to both the landowner and
jurisdiction. This last paragraph also assumes the need for
mitigation will continue when public support for such activity
may disappear. The statement in the draft is biased, subjec-
tive and speculative. It should be revised or deleted.
125. Page 4.8.11-14: The Project Specific Mitigation Measure
section is puzzling. If there is no project, how can there be
project specific measures? Why are they even needed? Who
would be responsible for constructing these recommended
facilities when there is no project? If there is no project
to make up the deficiencies in the existing road system, then
it usually falls on the jurisdiction to carry out necessary
improvements. Given current limitations on budgets and
resources, it seems unlikely that these measures would ever be
implemented. The analysis of significance (Page 4.8.111-20)
should recognize this.
126. Page 4.9.3-1&2: See comments 39-41 as they apply to this
alternative. Mitigation Measure #3 (page 4.2.2-4) should be
deleted. Both quarries have residential uses designated as
either the underlying or nearby land use on the County and
Chula Vista General Plans. Both quarries operate under
conditional use permits. Both must expand the area of their
permit to continue operating. As such, they are the intrusive
incompatible use. Should the County or City allow expansion
of the permits or operation outside the conditions of the
permit, then they are reducing the ability of adjacent
landowners to implement the jurisdictional General Plans. The
landowner or developer should not bear the burden of eliminat-
ing the incompatibility. That responsibility belongs to the
jurisdiction and the use that is intrusive to the underlying
permitted uses.
20
J;)--;;Z
127. Page 4.9.4-5: The subspecific designation of the coastal
cactus wren has not been accepted generally in the scientific
community. Please correct the draft EIR.
129. Page 4.9.4-7: With respect to biology, see comments 45
through 58 on the Phase I Progress Plan. These comments are
generally applicable to Phase II Progress Plan.
With respect to the RMP, enough restorable area exists to
easily meet all RMP goals. The RMP uses a combination of
preservation and restoration to create the best possible
preserve system. The RMP further contains performance
standards that restoration programs must meet, to assure the
RMP is met. The Phase II Progress Plan can easily meet the
RMP goals for sensitive habitats using the combined preserva-
tion/restoration strategy outlined in said document. The EIR
should be revised to reflect this.
The same comment applies to sensitive plans and animals.
129. Page 4.9.8.4-8: It is difficult to find 12 regional wildlife
corridors on Figure 3.3-7. The numbering only goes up to R11.
Please specify how many local and regional corridors would be
blocked vs. local and regional corridors constrained.
The draft EIR incorrectly states that the Phase II Progress
Plan does not meet Policy 4.1 of the RMP. Policy 4.1 partial-
ly states:
"Design the Preserve to provide adequate habitat linkages and
wildlife corridors.."
The standards require important corridors to be incorporated
in the Preserve per the Wildlife Corridor study which was not
available when the RMP or Phase II Progress Plan was prepared.
In short, the RMP requires project redesign to reflect
recommendations of the then unavailable Wildlife Corridor
Study. This automatic mitigation insures that Goal 4.1 of the
RMP will be met irrespective of the specific project that is
approved. The draft EIR should be so clarified.
Under "Sensitive Habitats", the draft EIR states that impacts
to alkali meadow would not be mitigable without significant
project redesign. This is incorrect. Alkali meadow can be
preserved at the SPA level without major redesign. The draft
EIR must be corrected.
This section also refers erroneously to the mitigation
measures in Table 4.2.4-7. Said table has no mitigation
measures. The correct reference is Table 4.2.4-8. With
respect to the Phase II Progress Plan, see comment #47.
21
I~j
This section requires pull-back from J-30 vernal pools to
preserve undisturbed mirna mound topography. Surveys in three
years have located no vernal pools in this area. This
particular mitigation is unnecessary to protect actual vernal
pools, results in a. loss of developable land and should be
deleted.
130. Page 4.9.4-9:
comment #45.
The no net loss comment is inaccurate - see
131. Page 4.9.4-10 through 15:
6. See comment 45.8
8. The Phase II Progress Plan already includes large patches
of intact habitat. Restoration and project revision will
be done as required under the RMP to meet the RMP goal.
This may not include the areas listed, but will, upon
completion achieve the 80% level. This measure requires
more than is necessary and may not be feasible given
grading and engineering considerations. It should be
deleted and replaced with the requirement for conformance
with the appropriate RMP policy.
9. A reference should be made to the RMP map showing restor-
able areas.
12. Realignments may not be feasible. See comment #11
13. See comment #45.
14. See comment #44.
132. Page 4.9.4-16: California gnatcatcher and coastal cactus
wren: See comment #45 and #47.
133. Page 4.9.4-18: Impacts to alkali meadow can be mitigated
without significant redesign. Please correct the draft EIR.
134. Page 4.9.5-9: See comment #19.
135. Page 4.9.8-1 through 4: See comments #21-23.
136. Page 4.9.1-1 and 2: See comment #24.
137. Page 4.9.12-1 Air Quality: See comment #62.
138. Page 4.9.12-1 through 6: See comments #27 and 28.
22
/S-I/
139. Page 4.9.14-1 through 5: Wastewater and sewer service,
integrated waste management, police protection, fire protec-
tion and emergency medical service, schools and libraries: see
comment #38.
140. Page 4.9.10-2 through 10; Table 4.10-1:
A. Incompatible with Eastlake: The text of the draft EIR for
the Environmental Alternative states some potential incompati-
bility exists and includes the same mitigation measure as is
used for Phase 1 and Phase II progress plans. The table
should indicate the same impact for all three alternatives.
B. Incompatibility with Internal Project Land Uses on the
Otay River Parcel. The draft EIR text for the Phase II
Progress Plan Analysis of Significance finds no such
incompatibilities. The S should be SIM for this alternative.
141. Page 6-9; Section 6.3.2.2: The draft EIR addresses the
increase in developed land. It does not disclose the increase
in permanent open space. The addition of 10984 acres of
permanent open space from the Phase I Progress Plan to the
estimated 10,499 acres resulting from the other cumulative
projects represents a 100% increase. This should be added to
the EIR to provide the decisionmaker with all available
information.
142. Page 6-16; Table 6.5-1: This table includes estimates of
gnatcatcher and cactus wren populations in the cumulative
area. However, many of the projects in the cumulative area
have little vegetation data available. There is even less
data available with respect to specific species. While
estimates of the amounts of vegetation types can be done from
aerial photos, it is difficult to so estimate populations of
specific pairs. It must also be pointed out that gnatcatchers
certainly do not inhabit all coastal sage scrub. The esti-
mates in Table 6.5-1 are highly speculative and should be
deleted. References in the text using these speculative
estimates must also be deleted. All that is known is that
coastal sage scrub, gnatcatchers and cactus wren existed and
continue to occur in the cumulative area. Development has
undoubtedly decreased their populations. The Otay Ranch
alternatives will add to the decrease with the New Town Plan
responsible for the largest impact out of all the various Otay
Ranch alternatives.
23
/r::
143. Page 6-12; Section 6.6.3: This section states that existing
repositories for archaeologic data are beyond capacity. It
goes on to, apparently, assign the responsibility for curing
this regional deficit by requiring Otay Ranch to provide a
"regional repository". Requiring Otay Ranch to cure an
existing regional problem is illegal and unfair. The measure
should be deleted.
144. Page 6.32-36; Section 6.9 - Agricultural Resources: This
entire section uses CDC maps and averages to determine there
are approximately 15,139 acres of suitable agricultural lands
in the cumulative area. This is compared against 8,714 acres
for Otay Ranch. However, more liberal SCS maps were used to
calculate the 9,714 acres. This section should be revised
using all SCS or all CDC information to compare amounts of
suitable agricultural land in the cumulative region with those
on Otay Ranch.
145. page 6-32: Section 6.9.2.3 states grazing would continue on
the San Ysidro and Proctor Valley parcels. This is incorrect.
All grazing and barley cultivation would cease under the
Environmental Alternative. This should be clarified and
revised if necessary.
146. Page 6-26; Section 6.10.3: These measures are infeasible as
stated previously in comment *24.
147. Page 8-6: Development of a landfill at site E-16 would
eliminate a large area now planned for inclusion in the
Resource Management Plan (RMP l preserve. It would also
eliminate planned corridors that would allow California
gnatcatchers and cactus wren to disperse from Poggi Canyon.
The Poggi Canyon population would be isolated. It is unlikely
such small populations would remain viable over time and they
would be lost. The draft EIR should more clearly point out
this impact.
24
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QIouut~ of ~au ~i.eBo
GRANVILLE M. BOWMAN
DIRECTOR
(619) 694-2212
FAX (619) 268.0461
lOCATION CODE 550
DEPARTMENT OF PUBLIC WORKS
\ \ :.-.<;a.u.~'r'-€'NGrNEER'-
~ - COUNTY AIRPORTS
C O-':J~I-Y-ROAo-COMMrS-groNE R
'-TRANSPORTATION OPERATIONS
COUNTY SURVEYOR
FLOOD CONTROL
LIQUID WASTE
SOLID WASTE
5555 OVERLAND AVE, SAN DIEGO. CALIFORNIA 92123-1295
September 30, 1992
Ann Ewing
Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 92010
Dear Ms. Ewing:
Subject:
Review of Draft Environmental Impact Report -
Otay Ranch Dated July 1992
Ye have reviewed the traffic aspects of the various alternatives proposed in
the Draft Environmental Report dated July 1992. The report adequately
identifies the needed onsite and offsite road improvements to mitigate the
traffic impacts of the various alternatives on the local and regional
transportation system of roads. If the project approval requires that the
identified onsite and offsite road improvements are to be provided by the
proposed project or are to be provided by others prior to approval of the
various village units then the approved project will adequately mitigate its
impacts on the onsite and offsite roads by the construction of the recommended
road improvements.
If you desire any additional information, please contact Bill Hoeben at 495-
5287.
Very truly yours,
~
--"0 V ROGER F. YALSH
Assistant Director
RFY:YAH:sjc
cc: Roger Yalsh, DPY (0332)
Anna Noah, DPY (0385)
Steve Denny, DPLU (0650)
Bob Hoglen, DPY (0336)
Steve Thomas, 315 Fourth Avenue, Suite A, Chula Vista, CA 91910
otyran.mem
/ s---;
1
EXTRACT - Joint CountyjChula Vista Planning Commiss~~~
Public Hearing~'orkshop - September 16, 1992 ~0[..;j~~~~I_
,~;\. _:~~ (v-
o ~..~ L,." "-
Citv of San Dieqo: Chai~l"'~'~''.:)mm~).
sioners Carson, De~~I't~oo~~;~~~j~. ~~~~h~~er
Countv of San DieqQ~..",.o~~~' .'jtt~ Commissioners
Bro~m, Ferraro, Kast~A~ "" er and Leich tfuss
vg,
COHHISS IONERS
PRESENT
PUBLIC HEARING:
DRAFT ENVIROffi1ENTAL IMPACT REPORT (CITY OF
CHULA VISTA EIR-90-0l, COUNTY OF SAN DIEGO
LOG NO. 89-14-98, SCH NO. 89010154
This being the time and the place as advertised, the public
h~aring was opened.
B. Public Comment on the DEIR
Dan Silver, 1422 N. S\oleetzer #401. Los Anqeles. CA 90069. I
represent the Endangered Habitat League, a coalition of 36
Southern California conservation groups, dedicated to land use
solutions. Our purpose is the protection of viable ecosystems
through proper planning. Otay Ranch is a test case. The Ranch
forms the cornerstone of the South County Multiple Species
Preserve System to which both Chula Vista and the County of San
Diego have committed by their membership in the Clean ',ater
Program, HSCP and the State of Cal ifornia and NCCP. If the
resources of Otay Ranch are not protected, these larger goals
will vanish. Our goals in reviewing this EIR is simply to
realize the intent of the Environmental Quality Act. That is, to
identify the most environmentally sound yet economically feasible
project. Unfortunately, our preliminary analysis shows that this
severely plotted document does not serve that basic and essential
function. Its inadequacies are many and \~e will later provide
written comments. We also need an additional 60 days to comment
and we protest the current rush to judgment. At this point, we
can point to two major and critical deficiencies. First, the
range of alternatives presented is grossly inadequate. There is
little difference between most of the alternatives in terms of
footprint, scope of development, adverse environmental impacts
and in proposed mitigations. Reflecting this similarity, the
reader is repeatedly cross-referenced from one alternative to the
other and for all except the Environmental Alternative impacts to
the most sensitive coastal sage scrub species are all significant
and unmitigable. There is also a huge gap between the several
uniform choices and the Environmental Alternative which we
consider to be an unrealistic, strong end proposal and not one
/(t
EXTRACT - Joint County/Chula Vista Planning Commission
Public Hearing/Workshop - September 16, 1992
2
single option presented to you, with the possible exception of
the Environmental Alternative is found to satisfy the require-
ments of the project's own Resource Management Plan. Also, after
reading this EIR, the decision makers simply do not know whether
any alternative meets the regional conservation needs of the NCCP
or MSCP. With 23,000 acres of flexibility and much degraded land
we have truly been cheated of alternatives which are financially
viable and meet resource protection needs. Yet, that is exactly
what the CEQA process aspires to and what CEQA requires. We urge
you to prepare additional alternatives, perhaps major modifica-
tions in Phase II, and circulate these for additional review.
Our Group may be presenting its own suggestions at a later
hearing.
The second major inadequacy is the insufficient and cursory
disclosure of cumulative impacts. The biological chain of
ilnpacts cover only six pages. Yet, this is the most crucial
part. Th e EIR substi tutes a superf ici al statistical tabl e f or a
reasoned, meaningful analysis and sets no standards or criteria.
If you were looking for a clear, meaningful analysis of haw a
particular alternative impacts a potential multi-species preserve
system when considered along with other developments, you will
not find it in this document. Furthermore, the minimal
discussion of mitigations is full of conclusionary statements not
backed up by analysis and is plagued by vague words such as
"potentially" and "partially." While we believe that our mutual
goals may be achievable, this document has a long way to go
before being legally adequate and a long way to go before it
produces an alternative for your consideration which both the
community and the natural resources deserve. Thank you.
Nancv Nicolai. 364 Elkwood Ave.. Imperial Beach, CA 91932. I am
a member of the South County Environmental Working Group and I am
also an ecologist. While there was a lot of good field work
conducted for the preparation of this EIR, I found that the
document and its Resource Management Plan is inadequate and
deficient in those biological issues I have been able to review
so far. I am unable to review this document adequately in the
time that I have been given. I will not be able to finish my
review within 60 days. I support the concept that our communit-
ies can plan and preserve habitats to preclude listing species as
endangered. This concept is at the heart of California's Natural
Community Conservation Plan, or NCCP, and it has been endorsed by
the President a couple of days ago. I understand that the City
of Chula Vista and the County of San Diego enrolled in this plan.
Baldwin's Otay Ranch is clearly a test case for the NCCP process.
If we fail on a project the size and importance of Otay Ranch,
the u.S. Fish and Wildlife Service and State of California will
wonder how the NCCP can work and who would want to join the NCCP
Ar
EXTRACT - Joint CountyjChula Vista Planning Commission
Public Hearing~vorkshop - September 16, 1992
3
if it can't work here. It can work here. There is room to plan
on the project site. There is no deterioration in the habitat
and ecosystem functioning on site like there is on so many
project sites where endangered species are concerned. There are
plenty of opportunities to connect important biological resources
to open spaces off the site. However, the project as proposed
and most of its alternatives do not promote the NCCP. It can
work if we use vision rather than go through another planning
process for yet another development plan. This is a vital time
to show how a visionary project can work. Part of the vision I
anticipated for this project was the accomplishment of the
natural areas preserve that is biologically driven. Preserves
better than the REPRO Guidelines and should take REPRO's place.
Unfortunately, the Otay Ranch preserve does not do this mainly
because there is no guarantee that a preserve will be set aside
with the passage of the EIR. We need to see solid evidence that
guarantees the existence of the preserve when the EIR is passed.
I suggest that we have enough biological information to date to
create the basic outline of the preserve and its connections and
these areas should be set aside in perpetuity. In addition,
guaranteeing the existence of the preserve ought to include
practical ways to set aside the monies for the infrastructure of
the preserve. Finally, the EIR should with the project and all
its alternatives, except the Environmental Alternative, sig-
nificantly impact nearly all sensitive habitats and sensitive
species. We have been hearing about that ad infinitum this
evening. These resources will remain significantly impacted
because they are inadequately mitigated. The project and its
alternatives do not conform to the standards of the RMP and do
not set aside a preserve designed by the RMP. This project has
the potential to become a star but I can only conclude that there
is little faith in creating a preserve on Otay Ranch and in
protecting environmental resources. Use the information we have
and conduct a little bit more research. We must leave no stone
upturned to find means for economic stability and environmental
health. I also understand that there is a wildlife Corridor
Study that became available September first and I was wondering
if I could have a copy of that? Thank you.
Pat Parris, 3154 Juniper Street. San Dieoo. CA 92104. I am a
member of the South County Environmental Working Group. My
appearance today is in regard to my August 19, 1992 request for
documentation of the Otay Ranch EIR processing period. Because I
did not receive a response within 10 days of my request as
required pursuant to Government Code 6255, I telephoned Deputy
City Attorney D. Richard Rudolf, on September 10, to enquire as
to a response. The following is my recollection of Mr. Rudolf's
concluding remarks regarding my request for documentation. That
the documents requested must be identified with more specificity
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and to contact Mr. Lettieri to see if arrangements can be made
regarding my request. If arrangements are made, not to impede
staff in my request for documents. The following supplement to
my original request of August 19 is in response to Mr. Rudolf's
request for greater specificity of the documents. That all
documentation from the date of Baldwin's application for the
development of Otay Ranch to the filing of the Draft EIR be
provided. To further qualify the adequacy of the identification
of the documents in question, the definition of public record is
any writings containing information pertaining to the conduct of
the public business prepared on, usually attained by any State or
local agency regardless of physical form or characteristic that
is pursuant to the Public Records Act. The intent of the Cali-
fornia Environmental Quality Act concords with the Public Records
Act. CEQA's Policy Statement essentially provides that it is a
duty of every citizen and every governmental entity to take all
action necessary to enhance the environmental quality of this
State. Pursuant to the California Public Records Act access to
information concerning the conduct of the people's business is
the fundamental and necessary right of every person in this
State. So I would like a decision as to these documents being
provided to me. Mr. Rudolf was supposed to come forward today.
Chair
11e may have a response later in the evening. It
is on the agenda.
Hs. Parris
All right. Thank you.
Carolvn O'Patrv, 1380 Space Mountain Lane. Jamul. CA 91935. I
am here as a citizen of Jamul, a member of Chaparral Green and a
member of the South County Environmental Norking Group. I have a
few questions if it's appropriate to answer them tonight or
whatever. Nhich agency will be making the decision about the
extension of time to review the EIR, will it be you the Commis-
sion?
Chair
We can make a recommendation.
Hs. O'patry If you can let us know who will be making that
decision and when? And then there was the ques-
tion about the lead agency, Chula Vista being chosen as the lead
agency. The EIR doesn't seem to address this annexation of the
Otay Ranch property. The rumor is that 10,000 acres will be
annexed and, I think, Anne addressed the prezoning - we would
like to know if that is going to happen and where? You said the
City of Chula Vista would approve that but not by resolution?
Hs. Ew ing
By ordinance.
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Hs. O'patry
Okay. Thank you.
Tricia Gerrodette. 11142 Caminito vista Pacifica. San DieDO. CA
92131. I am here as Chair to the Land Use Committee for the
Sierra Club, San Diego Chapter, and I would like to express my
disappointment that the applicant found and acknowledges that
there are problems with his New Town Plan but that he did not
then amend that Plan for EIR purposes. I found this the most
frustrating and confusing EIR that I have ever had to deal with.
I think because of the lack of a fixed target. Since the New
Town Plan is admitted to have flaws and not be the best possible
proposal, how are we to respond to possible impacts of this
proposal? If the proposal changes as it almost must, how
relevant would our comments be and how adequate can the EIR be?
I think we must have a realistic project before we can have an
adequate EIR. Thank you.
Carolvn Avalos. 605 Hvqeia Ave.. Leucadia. CA 92024. I am a
member of the San Diego County Board of Directors for the Endan-
gered Habitats League. I previously lived in Tecate for several
years. I continue to own property in that area. I have reviewed
parts of the EIR and one particular element of concern to me is
the water resources and water quality element. Briefly, in the
County's Resource Protection Ordinance, Article I, it states that
it will protect sensitive lands to prevent their degradation and
loss. Wetlands are named as "environmentally sensitive lands."
This Ordinance requires that resource protection studies for such
areas as the drainage system throughout the three properties. I
have not been able to obtain this study, however, what I see in
the EIR is disturbingly inadequate. In Article IV of the Ordi-
nance regarding development criteria, it says, "grading, grubb-
ing, clearing or other activity or use damaging the sensitive
habi tat lands shall be prohibi ted." It goes on to say that, "all
feasible measures necessary to protect and preserve the sensitive
land are required as a condition of permit approval." Yet, I
repeatedly read in the EIR, as, for instance, on page 3.9-16.
that increased run-off could "affect water quality in the ground
water and surface water system." That is a masterpiece of
understatement. Sedimentation, a witch's brew of run-off con-
tamination, increased or decreased flows in the drainage system
because of human activity and, finally, pollution of the already
heavily taxed coastal waters will certainly occur. Our riparian
network are the circulatory system of the land and the ultimate
wildlife corridors and guardians of habitat and they need to be
given much more consideration than what I can find in the EIR.
They are merely treated as conductors of run-off which will
apparently increase due to the addition of up to 57% impermeable
surfaces. In conclusion, such massive intrusions into and
manipulation of the existing ecosystem not only will cause
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immediate change in the habitat and wildlife patterns but will
also ensure on-going degradation. Thank you.
Caroline Coulston.. 141-B South El Camino Real. Ste Ill.
Encinitas. CA. 92021. I am an attorney and I have been retained
by South County Environmental Working Group with regard to this
project. The South County Environmental Working Group is pres-
ently reviewing the Otay Ranch EIR. We are very concerned
because we will not be able to adequately review this intimidat-
ingly large document by the October 7, 1992 deadline. Nonethe-
less, we can already tell that the document is inadequate in a
variety of ways. I think, most importantly, because it is not a
comprehensive document at this time. There are numerous referen-
ces to outstanding documents including a Wildlife Corridor Study
which we have not received. The informal conversations with
staff have indicated that there will be a staff recommendations
a:ternative presented to the Planning Commission and this will
force the public and the decision makers to review these docu-
ments in isolation. I wish to disagree with Mr. Reid's charac-
terization of a programmatic EIR as requiring less analysis than
a tentative map EIR. All environmental documents pertaining to
later parts of the project will incorporate by reference all the
material found in this EIR. Therefore, this EIR must provide an
ecologically sound basis and it must be adequate. Anne Ewing
mentioned the prezoning and annexation by the City of Chula
Vista, however, it is completely unclear whether Chula Vista has
applied for annexation or how much of the project will be annexed
if application approved. CEQA and State Law on this matter
provide that lead agency status should be the public agency with
principle responsibility for carrying out or approving a project.
If prezoning has been done by the City of Chula Vista or if
annexation has been applied for, then it will be the appropriate
lead agency. But, since we have been unable to review the entire
document to date, we have not been able to determine any language
which indicates either prezoning by Chula Vista or annexation
application. This person questions Chula Vista's status as lead
agency. The EIR is confusing and complex. The South County
Environmental Working Group is requesting that you extend the
public review period until, at least, December 7, 1992.
Julie Dillon. 416 Universitv Ave.. San Dieqo. CA. Good evening,
members of the Commission. I am representing the Helix Land
Company which owns 480 acres in the San Ysidro area next to Otay
Ranch. As I mentioned to you, a few weeks ago, at one of your
workshops, we are doing some preliminary planning now of this 480
acres and we just wish to ensure that the EIR before you provides
enough information for the land uses surrounding this property
and also the public facility needs to our property line. (Thank
you, Tony, there is the 480 acres.) We also question if we can
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7
plan everything around us without having an idea of what's going
on on our property. So we have begun doing some preliminary
studies, something like this (sketch of area map displayed). We
don't have anything yet to submit to you but what we are doing
now is going through the preliminary information - the slope
constraints, biology and other considerations to come up with a
land plan and we would welcome working with the Project Team
staff to share our preliminary thoughts and plans. Thank you.
Robert Fisher. 701-11 E. Shore Terrace, Chula vista. CA 91913.
I am a biologist from the University of California at Davis and I
am qualified with reptiles, amphibians and small animals and
vernal pools. I would like to address those issues as part of
the biology that has been done. I have done professional work of
EIR level for six years and field work in this region for thir-
teen years. I have experience on-site along Proctor Valley Road
w~ich is the only place I have been able to access and data I've
seen which I would estimate - I would expect to be base line data
of herps is entirely misrepresented in the EIR and the EIR is
inadequate at that level. That is just driving down Proctor
Valley Road without moving off the road. The species lists in
the EIR for sensitive species are not consistent between the
Draft EIR and the Appendix and the documents that are used to
create the EIR. Each document has its own species list of sensi-
tive species and what species occur on- or off-site and there is
no consistency and as several species presences are not included
in the Draft EIR but were listed in the documents that were
created and included into the Draft EIR, the studies that were
previously by the Baldwin Company, and it formed the basis for
the biology of the Draft EIR. I feel that with regard to herps
and small animals - with regard to reptiles, amphibians and small
animals, the surveys taken were inadequate to collect base line
data for the Draft programmed EIR. Only 32 days of survey work
was done between the two biological surveys that the Baldwin
Company had contracted and those 32 days form the basis of the
base line data for biology for the site which to determine what
the distribution of sensitive species on-site are to set the base
on the base line level. To get adequate base line data for the
reptiles, amphibians and small animals, just sensitive species on
site, would take no less than 150 days of field work based on my
estimate with my experience. Good biological data was only
present for high-profile species in the EIR, the gnatcatcher,
cactus wren and the Least Bell's vireo. No other sensitive
species are addressed at that level and all of them have dif-
ferent levels of sensitivity that are either equivalent or below
those profile species and they should all be addressed at the
same level of base line on biological data. Therefore, this data
is needed - this base line data is needed before significance can
be identified for these species. NCCP guidelines are not fol-
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8
lowed for surveying orange-throated whiptails my impression is
they were followed for the gnatcatcher and for the cactus wren,
and the orange-throated whiptail is the other species in the
NCCP's guidelines that wasn't adequately surveyed for... by the
guidelines. Lo\~ priority sites that are identified in the Draft
EIR which are agriculture land and then the far eastern end of
the site... of the San Ysidro site may have significant impacts
to several sensitive reptiles and animals that are not addressed.
These animals were not surveyed for on this site. Again, gnat-
catchers and other things were surveyed for on the site and they
weren't found but other species of less high-profile probably
occur throughout that site and they were not addressed.
Chair
Mr. Fisher, will you answer a question, please?
(Yes) Mr. Ferraro
Ferraro
Would you identify some of the animals that were
on-site that were not mentioned in the EIR.
Fisher Yes. The western skink, the Coronado skink, is on
the Federal registry. It is a C-2 species and
shows decline and it was found in the RECON - no, it's not in
there -in the HBA Report, in the 1989 report, that they used to
be present on-site and it was never followed through on in the
Draft EIR. The spade-footed toad is another one that was found
on-site by MBA as I'lell as other things that were not followed
through. So, using those reports, they should have picked up
those, I mean, I looked through those reports and they're still
present on site. Thank you.
rlichael Beck. P. O. Box 841. Jul ian. CA 92036. I am a member of
the South County Env ironmental I'lorking Group. I would 1 ike to
reiterate some of the things that have been said already since I
am one of the later speakers. With respect - specifically with
respect to the data from the EIR, since you undoubtedly have been
reviewing it, you are familiar with the use of qualifying lan-
guage throughout; vague references and statements that if you're
reading to read the EIR perhaps can be acceptable, but if you're
reading it to analyze the EIR and compare the alternatives
presented within the EIR, it essentially eliminates any kind of
quantitative comparison. I have a few examples that I will read
out but that is, in terms of its adequacy, one of most obvious
and immediate things that is evident. The EIR almost reads as if
it is a document that has been developed separately from the RN1P
and the RAlIP, as language in the EIR states, is supposed to be
the County's equivalent of the Resource Protection Ordinance and,
yet, there are no specific quantitative references to the amounts
- to the amounts of plants, animals, significant biological
resources that are preserved and it is very difficult to imagine
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how you can apply an ordinance strength to something that essen-
tially is subjective interpretation. It is essentially impos-
sible. One of the other most significant elements that is
evident in the EIR is the statement that refers to it in associa-
tion with the NCCP, the MSCP and other regional programs to
establish a preserve system. Now, coincidentally or otherwise,
the MSCP is in Phase II now, the mapping phase. They've done
their inventory phase which in one respect is equivalent to the
work that has been done on this EIR. The EIR and the MSCP people
say that these two projects should be coordinated and yet, in
fact, they are not done by the same biological consultant even
and, yet, there is no coordination. The EIR states that there
should be coordination and Otay Ranch will undoubtedly be the
most significant part - the most significant element to a South
County regional preserve system and, yet, there is no coordina-
tion. We don't even know if they are using the same criteria.
We don't know how they're analyzing the various alternatives or
whether they are and how they would fit into a regional preserve
system. So, how are we to judge what - for you or any of the
decision makers to judge what makes the most sense in terms of
the most significant question? To give one more example, since
I'm running out of time, about the language as one is reading the
EIR or analyzing it. Assuming that someone is analyzing it and
not just reading it, Section 3.9-14 is a section that is in the
Water Section and has to do with the changing surface water flow
rates. This was just two days ago I was reading this, and I read
it and I read it and something's wrong here and, maybe you can
clarify it for me. They are talking about the increase in
impermeable - the increase in surface water flow due to the
impermeable surface area that will obviously result from develop-
ment and, within that section, they talked about the minor
tributaries that are found on the property and how they will be
impacted evidently and obviously. Now, the minor tributaries as
well as the major river system are natural wildlife corridors so
the statement implied is these would be affected. They also make
a very definite statement, and it's again obvious, that there
will be an increase in erosion and siltation. Presumably, this
would be equivalent to whatever the increase in flow is. The New
Town Plan is 57% increase in permeable areas so it is very
significant. Yet, in this section it says - in the mitigation
section response to this it says that, "studies will show an
increase in erosion siltation and that this problem" - the
problem will be addressed by studies and the studies would take
place after the specific plan level, after the EIR is certified
and, at that point, where before in the EIR they made a statement
that we would leave the tributaries open where possible (again,
those qualifiers) the hydrologist can, after the fact, after the
EIR is certified, determine which ones will need to be channel-
ized and, essentially, has carte blanche to say everyone of them
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because, right here it says after the fact someone can decide
what the erosion siltation problem is. There is no way for us to
analyze the impacts of his relative to any of the alternatives
that are presented. So, I would also, of course, like to ask for
an extension of time to review this. Those of us who have been
working on it and honestly diligently working on it find we do
not have enough time to do analysis. Maybe to read it but to
analyze it. Thank you.
James Mavberry. 987 Lorna View. Chula Vista. CA 91910. I would
like to point out what I see as a conceptual flaw in this EIR
which, in fairness to its authors, may not have been part of
their assignment so to speak. The treatment of - First of all,
let me say that it would seem to me to have been made clear by
the table that was shown that if the Baldwin New Town is approved
as proposed, that this area as far as being any kind of habitat
for wildlife is history. That, even under the so-called Environ-
mental Alternative, that there is not really going to be much
left over. That being the case, it seems to me that the decision
that revolves around to this - do you recognize or do you not
recognize the uniqueness of this parcel of land? Southern
California has grown the way that cancer grows since the end of
World War II, let's say to pick a point. Places like Otay Lakes
are not common. Now, the EIR speaks of the No-Action Alternative
in terms of it being simply a state of inertness or repose and I
would take issue with that characterization of the alternative
because there are going to be needs of this community that would
be met by the No-Action Alternative that are not addressed, to my
knowledge, in the EIR. Specifically, there is the question of
whether the Lake will be needed in the future as a water storage
site. In other words, will the Lake have to get bigger in order
to hold the water for all of the people who continue this trend
of cancer-like growth in this area? Second of all, there is the
question of how does the destruction of this wildlife habitat fit
into the larger picture? Some of the species, as has been said
here already, are already facing extinction. If this habitat is
destroyed for a species which are not now facing extinction, the
destruction of this habitat could very readily lead to the danger
of their future extinction. If that doesn't playa part in this
process, then, I think, you should say so. But, from our review,
the EIR doesn't say anything about that. Thank you.
Jim Bell. 2923 E. Spruce st.. San Dieqo. CA. 92104. I've got a
little display that I want to show you. I am an ecological
designer and I was part of the Interjurisdictional Task Force.
wrote a report on the Otay Ranch Project called, "Ecologically
Integrated Planning: A Case Study - Otay Ranch: Maximizing Eco-
nomic Sustainability" which has been updated and I brought some
updated copies for you to have. Basically, what I did here was
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get a map of the agricultural soils in the form of an overlay and
the - (unrolls map)
Chai r
Can you hold on a minute, please, while we get our
stuff here? Got it?
Bell I took a look at the EIR too and it is pretty
confusing. One of the reasons why it is
confusing is there is no l'lay to correlate all the different
information that is being dealt with. What I'm basically calling
for is we need some transparent overlays to Sh~i where the
agricultural soils are, where the habitats are, where hazards
are, where these wildlife corridors are going to be in conjunc-
tion with all these other resources to really be able to analyze
it to see l'ihether it makes sense. As I did this agricultural
soils Qap I found that, for the most part, the sites that the
Buldwin Corporation has picked are not that great agriculturally.
Mostly they are #7 and #8 agricultural soils which is sort-of at
the lower end of the scale. But, without that overlay, there is
no way to really tell. There is some Class 4 soils that are
pretty good quality that Ilould be iQpacted, not a Ilhole lot.
But, I think, we really need to know what we are losing and we
need a forQ of presentation so we can tell really what's going
on. I don't think that's really - that has happened in the first
place. In the copy of the report you have there, there is a
section called, "Ecologically Integrated Planning" and that was
actually added to the original c:oCUQent that Ivas accepted by the
Interjurisdictional Task Force. But it basically called for a
way of mapping the si te that liould map the whole drainage systeQ
to begin Idth so Ive could see not only the project but proposed
projects (which was brought up in terms of the other site that
someone spoke about a few minutes ago) and we can see the I-Ihole
drainage basin in its entirety so we can tell about the Ivater
fl~iS and so forth. One of the maps that is sholm in the back
has the drainage basins outlined. I've been in this field since
1974. Hhen I was involved with the Interjurisdictional Task
Force I said, "\'leI 1 , you want me to give you and ecological
evaluation? I can't do that with the available resources.
Without some kind of mapping available so we can see different
resources and hazards and so forth, in synergy, there is no way
to tell lihether if the plan makes good sense or not. It may very
well make good sense but there is no way to tell Ilith the infor-
Qation as we have it nOli as it is presented." Thank you.
Adrien rIvers, 1890 Ithaca st., Chula vista, CA 91913.
I had an opportunity to go through the EIR and find it basically
incomplete. It has not answered some very vital considerations.
One is that it says something like the impacts of historic and
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prehistoric resources are unknown. I think we need to know that
first. Another is the overall water issue. It says, "further
analysis is necessary to determine the magnitude of the impact
and to identify measures appropriate to mitigate significant
effects. Well, I guess that says we need further analysis, it
clearly says that in its own EIR. A third issue, I think is very
dear to my heart, being a teacher for the last 25 years, is the
matter of schools. To build some 6 to 32 new schools seems to me
extraordinary. The money for these schools is supposed to come
from the developer, from the Mello-Roos Assessment District and
from the State funds. There are no State funds for schools.
Since the EIR has been completed our State has become embroiled
in a very large turmoil as far as school funds are concerned.
The EIR never mentions where the salaries for these teachers for
these 32 schools will ever come from. I am very concerned that
is an inappropriate choice to make to say there would be from 6
to 32 new schools when there are no funds to build those schools
or pay those teachers. Thank you.
Marcia Jones, 370 Andrew Ave., Leucadia. CA 92024. Ms. Jones
submitted a letter, dated September 16, 1992, for the record.
This letter addressed concerns about water-related issues in the
EIR.
Chair
I am going to call a five minute recess and we'll
come back and continue with Item IV. Make that 10
minutes.
RECESS:
7:06 to 7:23 p.m.
The meeting was reconvened at 7:23 p.m.
C. Plannino Commissions comments on DEIR
The Chair asked for comments from the members of the Planning
Commissioners on the Draft EIR for staff.
Wright I guess I would like to raise the question that we
covered at a previous meeting and that had to do
with the discussion of the adequacy of water availability and I
would refer you to the LAPCD letter, I think everyone got a copy
of that, that letter of September 10, 1992. In that letter the
author touched on many of the points that we had talked about
previously but went into them in a lot better detail. I guess my
question is to staff, somebody on staff who could respond to the
LAPCD letter, or do you feel it is necessary to respond to that
at this time?
Reid
and,
in that
/1r.
all
case,
Ch ai r .
letters
in much
We will, of course, b~ responding to
incl uding the one from LAPCD
detail. Probably, I think, we could
/0r
13
get a response back to you by your next Commission meeting, if
you'ld like, or at the time of the Final EIR.
Wright I thought it was staff's position when we talked
about this before, that this sort of issues - a
lot of the water issues could be dealt with at the specific plan
level. Is that still staff's position or am I misstating what I
thought was...? Or does staff have a position on that?
Lettieri The Commission has requested that of staff, I
think there were a number of referrals back to
staff and one dealt with water, with availability, and we have
been working with the a1A to come up with additional information
to respond to that, however, we have not gone through the LAFCO
letter. I think what Doug Reid is stating is that for the purpo-
ses of the EIR we will do that and try to bring back a response
on October 7. If not, certainly with the Final EIR.
Chair
Commissioner Wright.
Wright Okay, so the response is still in an evolutionary
stage of being developed. Okay. I just wanted to
make the comment that I agreed with much of what I read in the
letter and it really does seem to me that the EIR is woefully
inadequate when it comes to the regional water issues and the
questions about regional water supply and the role of this
project in the regional picture. I'll drop it at that point.
Chair
Commissioner Ferraro.
Ferraro I have some concerns about the EIR. First of all
with a broad brush paint...a broad brush which I
paint with. I'm concerned about some items in the EIR that have
been put off until a specific plan amendment (or some other
device which will have to be initiated) and that these items that
are being put off are significant items that need to be addressed
in the EIR now because of the pOlicy-making nature. One of them
(along with Chairman Wright) I am concerned about is that we have
a fuller discussion regarding water. Where is it going to come
from? What is the impact going to be on other agencies? How the
San Diego Water Authority is going to obtain water? I think that
is one of the items that should be more thoroughly discussed and
not be held over for a SPA.
I am concerned about the jurisdictions. I would like to have
more designation of who is going to operate in the areas where
these developments are going to take place and whether or not,
and what are their capacities to handle the responsibilities?
For example, is the Otay Lakes area going to be in the County or
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is it going to be in the City of Chula Vista? If it's going to
be in the County, what does that mean for existing County policy?
If it's going to be in Chula Vista, what does that mean in terms
of what the existing Chula Vista regulations are? I don't think
it should be put off until that area starts coming under an SPA.
I think that specified jurisdictions should be identified and
impacts regarding their administration, how they are going to
administer...? For example, last time, we talked about the Fire
Protection Facilities. We had a Public Facility Plan in which we
were asking questions about the fire protection agency. However
we did not get involved into who was going to conduct those fire
protection facilities? What agency was going to be responsible?
l'las it Chula Vista? Was it rural fire department? Hhat is a
separate fire department? Nhat was their response time? How
many engines? I think we need more specific data to be in this
EIR rather than waiting again for an SPA.
I think we should be talking more specifically about sewers. I
would like to see some additional data about specifics. About
hOI'i we are going to handle the sewers. l'Iho is going to handle
the sewers? The EIR calls attention to (perhaps) San Diego,
calls attention to some other agency that is going to handle the
sewers. But, I would like to have some specifics, some iden-
tification and the impacts of that identification. I l'iould like
to defer my comments until, maybe, later on again. I have some
additional comments.
Ch ai r
Commissioner Leichtfuss
Leich tfuss Thank you, Hr. Chai rman. I don't kno\'i
whether to ask the County Counsel (we call
our County Counsel our Attorney, I don't mean the Council per se)
or the City Attorney or who to ask but l'ie deal, in the County, a
little differently with the Draft EIR and what would be the
process right now? Would we making suggestions for inclusions of
things such as Nright and Ferraro have? Is that how you handle
it? Because if we are, I have a number of items that I would
like to see a little more work done on this Draft EIR after
listening to testimony.
Rudolf Ilr. Chairman, since I am the City's Legal
Agency, I think I can respond to that. The
purpose of this portion of the Agenda is for comments from the
Commissioners. In our process we have the public hearing, get
the public input and then ask for comments and directions from
the Commissioners. In this particular instance, the
recommendation will be for continuance to still another meeting
where there will be another option for further public input and
further comments from you. Obviously, our preference would be to
the extent that you had a chance to go through and arrive at some
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15
comments, to give us direction tonight.
Leichtfuss Hay I continue? (Chair - Go ahead.) These
are the items. (1) The "university site"
that it be looked at, as I referenced before, for different uses.
(2) I don't know who to deal with the verbiage that was brought
up several times by members of the audience. But I, too, found
the verbiage vague in the fact that it was difficult to make a
specific determination. So the verbiage was a problem as far as
not being very specific so that I could draw conclusions. (3)
The issue of annexation, to have that looked into further, and
the prezoning. (4) The water that Commissioner Nright mentioned.
(5) The species list, to make sure that is consistent. (6) The
regional preserve system. I felt that should be addressed more
specifically in the Draft EIR. (7) There was a good question
brought up as far as the No-Action Alternative and the Lake. It
struck a real chord with myself corning f rom North County. lie are
in the process of, perhaps, increasing Lake Holford and that has
been causing a lot of problems in that area. It would be a lot
easier to deal with any Lake expansion in the Draft EIR. (8) If
the Draft EIR could address a little more specifically what I
call the "building blocks of extinction" for the preservation of
species. In other words, how one impacts the other. (9) The
mapping of the drainage basin and soils I thought was another
important item. Thank you.
Chair
Commissioner Decker.
Decker I suppose I go next or I could defer to someone
else. My comments are very short. I would like
to, first of all, commend the public for their thoughtful and
insightful comments. They covered far more area than I \~ould
have covered but they covered the area that I had included. I
would like to bring your attentian to the No-Project Alternative.
It is treated as a null case the way I see it in here. But, in
reality it seems to me that the No-Project does have positive and
negative impacts. I would like to see that examined a little bit
more. Because obviously something is going to happen if we don't
do anything and we need to understand what those are. Even if we
don't ever select that alternative, we need to understand those a
little more than just no impact at all. I'm sure there are some
impacts if we think about it carefully. I thought to use the
Lake as an example: the species degradation, the area itself is
not getting better, if it's getting better or getting worse,
doing something. If you don't do anything at all, it's still
going to have some impact - if we don't have a project at all.
So, I'd like to see what those are. So we can at least look at
that as a viable possible alternative as opposed to the null
case.
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EXTRACT - Joint County/Chula Vista Planning Commission
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16
Chair
r.lr. Krei tz er
Kreitzer Mr. Chairman. I would like to address water
again. Richard Wright, I think, covered that
pretty well, but I also did notice very much that there is
nothing addressing the sources of water. If you just take the
figures from the EIR here of an average of 600 gallons/day/dwe-
lling and take the New Town Project, you are talking about 30
million gallons of water/day. That doesn't include commercial or
industrial of the parks' or anything else use of water. Or take
the Project Team Alternative, which comes to about half of it,
you are still talking about 14-1/2 to 15 million gallons of
water/day. Is that going to have to come out of other people's
allotment? Does that mean it comes out of the City of San
Diego...comes out of the City of Chula Vista? There's only so
much water. How far can we stretch it? How much can we ask
people to conserve so we continue this kind of growth? That has
t::> be addressed.
Mr. Decker, your commenting on the No-Project Alternative is
important too because we need to know what will happen to this
land if it is going to be built, how it's going to be built if
this project does not happen. Then, we have the same kind of
issue going on in the urban reserve in the north part of the City
right now. If we don't build now with the current framework
plan, then what's going to happen? \'le're going to have 10-acre
ranchettes out there and that kind of thing. It is important, I
agree. I have no idea ,Ihat happens down here, that never even
been discussed. That is something that should be touched upon.
What is the potential if this doesn't happen?
Overall - can I say another thing? I know we have gotten letters
here from the Sweetwater Community Planning Group asking for an
extension on this to November 15th. This is a huge document to
really...to digest. You can't digest it all but go through and
read and then go back later on and find there are questions you
have and so forth. I really think we do need to have more time
on this. I have a personal problem in that I'm going to away all
of October and I'm going to miss the next meeting. I hate to
miss it but I know you can't make a decision on one person but I
do think, for the publ ic' s sake too \~e need more time on it.
Chair
r.lr. Kreitzer, we will handle that under Item VI.
Commissioner Carson.
Carson I also have been very impressed with the quality
of the public opinion and your input tonight and
I was probably most impressed by Jim Bell. The reason I was
impressed by Jim Bell was because it comes down to what I need as
an individual. I need those visuals. I need to see those
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EXTRACT - Joint County/Chula Vista Planning Commission
Public Hearing^'orkshop - September 16, 1992
17
overlays and that was something, I think,
last meeting and you said would be coming.
come very timely for us to be able to see it
public that they also want to be able to put
hole where it belongs so we can actually see
for.
I requested at our
I think it needs to
and I sense from the
every key in every
where we are headed
Everything that has been covered today that you are requesting, I
am in 100% agreement with except I have one other question or one
other request for organization. Because this is such a massive
project and in order to do justice to it I feel that (and I'm not
going to talk about the extension, that's another thing, okay).
What I want to address is the fact that - in our next public
hearing that we earmark the key things that are going to take up
the majority of our time. If we want to talk about the biologi-
cal resources, then have a presentation on biological resources
so the public can give input back as to what they have heard from
the developer. If we want to talk about air quality or sewers or
water or anything, prioritize the things we are going to come up
and give to us so that I can be a better organized Commissioner
listening to the input and feel that I have done the project
justice. Equally, the publ ie, I think, can feel that they have
had their input on everyone of those agendas. So we have a
table of contents assigned that tells each one of the important
things that we are covering. I would like to see those taken
almost step by step and prioritized. If there is something low
on the end, we feel there is something very, very minor - then
leave it at the very tail end. That is my personal opinion and I
just feel it is a matter of organization. That is how I need to
operate whether or nor anyone else would need to or not. That's
how I f eel. Thank you.
Chair
Commissioner Wright
Wright I wanted to wait until the other Commissioners
have had a chance but I did have a couple of
points that I wanted to cover. I'll wait.
Chair
Commissioner Kastelic
Kastelic I don't really have much to add to what the
Commissioners have said but I do have a question
about the Planning Commission for Chula Vista and what your
decision-making powers at this point since we do it a little bit
differen;_" :.r: the County. The decision that you make or propose
to have made at the next meeting, is that to close public tes-
timony and just decide that issues have been discussed or oppor-
tunity has been given to the public to participate and at that
point it would be closed? Is that the sole decision that you
make at that point?
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EXTRACT - Joint CountyjChula Vista Planning Commission
Public Hearing~vorkshop - September 16, 1992
18
Chair
Perhaps Tony or Rich could address
don't believe we are at that point
intervening things that will occur
give a finite answer to that.
that but I
yet. I think
between now and
there are some
then for us to
Kastelic
Whether you make the decision next week or not, I
just want to understand your process.
Lettieri
I believe 1-1:"" "cid, the Environmental Review
Coordinator, should respond to that. (Thank you.)
Reid The basic procedure is that during the public
hearing we take testimony on the adequacy of the
EIR, get guidance from the Planning Commission, close the public
hearing which closes the public review period. Then we go back
and prepare the Final EIR which is brought back to the Planning
COmmission to ensure that all the responses are adequate and any
modification to the text of the EIR that were requested have been
made.
Kastelic The question I have is, if your Planning Commis-
sion determines that the period for public input
is not adequate, is that your sole responsibility? I notice on
the Agenda coming up is "Comments to the Board and Ci ty Council",
so your decision is advisory to your City Council on whether or
not this public review is adequate?
Lettieri
TO the Chair. The City of Chula Vista's local
CEQA Guidelines give authority to the Planning
Commission to extend public review.
Kastel ic
So it rests with the
that decision - the
sion?
Planning Commission to make
Chula Vista Planning Commis-
Lettieri
Yes.
(Okay, thank you.)
Wright
Could I just add to that? See, we are strictly
advisory to our Board of Supervisors on that
point.
Kastel ic
We don't make any determinations in the County.
\'7righ t
No, but we can make recommendations.
correct, in this instance we can make
dations to our Board.
No, that's
recommen-
Kastel ic
Right. But it would be held up if the Chula Vista
Planning Commission determined that the time has
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EXTRACT - Joint CountyjChula vista Planning Commission
Public Heaiing~lorkshop - september 16, 1992
19
been inadequate just by
as a Joint Commission.
tics here, I guess.
the very fact that vie couldn't move ahead
I'm just trying to understand the poli-
Chair
Commissioner Wright.
wright I'd like to get to a couple of points. Commis-
sioner Carson, your point is good about having
data presented in more informative fashion. The interesting
thing about it is that we don't need to go back to (I don't want
to call Mr. Bell's efforts less than sophisticated, I think that
they are pretty good) except we do have all of this data in
digital form. We are in a position where we can crank out all
sorts of combinations of different factors. All we have to do is
ask for what we want. It's a lot easier to get that kind of
information than to laboriously produce a series of overlays and,
not denigrating Mr. Bell's efforts, I think they are pretty good,
i~ is just that it is kind of silly for us not to take advantage
of the fact that this data is in good form and we just need to
tell staff what we want and that data can be presented as infor-
mation then.
The other thing I wanted to ask the Commissioners how they felt
about this when they heard the presentation. Let me just check
my notes. !1r. Silver, I think it was t1r. Silver and some others
too, made some comments about the range of alternatives. The
notion that, here we have the New Town Alternative over here,
over on this end of the scale we have, say, the Environmental
Alterative or (I'm still thinking about the No-Project Alterna-
tive and the implications for that and how we need to deal with
that) and then, it seems as though (in my way of thinking about
it) that most of the other alternatives fall - if you divide the
kind of a scale in half - most of the other alternatives seem to
fall more toward the New Town Alternative. And I'm just wonder-
ing whether that's an adequate range - well, the range is there -
the New Town all the way to the Environmental but, I'm wondering
about the distribution of alternatives throughout that range and
whether you feel that is adequate or what we have been given is
adeq ua te?
I also have a sense that the New Town Plan is just kind of a
straw sitting there and it's supposed to be knocked down and then
we deal with these other alternatives and I think the public is
having some problems (and I'm having problems) dealing with the
fact that the project is the New Town Alternative when it prob-
ably should be some other alternative. I know at some point in
time you have to pick a project. But, it seems like this project
has evolved to a point over several years where the New Town
Project is, maybe, somewhat dated. There has been a lot of new
thinking that's gone on and a lot of new data, and yet we seem to
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EXTRACT - Joint County/Chula Vista Planning Commission
Public Hearing/Workshop - September 16, 1992
20
be hanging on to that New Town Alternative as the project. I
don't know. I have some uneasiness about that. I don't know how
the rest of you feel about it. I'd appreciate any comments you
might have.
Chair
11r. Decker
Decker Mr. Chair, I would like to comment on this. I
would note that Mr. Lettieri mentioned this
somewhat earlier in our process that we aren't limited to one of
the specific alternatives. l~e can actually form a hybrid of any
or all of the alternatives or anything we feel is useful or
necessary. So, I want to leave that in everyone's mind. Don't
feel obligated to pick one of the nine. If there are good parts
of one you want or bad parts or things like that, we can hybrid
one, one we like. We certainly have enough time to do that.
Chair
Commissioner Leichtfuss
Leichtfuss I would like to comment. I think that a list, as
mentioned, would be excellent because I have felt
a small amount of frustration with every meeting writing down
some crucial things but not having a vehicle to get back to them.
So, I would really like to entertain the idea of doing something
like that. As far as we were just talking about with the alter-
natives, I agree with both of the Commissioners. Commissioner
Wright, I was looking on page B-4 and noting the number of
dwelling units and it does seem that there is a big gap and as
far as lower alternatives, there appear to be three versus the
other five rather grader alternatives. I agree with the Chula
Vista Commissioner that we can hybridize these. I don't know if
we have to come up with any more but I think it is important to
note, during this public meeting, that these are not our only
alternatives. Thank you.
Chair
Commissioner Kastelic
Kastelic I was just going to comment on what Commissioner
Leichtfuss was saying. If we hybridize one of the
alternatives, I believe that it would require further environmen-
tal analysis of that hybridized option. Is that correct?
Lettieri
To the Chair. Depending on the hybrid, we would
have to go back and make a recommendation as to
not it would require a supplemental EIR and bring it
Commission.
whether or
back to the
Kastel ic
I just wanted to make that clear. Thank you.
Chair
Commissioner Ferraro
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Public Hearing~10rkshop - September 16, 1992
21
Chair
Commissioner Ferraro
Ferraro Mr. Chairman, along the lines of alternatives. I
feel a little put upon making so many decisions on
probably one of the largest projects in the State of California
in such a short period of time. Would it be feasible to just,
say, (a generic question) would it be feasible to have a workshop
session where rather than being programmed as we are with the
staff presentation, we can just talk about alternatives? As we
have had special sessions for field trips? I'll just lay it out,
you don't have to respond to me now. The thing is - I would like
to spend more time discussing alternatives rather than the short
period of time that we are being allocated.
Next, I would like to see the young zoologist's comQents, Mr.
Richard Fisher's comments, be addressed when we have another
m~eting regarding the EIR regarding his comments about what was
left out.
And, lastly, I would like to see some additional information
regarding schools. I don't know a lot about State law but I do
understand that planning agencies can take into account the
adequacy of schools in considering projects. Therefore, I would
like to know how this area is going to served by schools? 11hen
the schools are going to be built? Which jurisdiction is going
to build those schools? what capacity they have, etc., etc.?
Thank you.
Chair
Commissioner Leichtfuss
Leichtfuss Mr. Chairman, one last question. Would it be more
advantageous for the Commissioners to ask for,
perhaps, another alternative during the Draft EIR process or to
wait and discuss that further down the road. My only...I just
have a problem that in the past with the County sometimes it just
gets lost in the enormous amount of public testimony and then the
time constraints, the pressure becomes so great that it just gets
rushed along and we don't often get the opportunity to get
another alternative. I just would like your input on that.
Chair If I can respond to that. I suppose that we can
ask staff to provide whatever data or information
we ask them and if part of that request is for alternative "x" or
"y" or whatever in some fashion or form, I guess they will
provide it to us. They've got the building blocks and I think
they can put it together. Commissioner Martin.
Martin
Mr. Chairman. We might want to think about,
before we get another alternative and another and
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EXTRACT - Joint County/Chula Vista Planning Commission
Public Hearing/Workshop - September 16, 1992
22
another, there are 14 issues in the EIR. Maybe I'm supporting
what Commissioner Carson said but if we could find out what do we
want in the biological part, what we want in the water, what we
want in this, then from that, the genesis of that document in the
EIR, then from that they could come up with a plan that would
seem to be acceptable. Not to degrade any of the work already
done because all of that is going to be the very basis informa-
tion and it seems to be all there. If this information is
accurate that we've gotten in the EIR. If that is another
question, then the only way it can really come out is if we study
each one of the segmentally, I would think.
Chair
Commissioner Wright
Wright I think that's a good approach. It is clear that
somehow we have to evolve. If we're unhappy with
all of the alternatives, that will, I suppose, evolve out of our
discussions and out of that will evolve some kind of an alterna-
tive, possibly. The question is at what point should that
happen? I get the sense that it might be better for that to
happen after a lot more discussion as we get more deeply into the
project. I don't think we are in a very good position to do that
at this point and I'm not so sure, Commissioner Ferraro, and I
don't disagree with you on a need for a workshop where we sit
around a table and say what we think is good and what we think is
bad, but I'm not so sure that we can just do that in one workshop
fairly on. Maybe that is something that has to happen down the
line. I don't know. It's overwhelming.
Chair Well, we can do what we want. We can schedule a
workshop if we feel we need it. One of my
responses to Commissioner Ferraro's plan and comments is that as
to those specific items that we don't understand as well as
others, we have access to all the technical papers. We have
access to all the data that has been developed and we can make
ourselves available of all of that. I haven't been to their
office but I'm going to be there because there are a number of
things I am very concerned about. I'm really concerned about
that traffic thing. I'm concerned about the impact that develop-
ment south of the Border is going to have on this thing. I am
concerned about the number of river crossings, I don't think
that's been addressed to my satisfaction. I am really concerned
about the wildlife corridors, what impact...one of them is 500
yards wide would make versus one that is 300 yards and so on? I
guess we'll be having a very difficult set of variables and we
may not know what impact changing one variable has on another.
We have discussed this a little bit, one of the Commissioners and
I, and maybe there is no easy way to do that. I think we will
just, sort of, have to stumble through it and ~lork it out. In
time, I think we will put something together that we all feel
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EXTRACT - Joint County/Chula Vista Planning Commission
Public HearingAvorkshop - September 16, 1992
23
will be the preferred position or the preferred alternative. As
to timing, I sure wouldn't want to venture a guess when that will
take place because we all work at different levels and different
speeds, absorb at different levels and, I think, we're in for
some interesting discussions.
Chair
Mr. Tuchscher
Tuchscher Mr. Chairman. It is my understanding that the
important thing in analyzing this EIR is that it
covers the full range that we have discussed, the No-Project
Alternative and the New Town Plan and that all the elements are
addressed accurately within that range. But it is not, it is my
understanding and perhaps staff can comment on this, it is not up
to us to come up with that hybrid we discussed for approval prior
to acceptance of the EIR, if we can get to that stage. That
after acceptance, then we will have the general plan process -
a2l the processes that were discussed here - those approval
processes to get down to the specific land use issues and come up
with that hybrid. That would then follow, or the focus EIR would
then follow with that. lve have a project here in Chula Vista,
the Mid-Bayfront Project which has done just that. It is not as
if there was no precedent for that.
Chair
Any additional comments from staff? Commissioner
Kastelic.
Kastelic During testimony several people brought up several
concerns and other people had questions or
comments that required, in my mind, an answer from staff. My
question is, will the verbal testimony be answered in written
form or should these people write their questions down in order
to get a written answer?
Reid
Mr. Chairman. There will be a transcript of all
the public hearings and the Final EIR with appro-
priate responses to the questions and issues
raised.
Chair
Commissioner Tuchscher
Tuchscher Mr. Chair, could I make a couple more comments,
just real briefly. I agree with Commissioner
Carson's comments relative to organization and also relative to
the visuals. I have found myself flipping back and forth between
maps. I have calluses because I have been flipping back and
forth between maps so many times. I would love to see overlays.
Visually, it would be easier for me to understand and I think
there are many members of the public that would appreciate that
as well.
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EXTRACT - Joint CountyjChula Vista Planning Commission
Public HearingjWorkshop - September 16, 1992
24
Relative to the NO-Project Alternative, if that is looked at as
Mr. Decker suggested in greater detail, I think there certainly
are positives and certainly are negatives to that No-Project
Alternative that should be investigated; such as, circulation and
Interstate 125 and these types of elements. I agree with Mr.
Decker on that issue as well. Thank you.
Chair
If there are no more questions of staff, then we
will continue this public hearing to the meeting
of October 7, 1992 at 5:00 p.m. here in this
building.
/~
26 September 1992
,~"--':::----'
iW1cte ~ ~~/~!
:;\! OGT-2 " flUIl,i!
',';' - II f.
~ U! ' Jl0j
Anthony J. Lettieri, Otay Project Planning Office
Mayor Tim Nader, City of Chula Vista
Clerk of the Chula Vista Planning Commission (Please distribute to all members)
George Bailey, Chairman, San Diego County Board of Superviaora
Clerk of the San Diego County Planning Commission (Please distribute to members)
RE: Otay Ranch Project Environmental Impact Report Prepared by Ogden
Gentlepersons:
As I have conducted excavations at the Otay ranch for ten years with my students from
Southwesteern College, I have been asked by several interested parties to comment
on the environmental report prepared by Ogden.
I feel qualified to comment esentially on the specific site which we were in the process
of excavating although I have walked along the river valley and know that there are
many sites in the area.
The sne we excavated as a project for archaeology for Southwestern College is
referred to in Ogden's report as SDI 11,369 (also as SOi 11 ,376/W2391 and also by
th(l R(l<;.gn numb(l!"$ of OR-70 and OR-79 and by CSUSO F:5:1).
W@ 1@r;J qyjtf; cm1~n that thi:\l :\litiil i:\l thiil Old Village Site of Olay, a large habitation site
which wa:5 abandoned about the time of Spanish contact. It is an extremely important
site since the quantity of artifacts numbers in the tens of thousands. We found hearths,
lithic scatters, huge quantities of all types of prehistoric stone, bone and shell tools and
ornaments including a steatite fetish. We also found a sweathouse,and were unable to
determine the size of it because of Baldwin's refusal to allow us onto the site after they
bought the property.
The proper continued excavation of this sne is critical to our understanding of the
prehistoric cultural history of this area. We excavated le88 th~' 10% of the sne.
In the Impact Report the site is referred to as being planned for open space:Table
4.2.5.1., Table 4.3..5.1.,Table 4.4.5.1., Table 4.5.5.1.,Table 4.6.5.1., Table 4.7.5.1., but,
in Table 4.9.5.1. F/OS meaning Freeway/Open Space. I am appalled that there is even
a hint that the site might be destroyed to put in a freeway.
In Table 3.4-1:Previous Cultural Resource Studies That Have Resulted in the
Recordation of Snes, my Preliminary Report of 1977 on the excavation is not
mentioned, although it was referred to several times in the repcrt..
Since I am not sure exactly what is meant by Open Space, my comments would be
that I would hope that the sne would be thoroughly investigated. the excavation of the
sweathouse continued to determine the size of the feature and the extent of the site
itself be determined if it is not possible to set it aside from development.
There is some talk of the establishment of a park somewhere on the Otay River in the
area of the site. I think this would be a very ROod idea. It could also have as a part of
the display the site itself. Southwestern College, where the artifacts which were taken
from the site, are at the present time stored,2 would be willing to talk about the transfer
of the thousands (really tens of thousands) of artifacts to a permanent site such as a
museum wtlh lhe proper funds for and security for the curation of the collection. The
collection is well maintained, well documented , and well preserved. I would like to
know that it was in a permanent home when I retire which I plan to do within the next
few years.
Please consider carefully, before you allow the destruction of this most important site,
without doubt it is the most important site so far excavated this far south and west in
San Diego County.
Charlotte McGowan, Professor ~ ,A' 9", 1f, ~. -" ,.
Anthropology/Archaeology ~1.JI.....,~<'v'--'
Southwestern College
Chula Vista, CA 91910
I
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THE CITY OF
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SAN DIEGO
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erIT OPERATIONS BUIWING . 1222 FIRST AVENUE
(619) 236-5551
sXff7J7EGO, CA 921Ul-'fI55
ENGINEERING
and
DEVELOPMENT
DEPARTMENT
September 30, 1992
File No.: 430.8 (Otay Ranch)
Douglas D. Reid, Environmental Review Coordinator
otay Ranch Project Planning Office
315 Fourth Avenue, suite A
Chula vista, CA 91910
Re: otay Ranch
Dear Mr. Reid:
Thank you for the opportunity to comment on the Otay Ranch EIR.
Our staff has been working with your transportation technical
committee for the last two years. These comments were forwarded
verbally to Steve Thomas who serves as Chula vista's representative
on the transportation technical committee.
We have reviewed the draft Program Environmental Impact Report for
the proposed Otay Ranch development dated July 1992, and have the
following comments:
The proposed development of Otay Ranch, the New Town Plan, under
the Phase I - Progress Plan alternative land use would generate
approximately 736,883 daily trips. The proposed large development
would have a significant unmitigated traffic impact on regional
facilities such as I-805, SR-905, SR-54, Bonita Road, otay Valley
Road, Sweetwater Road and future SR-125. Futlure access to and from
South Bay would be at an unacceptable level of service "F", which
is a breakdown flow in traffic conditions and is not acceptable.
An alternative land use plan should be evaluated with a lower
density to try to reduce the traffic impacts of this proposed
project.
This proposed project appears to be in conflict with the congestion
Management Program. If the proposed project is approved causing a
breakdown on regional facilities, then it would seem meaningless to
try to evaluate other smaller projects in the area under the
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congestion management guidelines, with the goal of mitigating
traffic impacts so regional roadway fa~ilities in the area would
operate at acceptable levels of service.
Additionally, there currently are discussions in progress relative
to a proposal to place a regional airport in the otay Mesa area.
If this proposed project .were to go forward, it would severely
restrict access to such a facility.
sincerely,
Division
LMQ:hk\gdb
b:4308.lmq
Attachment: Location Map
cc: Hal Rosenberg, city of Chula vista
Robert E. Asher, County of San Diego
steve Denny, county of San Diego
Jeff Strohminger, MS 507
Tom story, MS 5A
Gail Goldberg, MS 660
Larry Van Wey
Dave Sorenson
Linda Marabian
Dave Di pierro
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Regional Location of Project Site
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2885 Echo Valley Road
Jamul, CA 91935
October 2, 1992
Mr. George Bailey
Supervisor, Second District
County Board of Supervisors
1600 Pacific Highway
San Diego, CA 92101
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Dear Mr. Bailey,
I live in the Procter Valley section of Jarnul. My house is within a quarter-mile of the
proposed Otay Ranch project. Any build-out on the Eastern portion of Procter Valley Road
by Baldwin could have a serious impact on our community character. Therefore, I feel my
needs should be protected by your office.
It disturbs me that Lead Agency Status has been given to the Chula Vista City Council.
They are on record as stating that their community will be most impacted. I disagree. They
are also on record as responding to Chula Vista residents preferentially, and that is unfair.
From my vantage point, I have been abandoned by your office.
First of all, there is an effort to shift the area of jurisdiction of the Jamul Planning Group
further South, leaving Jamul residents in Procter Valley surrounded by development
unsympathetic to our needs. Second, I was informed by a Baldwin employee that they
intend to bring sewers as far East as possible, which will encourage higher density
development. The next Regional Plan could clearly make Jamul as farless desireable place
to live.
I feel the City Council of Chula Vista is not interested in preserving my community.
Neither is Baldwin. I believe it is time you stood up for your constituents.
Thank you for your time.
sm'~~
~y A. Haron
c.c: T. Nader
B. Bilbray
D. Reed
D. Jacob
J. Doyle
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H'l/12I6/92
09:1213
RECON
NO. 430
1]1211
00
THE CALIFORNIA NATIVE PLANT SOCIETY
San Diego Chapter, P.O. Box 1390, San Diego, California 92112
October 6, 1992
F.x II.
on
Mr. Douglas D. Reid
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
Subject: Draft Pro[;-ram Environmental Impact Report for Otay R~lnch (City of Chult!
Vista EIR 90-01; County of San Diego Log Number 89-14-98; State Clearing
House Number 899 I 9154)
Dear Mr. Reid:
As part of the public review required uncler the California Environmental Quality Act
(CEQA), the San DIego Chapter of the California Native Plant Society (CNPS) hus
reviewed the draft program environmental impact report for Otay Ranch (DEIR)
prepared by Ogden for the City of Chula Vista and County of San Diego. It should be
noted that, clue to the brevity of the public review period, this review is general in nature,
focusing primarily on bot!lnical issues. Comments will commence with general issues,
followed by page, figure, andlor table-specific comments.
A. General Comrnems
1. Neither the proposed project, nor any of its alternatives (with exception of the
environmental alternative), meets the standards set forth in rhe draft Resources
Management Plan (RMP) or the COunty of San Diego's Resource Protection
Ordinance (RPO). Impacts to Diegun coastal sage scrub, maritime succulem
scrub, valley needle gras, grassland, riparian wpodlallds, southern interior
cypress forest, oak woodlands, and vemal pools 'are substamially greater than
would be allowed for smaller developments in the County of San Diego, even
without the application of RPO. It is difficult to determine the actual degree of
nonconfoffimnce to the RMP standards for the Phase II Progress Plan, Fourth,
Project Team, Existing General Plans, amI Low Density alternatives as no il1-
depth analyses were conducted. It is unclear how a draft RMP is to bc used as
a guide for the implementation of mitigation when "portions could be
changed". From our understanding, the RMP is 011 a different timeline for
approval than is the DEIR; CNPS hopes that the fInal R.c'v1P does not reflect
reduced standards to bring project impacts 111 to C0l1fOm1ance.
DEDICATED TO THE PRESERVATION OF CALIFORNIA NATIVE FLORA
/rf
10/06/92
0'3:04
RECON
NCl.430
Gl02
Mr. Douglas Reid
-2-
October 6, 1992
2. The classification system used for plant COmmunities is not consistent
throughout the DEIR document. There are inconsistencies from section to
section in the DEIR, as well as between the DEIR and its biological technical
appendices. The text should include a discussion of the criteria used to classify
plant communities. In various tables, figmes, and sections of text there are
references to Diegan coastal sage scrub, coastal sage scrub/non-native
grassland, non-native grassland/coastal sage scrub, mixed chaparral/coastal
sage sCl1lb, coastal sage scrub/mixed chaparral, and disturbed Diegan coastal
sage scmb. All of these are not c1assificaiion units used by the California
Natural Diversity Data Base (Holland 1986), although text states on page 3.3-4
that all nomenclature for plant conununities confonns to Holland (1986).
Holland (1986) is a hierarchical system which allows for refinements to include
new classifications, however, the crite'ria used in thtl development of these units
should be provided.
3. As an example of how important the consistent classification of plant
communities is for impact analysis, Diegan coastal sage scrub is used as an
example. It would be helpful to know how disturbed Diegan coastal sage scrub
was differentiated from undisturbed Diegan coastal sage scrub. Given that this
is not provided, it is included with other types of coastal sage scrub.
Tn this calculation of New Town Plan impacts (reference Table 3.3-5) to
Diegan coaseal sage scrub, the following categories are combined: Diegan
coastal sage scrub (5,270.2 acres), coastal sage scrub/non-native grassland
(309.5 acres), coastal sage scrub/mixed chaparral (5.8 acres), and disturbed
coastal sage scrub (658.6 acres). This total acreage of impact equals 6,244.1
acres, or 56 percent, of the 11,146.1 acres found on Otay Ranch. Tn
comp~.rison with totals in Table 3.3-6, no combination of the category acreages
in Table 3.3-5 yields the total acreage for Diegal'l coastal sage scrub (5,585
,
acres) indicated on Table 3.3-6. Combining Diegan coastal sage scrub (5,585
acres) and dismrbed Diegan coastal sage scrub (781 acres) should be done to
calculate impact acreages. Coincidentally, this combination results in 56
percent impact as well.
4. The analyses provided in the DEIR do not adequately address habitat impacts
in a regiol1al perspective. Again, using Diegan coastal sage scrub as an
example, the loss of 6,244 acres of coastal sage scrub constitutes approximately
live percent of the coastal sage scrub (54,565 hectares) occurring in San Diego
Couney and two percent of what exists in the United States (288,388 hectares)
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1<l/06/S2
09:04
RECON
~IO. 430
[;103
Mr. Douglas D. Reid
-3-
OctoberS, i992
(Salata, unpublished data 1992). Not factored into this 56 (or 54) percent loss
is the fact that much of the coastal sage scrub on Otay Ranch exists in large,
contiguous tracts and provides an important link with coastal California
gnatcatcher habitat in Mexico. To merely state that, yes, this impact is
significant does not disclose to the public the biogeographical magnitude of this
impact.
Similarly, stating that implementation of the New Town Plan would result in
the loss of 72 percent of the vernal pools (or habitat?) found on Otay Ranch
does not provide the public with the whole picture. It is estimated that only
four percent of San Diego County's original vernal pool acreage remains
(Oberbauer and Vanderwier 1991), much of it in a disturbed condition. When
resources have already been diminished by over 96 percent, losses of this
magnitude are not accept~.ble. Similar problems exist for maritime succulent
scrub.
5. CNPS has concerns with the level of impacts to habitat proposed to be
mitigated through the implementation of restoration programs. For example,
coastal sage scrub/non-native grassland matrices generally function as coastal
sage scrub in ten115 of how it is used by wildlife, including coastal California
gnatcatchers. Without definitions of these plam community designations, it is
hard to concur that active management of coastal sage scrub/non-native
grassland, non-native grassland/coastal sage scnlb, and disturbed coastal sage
scrub is necessary or should be credited as mitigation. What percentage ratio of
coastal sage scrub to non-native grassland changes the designation from Diegan
coastal sage scrub to coastal sage scrub/non.native grdssland? From coastal
sage scrub to non. native grassland/coastal sage scrub? Most of the coastal sage
scnlb on Otay R,mch has been disturbed by grazing activity; removal of
livestock would likely allow these disturbed areas to restore themselves.
Similarly, CNPS questions the percent preservatiojl' vs: restoration provided for
in the RMP, For example, preserving 80 percent of the valley needle grass
grassland is an adequate standulu, however, the fact that only 25 percent of this
is in situ, the remll.inder liS" restorll.!ion, is not.
6, It is generally unclear how the percentages for the standards in the RMP were
established for habitats and sensitive plant taxa. For plants, it does not seem
that the acceptable loss percentages were calculated taking into account the
regional disu'ibution of taxa. For examplt:, a 7() percent preservation in sim for
Hemizonia conjugens (vs. 95 percent for Acamlwminrha ilicifolic.) is based
upon the fact that it the Hemizonia is abundant where it is found. This may be
110
10/06/92
09:05
REeD"1
NO. 430
Gl04
Mr. Douglas D. Reid
-4-
October 5, 1992
trUe some years (like 1991 and 1992) but it does not consider the fact that its
U.S. distribution is restricted to a small geographic area (the Sweetwater/Otay
region of San Diego County). Salvia mUldl is similarly distributed, although
abundant where it occur. Acanthomil'llhCl ilicifolia has a much wider
distribution (albeit only in San Diego County), although it is never as abundant
as Hemlzonla conjugens in good rainfall year.
7. The degree to which salvage, transplant, propagation, restoration, and
reintroduction programs are proposed for use as mitigation also concerns us.
Of the types of mitigation provided for in CEQA, CNPS supports those which
avoid net reduction of population size or species viability. For many taxa.
these pollcies require the protection of essential plant habitat in situ. In othcr
instances. policies require that impacts be fully avoided in order to prevent a
significant impact. Alte.rnatives such as rescoraticll and off-site introduction are
generally unproven and often unsuccessful. As such, these methods should
only be used after alternatives which avoid or minimize impacts to the resource
have been fully explored. Restoration and reintroduction programs. despite:
what is stated in this and other environmental documents, are rarely successful.
Fiedler (1991) in a study of mitigation-related transplantation, re-location, and
reintroduction projects involving state-listed plant taxa found that only eight of
53 such attempts were fully successful. Only seven others were considered to
be of limited success. CNPS recognizes th,u numerous biological consultants
promote and conduct such programs as parr of CEQA-based mitigation,
however. the success of their work has not been reliably demonstrated to the
Endangered Plant Program. California Department of Fish and Game (CDFG),
or CNPS. This lack of success has lead the EndaIlgered Plant Program to view
such "mitigation" with extreme caution.
Salvage, transplantation. restoration, and reintroduction programs are often
proposed prematurely, before due diligence tQwards avoidance and/or
minimization of impacts has been demonstrated. 'For example, preservation of
vernal pools must be fully explored and receive first priority. The discord
which exists between those biologists who feel that such programs are adequate
compensation and those who do not continues to allow decision-makers to
believe that the need for protection of habitat and species ill situ is less urgent.
Such is not the case; salvage, transplantation, and reintroduction activities do
not recreate habitat. TllOse inexperienced with the complexities of naturd!
communities seem to feel that, with a bit of thought and considerable expense.
anything is possible and that rare plant taxa and/or entire habitats can be
successfully re-established. This idea tries to soften the loss of natural areas
~'t
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Hl/06/92
09:06
RECON
'10. 430
[;05
Mr. Douglas D. Reid
-5-
October 5, 1992
through the illusion that taxa have been "rescued", enforcing the idea that
habitats are no more than the sum of their dominant biologic components with
l\ few sensitive taxa thrown in for good measure. There is an enormous
difference between intact habitat and a collection of native plants deliberately
placed in open space. Similarly, merely bulking up seed in a greenhouse does
not ensure its suitability for use in re-establishing natural populations.
The wholesale application of these methods in the fu\1P does not appear to
reflect the degree of caution which should be used in the advocation of such
activities as mitigation. CNPS would like to see data on the use of salvage,
transplantation, and reintroduction of plant taxa and restoration of habitats
which are targeted for such activities in the RMP prior to our endorsement of
these methods as a major component of any mitigation program for botanical
resources. In lieu of this, we concur with the Endangered Plant Program,
CDFG that these programs be successfully completed prior to the loss of the
target taxa and/or habitats,
As a final note on this subject, however, we woul~ add that salvage,
transplantation, and propagation programs are not always inappropriate, having
value as impact-reducing measures. Plant materials which would be lost as part
of impacts which have been detennined to be not significant, or use of over-
riding findings by a lead agency, could provide the basis for studies to
demonstrate the appropriateness of such mitigation methods. Any such studies
should include long-term monitoring programs with established criteria upon
which to detennine their success. The duration of monitoring periods should
consider the life fonn of the plant. For example, a five-year monitoring
program may be appropriate for an annual taxon like Acanthomintha ilicifolia
or Hemizonia conjugens; it is not appropriate for tree species such as QuerCI~Y
engelmarwii.
./
8. The resource management plan needs to address nLxa which will likely be listed
by the federal and state governments in the next five years. While this is often
difficult, with a program that will set in place land use plans to be implemented
over the next 50 years, it does not seem unreasonable. This is one way to try
and avoid the confliCtS which will most certainly arise when environmental
review of future specific plans or tentative maps occur in the future.
9. CNPS is aware that additional surveys were conducted by Baldwin's
consultams in spring 1992 as part of the Resources Agency's Natural
Cormm1l1ities Conservation Program. Where are these data? Fieldwork
/ V3-
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10/06/92
09:07
RECON
"10. 430
[;106
Mr. Douglas D. Reid
-6.
October 5, 1992
conducted this year by biologists working on other projects in this area has
identified dramatic increases in certain resources, twO examples being coastal
California gnatcatchers and Hemlzonia conjugens. Similar trends are expected
on Otay Ranch as well. It is difficult to provide concurrence with any preserve
design knowing that significant data may be missing. Given that theDElR was
release.d for public review in August, we feel that these data could have be.e.n
Included.
10. CNPS sees two options for preserve design: a large, minimally-managed
preserve or a smaller, highly-nianaged preservees). These options are alluded
to in Table 4.1-2 which provides for the RMP as pan of the proposed proje~t
(New Town Plan), Phase r Progress Plan, Phase II Progress Plan, Founh. and
Project Team altt.mauves, but noc for the E.~isting General Plans, Low Density,
and Environmental alternatives. It is our opinion that the a large preserve coLlld
be designed which would adequately address our concerns regarding impacts to
resources associated with the development of Otay Ranch, however, this would
mandate substantial project redesign unless ihe Environmental alternative was
selected. The preserve which would be necessary as part of the New Town
Plan will require intensive management, and the preparation of an adequate
document to implement this management would require the collection of
additional autecological and syne.cological data for a number of taxa, most
notably small mammals and herpetofauna.
B. ~cific Comm~
These specific comments deal primarily with the DEIR; the short time allowed for
public review pr~cll1ded CNPS from providing an adequate review of all of the
technical appendices.
I
I. Page 1.17: Text in section 1.2.2 states that the 1ev,e1 or detail in the is DEIR is
focused on impacts that can be expected to occur 'from adoption of two general
plan amendments and a general development plan/subregional plan, and leaves
the more detailed analyses to be completed in conjunction with project-specific
environmental review conducted for subsequent discretionary permits. This
program document, however, sets into motion land uses which may be, in
actuality, quite difficult to substantially modify in the future, even with new
information. This new lnfoffilation is expected to be important; Table 1.1- 1
shows that virrually all biological impacts arc significant and not mitigated at
the level of analysis contained in this document. In om experience, new
biological information does not usually have the clout to change land-uses once
/.-
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10/06/92
09:08
RECO~I
r.IO.430
Gl07
Mr. Douglas D. Reid
-7-
October 6, 1992
geneml and specific plans have been adopted. We suggest that this DEIR take
its best shot now by providing llll of the infomlation available for the project
area for use in crafting a project design that will protect biological resources on
a region scale.
2. Figure 2.3-1: This figure indicates that State Route 125 will be located in
Johnson Canyon. Caltrans has not yet established the route for this highway
south of the Otay River or north of the community of Eastlake. Figure 2.3-4
also shows the alignment for SR-125 as if it were already established; text on
page 3.3-106 indicates this as well.
3. Page 3.3-6: The discussion of clay lenses in (he Grasslands/Meadows se~tion
should include information as to why these soil conditions are important for
consideration. Clay lenses can be pres<lnt in a larger area of a different soil
series and provide habitat for a number of sensitive plant taxa, including the
state-listed Acanthominrf.a ilicifolia and Hemizonia conjugens, federal
candidates Muil/a clevelandii. Brodiaea orcuttii and Dudleya variegata. ~nd
CNPS listed species such as Adolphia californica and Harpagonella palmeri.
No discussion of clay lenses appears to occur in subsequent sections of this
document.
4. Figures 3.3-1(a,b,c): To assist in review, it would be helpful to have the same
screens used for each habitat type,
5. Figure 3.3-7: It is unclear why Johnson Canyon is omitted from any type of
wildlife corridor designation. It appears to contain resources commensurate
with those found elsewhere and, although it does not provide as great a
connection to other areas as does O'Neal or other canyons, it contains greater
wildlife habitat thcln currently exists in Poggi or Wolf Canyons. Given the
I
general perception that Johnson Canyon is a wildlife corridor, it seems the text
should provide infonnation on this canyon, hen if to JUS! dispel this
perception. Also, nowhere in the appendices is the infomlacion provided co
support these regional corridors. How were these detemlinations made?
6. Table 3.3-5: This table summarizes impacts to vegetations associated with the
implementation of the proposed project (New Town Plan), however. these
figures do not appear to be consistent ....ith those Oil Table 3.3-6.
It is unclear why there was no SUllllllary table for plant impacts similar to
Tables 3.3-5 (plant community) and 3.3-8 (wildlife). To provide for this
f9V
10/06/92
09:08
RECON
NO. 430
[;108
Mr. Douglas D, Reid
.8.
October 6, 1992
information only in Table A.7 of Appendix A is not acceptable. The
appendices were not as widely distributed llS the DETR and without this
information it is hard to concur with the com;lusions in the DErR.
7, Page 3,3-79: Text in section 3.3.2.3 states that the impact to each plant species
is analyzed using the n\lmber and relative sizes of populations or mujor
aggregations of sensitive plants, however, no plant species information is
provided except in Table A-7 of Appendix A. This table is organized quite
differently than those created for habitats and wildlife, using parcels and
summary point location percentages only. There is very Iiltle information on
population sizes, aggregations, etc, The use of poim locations seems to be how
significance wus detem1ined, however, its applicution here is questionable.
Point data do not necessarily provide an indication of density within each
occunence, indeed, the text states that the number of points may not reflect the
population size or individuals but. in some cases, may be correlated with the
level of survey effon in different areas. It is difficult to accept that this
information is adequate to determine significance or to develop adequate
mitigation.
8. Table 3.3-10: This table basically states that the proposed project (New
Town Plan) requires redesign to retain resources at levels necessary to meet the
standards set in the resource management plan. Virtually all impacts to
biological resources are significant and not mitigable (mitigated?). A redesign
mnst occur now when a comprehensive approach to impact analysis and
mitigation can be taken: it will nOt occur in a piecemeal fashion later during the
environmental review for implementing specific plans and tentative maps.
CNPS again expresses our disagreement with the inadequate public review period
provided for the review of this extremely complex document and its attendant appendices
(see letters dated July 22 and September 14, 1992). Sixty. days is not enongh time to
provide the City of Chllla Vista and County of San Diego' \vidl the kind and quality of
review that was requested in the July 31,1992, letter which requested reviews address the
accuracy and/or sufficiency of the DEIR in three areas: substantial adverse impacts upon
the environment: ways in which adverse impacts might be effectively minimized or
avoided; and feasible aiternati ves to the proposed project. The Otay Ranch project is
unique in both its size and complexity and to provide the type of review which would be
helpful to your jurisdiction and the County of San Diego requires a substantial amount of
J
..._._~._,_.h-__.._ .
10/06/92
09:09
RECO~I
NO. 430
[;l89
Mr. Douglas D. Reid
.9-
October 5, 1992
time and coordination. In the case of such a reviewer-unfriendly document, providing a
competent, constructive review constitutes a tremendous task even for those of us who
are not novices at this type of thing. CNPS was unfortunately unable to accomplish this
in the time allotted.
Much of the CNPS's review of botanical issues associated with any environmental
docurnetH centers around information contained within the appendices. In this case, the
appendices were essential as they often provided the only summaries of plant impacts,
etc, We were not sem pertinent biological appendices along with the DEIR, although it is
our understanding that others (San Diego Biodiversity Project, for example) did.
Arrangements were made with Joe Monico, Olay Ranch Project Planning Office, on
August 10 to have the missing appendices sent to us, however, project oflice clerical Stan'
could nO[ figure ont how to get the appendices to us while Mr. Monico was on vacation.
As a result, CNPS review period fOf biological technical appendices was, in reulity, only
30 days.
It is rumored that the Chula Vista City Council may choose to extend the public review
period upon taking back their authority to do so on October 6 is useless to us in terms of
providing us the opponunity to hold off on our comment preparation. We must assume
that the close of public review is October 7; we cannot risk missing the deadline for
submittal of comments should things not go as e;<pected during the October 6 council
hearing.
In conclusion, CNPS requests thut the City of Chula Vista not certify this DEIR in its
current form. We feel that there nre enough questions about the adequacy of the
document and the RMP, lack of detailed analyses for alternatives, and the full disclosure
of information to justify our position. In any case, we ask for the opponunity to review
the final environmental impact report prior to its consideration for certification to ensure
that our comments are adequately addressed. When this document is available, please
I
contact me at 270-9573.
~~;/
Bertha McKinley ~
Vice-President
/9&
10/06/92
09: 10
REcm~
~IO. 438
[;110
Mr. Douglas D. Reid
-10-
October 5, 1992
References
Fiedler, P.L.
1991
Mitigation-Related Transplantation, Relocation and Reintroduction
Projects Involving Endangered and Threatened, and Rare Plant Species in
California. Endangered Plant Program, California Department of Pish and
Game, Contrllct FG-861 1. Final Report, June 14.
Holland, R.F.
1986
Preliminary Descriptions of the Terrestriai Natural Communities of
California. Unpublished report, California Natural Diversity Data Base,
California Department of Fish and Game, Octcber.
Oberbauer, T.A. and J.M. Vanderwier
1991 The Vegetation and Geologic Substrate Association and Its Effect on
Development in San Diego County. In: Abbott, P.L. and W.J. Elliott, eds.
Environmental PerHs, San Diego Region. San Diego Association of
Geologists, October 20.
Salata, L.
1992
Wildlife Biologist, U.S. Fish and Wildlife Service, Southern California
Field Office, Carlsbad. Unpublished data: California gnatcatcher
population estimates.
cc: Norma Sullivan, South County Environmental Working Gronp
James C. Dice, Region 5 Plant Ecologist, California Departmeni of Fish and Game,
San Diego
Ken S. Berg, Endangered Plant Program, California Department of Fish and Game,
Sacramento -'.
Mark Skinner, Botanist, Caiifornia Native Plant Socier},' Sacramento
,
/- /
/ I
_ ,,_______~...._"_ _"~..."_n '__~_~~""L~,",~'~'" ~.. - -".
SENT BY:Xerox Telecopier 7021 :10- 5-92; 11:18
6196915540~CITY OF CHULA VISTA :# 2
Sweetwater Union High School District
ACMINISTRATION CENTER
1130 Filth Manu.
Chula Villa, California 91911.2898
(819) e91.~~00
Division 01 Planning and Facilities
October 4, 1992
Mr. Douglas Reid
Environmental Coordinator
City of Chulo Vista
276 Fourth Avenue
Chula Vista, CA 91910
Dear Mr. Reid:
Re: otay Ranch Draft Environmental Impact Report - D.E.I.R.
Thank you for the opportunity to review and respond to the Draft
Environmental Impact Report prepared for the Otay Ranch. You and the
other members of the Otay Ranch Project Team must be pleased to have
arrived at this juncture In the planning process.
As you are aware, the Baldwin Company and the Project Team have
kept the Sweetwater Union High School Dlstrlct apprised of the
development Of the various project alternatives. The Draft Environmental
Impact Report accurately states (Table 3.13-14) the Impact this project will
have on district facilities. Under the new town plan, approximately three
middle schools and four senior high schools will be required. The other
project alternative would require, at the very least, ;two middle schools
and two senior high schools, I I
To mitigate this Impact, I am requesting thot the CIty Council require that
the strategy Identified in the Long Range Master Plan for Educational
Facilities, Facility Implementation Plans, be implemented.
/f)r
SSNT~Y:Xerox TeleCopier 7021 :10- 5-92
11 : 18
6196915540~CITY OF CHULA VISTA ;~ 3
Mr. Douglas Reid
October 4,1992
Page Two
The strategy can be paraphrased as follows:
1) That the General Development Plan Identify the general
locatIons of schools.
2) That the specifIc school siting be resolved at the SPA Plan
level.
3) Thot the applicant be required to establish the funding
mechanism for provision of schools Identified for the entire
Otay Ranch at the beginning of the first SPA Plan approval.
At the time of the first SPA approval, It is only necessary thot the funding
mechanism (at this time a Mello-Roos Communtty FacilitIes District is being
considered) account for the needs identified with that particular SPA.
Additional SPA Plans will be annexed to this Mello-Roos Community
Facllities DistrIct.
If you hove any questions or comments regarding this Important issue,
please feel free to give me a call at 691-5553,
S;Z_~
Thomas Silva
Assistant Director of Planning
J
1S/ml
c: KIm Kilkenny, Boldwin Company
Kate Shurson, Chula VIsta Ctty Schools
,
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SENT BY.:Xerox Telecopier 7021 i10- 5-92 i 11:19 i
6196915540~CITY OF CHULA VISTA i# 4
,
M
The Baldwin Company
CIYI/t:manshlp III building :llIce 1956
March 19, 1992
TOI oist:rll::lution
:m:lM: ~ P. D:Jyle ft1J "
SOBJD::'1': MB!."l'Im CD' : : 199f-=- r:tI!AY. :R1lH::H ="lr\T, '!:'U'TT,,,,,,,",,~
Four agerrla items were n1 ~,..~: ~ '
................,..
'.... .-. ...
.., .. ........-..,. .
\
)
,..
- Master Plan status
- GDPI<equi.rements
- ~. Requirements
- :E'hasin:] ,
A brief description of each ni",...,'....ion !OllCMs:
1. -<rtar Plen status: Kathy Schwartz to PJ;PVide final ~ to Bal
by March 24th. Master plan will incl1.lde all UJ;dates/revisions utilized
School Fao1lities In'pl8lll!mtation Plan. Steve Doyle will provide copies
Master Plan to Project T-. by March 26th. Project TemII will distrillllte
=ver latter ~ fr:sr camnants ~ck in two weeks.
2. GOP llatft,i_io."'l 1he sitin; criteria shot.m in the Schools Facili as (
In'plementation Plan has bean reviewed 'r:Jy the Districts an::i is also shewn in p/-"'"
the Master Plan. 'II::iI1 silva raquasted tha;t the GDP show a ''b\Jhble dnwirq" or.jt.>
the senior and Junior High school locations. '!he District wants
near a four or six lane roadway. :!<ate ShUrson requested the GDP show
j,I.......t"'sed location fr:sr elEll!llmtary SC"hCY'l1.51. 'Ihe d1......'....ion that foll
=x::J.1.lder:1 that tha GDP 'WOllc:i list the village canters that WUld incl
elelll!lntluy schools- and tha text WClUld deeori.i:e the~ echooJ.' s setting within
Village CGrrt:er. J
3. lI'I",~i."., t"!"'Ib.-l'll.~ Tan Silva, Kate Shurson an:i steve Coyle con::un:ed
the School Districts ani Baldwin would errt:er into a birxiing b.9l:t=lleTlt
Ball;iwin to mitigate its impact to school facilit1QS1 prior to the f'
approval of the GDP/SRP. A dra.tt of the agJ::.........t outline hI:Is
circulated. Tom Silva has provided. preliminary ,. ''''''-,ILs. Kate Shurson
rwiewin:;1 the outline. Tom, l':ate an:! Stave will get together to n; ..,.."....
1b,j....";!ldellt :bef0X'8 the atto:rneys get involved in dr2l:ftin; the lan;uage.
4. Phas;~: steve D:ly1e ran thJ:a.1gh the phaain; pl.'"':j.LQIll utilized in
Growth Management Plan. Both Tom silva and Kata Shurson ~..=-l that
a8SIlllpt:ions shculd include no ~city availability to beqin with.
elementary schools shculd. ):Ie sized fr:sr 650 st::IJdQnts, j'-1l1icr high schools
ciIJ ]J
.___>0>0 .~_~_.__.._,~.,_~__,. ,. ~
SENT t}Y:Xerox Telecopier 7021 :10- 5-92 11:20
6196915540~CITY OF CHULA VISTA :# 5
,
'11
1500 studerrt:s ani high schools forrt5@ studer:tts.. 'Ihe.rQ was general
that school facilities should l:lQ a~le whsn apprcxilnateJ.y halt the
an project:Gd to be gCll'larated. Q.1estions wra :t':tIi<<ed re;arding the
school an:l. tha "first" half of a student ~tion, Le., hew would
handl6d? '!here was a question :t'" i "'""'l abcut the on;oin;J unification
an:! its affect on sc::hoo1. capaoity. Toll, Kate, an:i Ste'IIe agreed to
to;;ether an:1 review these items in = clataiJ.. Kate 5h=son said
District wo,Ud consider building achools f= ItXJre than 650 ~ (rra
to 850). 'nUs rray allow all village re5lidants to utilizG one 81
school.
Distr
BE: otay Panch Scbcol Facili
PagQ
'!he ~ errJed with a 0i"("l'....ian of shara:::l. library facilitiss an::i c:
care. Tom Silva said the EastIal<& High SChool has a 19,000 SF facility
is pl.O~ for joint usa. Tan said the dist:rict favors this approach.
said that the 8l.~ schools had CCll1CSnlS ab:::ut sharing library facili ,
but wo,Ud ccnsidar the idea. Kate eai.d the District did favor child care at
the schools an::i hacl just receiVed a state grant to expan:l their pl:O;;.r.dl...
Projo:::t TealII an:1 !3aldwin will =rt:inua to ~ with both Districts on
idGas.
If there are any = or ~es in thasQ notes, pl"'''''''' let lllQ
SID: csb
Distr:il:lution: 'rcny Lettieri
Joe Monaco
KatG Shurson
'!'em silva
Kathy Schwartz
.'
2/) !
SENT 8oY:Xerox Te I ecopier 7021 ; 1 0- 5-92 ; 11: 20
6196915540~CITY OF CHULA VISTA :# 6
,
Sweetwater Union High School District
ADMINISTRATION CENTER
1130 Filth A..nu.
Chula Vllta, CallfOrn'a 91911-2896
(610) 891.6800
Dlvlslon of PlannIng and Facilities
February 4, 1992
Mr, Stephen P. Doyle
Vice President
The Baldwin Company
119715 EI Camino Real, Suite 200
San DieiO. CA 92130
Dear Steve:
Be: Otay 1kmch School FtUlilitie.
Thank you for the opportunity to review the proposed outline of the furore 8i1'8emen
between the Baldwin Viste Associates and the Sweetwater Union Hiih School District. As
we discl1llsed on the phone, I've made a few revisions to reflect Mr Campbell's and my
recollection of our previoll8 discussions. Enclosed is a revised revision of the outline with
the added section. italicized for easy identiflcation.
As you can see, the recitals have remained the same, The only sii1rlficant chanre haa been
a clarification of the specific funding mechanism which is aceeptable to the district with a
caveat that it can be rsple.ced upon mutual coment and legislative authority, if necessary, I
have aleo reviewed the revised school facilities implementation plan, dated December 23,
1991, and find that it is acceptable.
Please review the revised outline and then give me a call 60 that we can diSCl1Ss the need, if
any, for further refinement.
~A
Assistant Director of Plan nine
,
I
TSlml
Enclo8ure
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SENT BY:Xerox Telecopier 7021 :10- 5-92 : 11:21
6196915540~CITY OF CHULA VISTA :# 7
,
OUTLINE DRAFT AGREEMENT
BETWEEN BVAAND SURSn
Revised February 4, 1992
'FlArntalR:
A) BVA is CLP/(deve}oper)
. B) Developer is owner of OR
C) Is within SUHSD (districts) boundaries
D) Developer seeking approvals
E) Community Plans - facilities at time of need
F) Developer has directed preparation of Master Plan and
Implementation Plan for school facilities. (Plans to be updated,)
G) Plans outline school facilities data for siting criteria, school
population size, land requirements and state criteria for costs.
COVAnAnt.ll:
"....,.
1) Developer agrees to mitigate it's impact to school facilities based on
the following:
a) The criteria developed in the plans as applied to the
land use plan approved by the city and county, and
b) Prior to the approval or the first SPAplp.n or precise plan,
developer will establish and impZemenfa Mello-Roos
Community Facilities District which ls fZexibZe enough
to allow for the annexations offuture SPA or precise
plans. If there is a change in legislation which provides
the school district and ckveZoper with an alternative
funding mechanism, upon the mutual COnB8nt of both
parties, the MelZo-Boos district may be replaced.
/ A")
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, '
. . .....-. \." ~.. ,.,~.. - -"-
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11 : 21
6196915540~CITY OF CHULA VISTA :# 8
-
Outline Draft Agreement
February 4, 1992
Page 2
2) Developer agrees to identify the general location of school sites
which are acceptable to the district in the approval O.R. land use
plan.
3) Developer agrees that this ai1'gement will become binding on all
property within the Otay Ranch and run with the land.
4) District hereby waives any and all objections to the processing or
approval ofland use entitlement for Otay Ranch which are
consistent with the approved General Development Plan. However,
district reseroes the right to consider the impact propo~d changes to
the General Development Plan may have on. schools and require
appropriate mitigation. measures.
5) District acknowledges that this agreement will serve as mitigation
for school facility impacts for the Otay Ranch environmental impact
report.
:J 01(
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WILSON ENGINEERING
,; ;
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DEXTER S. WILSON. P.E.
ANDREW M. OVEN. P.E.
MARK A BURBRINK. P.E.
,.\ ;
L,I
OGT-5
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October 1, 1992
Otay Ranch Project Plannin,g Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
Attention: Douglas Reid, Environmental Review Coordinator
Subject: DEIR Otay Ranch
The following comments are offered on the above referenced document,
specifically with regards to Section 3.13.1 Water Availability and Demand.
1.
Page 3.13-6, third paragraph of the above referenced section: One agency
currently provides water service to the project area, the Otay Water District.
The City of San Diego does not provide water service to project area. There
are two areas of the project (the San Ysidro parcel and the Resort site on the
Proctor Valley parcel) which are not currently within any water purveyor's
jurisdiction. These areas are controlled by the San Diego County
Groundwater Ordinance.
2.
t
Page 3.13-17, second paragraph, last sentence under the discussion of Otay
Water District. This comment was made by Mr. Mumford, yet it is out of
place and context where' it is shown. The sentence, "However, due to
existing drought conditions.." would be better understood if located on page
3.13-6 under the existing conditions discussion (at the end of the second
paragraph). While it is true that the Otay Water District is subject to water
availability restrictions placed on it by MWD, generally, those restrictions
are uniform in application and are effective on the entire MWD service area,
"4;1
-I,
703 PALOMAR AIRPORT ROAD. SUITE 300 . CARLS8AD, CA 92009
(619) 438-4422
FAX (619) 438-0173
Douglas Reid
October 1, 1992
Page 2
not just the OWD. Permit restrictions currently in effect in OWD will be
lifted when the new CWA pipeline 4EII is completed (currently under
construction) .
3. Page 3.13-8, second paragraph, revise the first sentence to read: "The City
of San Diego Water Utilities Department provides water service to the
majority of the City of San Diego, Imperial Beach, Coronado and parts of.
the County of San Diego. Although a portion of the Otay Ranch property
falls within the City of San Diego municipal boundaries (approximately 390
acres, east of Brown Airfield on the Otay Mesa), this area is under the
service jurisdiction of the Otay Water District and would be provided with
water service by the OWD."
4. Page 3 .13-8, fourth full paragraph, revise the third sentence to read: "The
Sweetwater Authority serves central Chula Vista largely from the
Sweetwater Reservoir filtration plant. The Sweetwater Reservoir has a
capacity of 27,000 acre-feet and the filtration plant has a design capacity of
24 mgd. "
5. Page 3.13-8, fifth full paragraph, revise the first sentence to read: "The
Otay Valley parcel and a large portion of the developable Proctor Valley
parcel are within the Otay Water District."
I
6. Page 3.13-9, figure 3.13c2. Delete the reference for the City of San Diego
Water Utilities Department serving any portion of the project. The boundary
line shown is a municipal city boundary, not a water service jurisdiction
boundary. The OWD jurisdiction includes all of the Otay Valley parcel and
that property on Otay Mesa, east of Brown Airfield at the project's southerly
boundary. Additionally, delete the reference to the Tiajuana Valley County
Water District and replace it with the San Diego Water Utilities Department.
While the Tiajuana Valley County Water District does exist, it does not
J-()&
Douglas Reid
October 1, 1992
Page 3
serve water to the west end of Otay Mesa, the City of San Diego serves this
area. (See attached figure)
7. Page 3.13-15, first full paragraph, first sentence, delete the reference to
"the Colorado River'Basin RWQCB". It has no jurisdiction within the
project area or the region's surface and subsurface waters.
8. Page 3 .13-17, Jurisdictional Alternatives, the second sentence should be
revised as follows: "The Otay Water District is the preferred jurisdiction
for water service, however, each of these alternatives is discussed below."
9. Page 3 .13-17, Otay Water District, revise the first paragraph to read:
"Approximately 70 percent of the water demand for the Otay Ranch project
is within the OWD. OWD is the logical service choice for the project.
While the OWD is currently experiencing a water delivery shortage which
impacts its ability to service new demands, this shortage is expected to be
resolved when the new CW A pipeline is completed (this facility is currently
under construction), "
10. Page 3.13-17, Otay Water District, revise the second paragraph to read:
"OWD has adequate capacity to serve existing needs and is planning to serve
the portions of the project that fall within its jurisdiction (the Otay Valley
parcel and a portion of the Proctor Valley parcel). Upon completion of
CW A's pipeline 4EII, adequate capacity would be available to serve Otay
Ranch. With improvements to the MWD and CW A delivery and storage
system, OWD will be able to fulfill its Water Service Master Plan (draft
1992) and provide water service to the Otay Ranch through the year 2030. "
11. Page 3.13-19, Preferred Water Distribution, delete the first paragraph and
replace with the following: "The jurisdictional preference for the project is
to remain in the Otay Water District. Based upon the Wilson Engineering
/};, /
~....,.. '.-
,-./
Douglas Reid
October 1, 1992
Page 4
report, modifications to the Draft OWD Water Service Master Plan (1992)
are suggested for water storage and delivery. These modifications have been
reviewed by OWD and will be incorpora'ted into the final Water Service
Master Plan. Informal negotiations have begun with the City of San Diego
to acquire or lease stbrage and filtration plant capacity in the .Lower Otay
Reservoir and filtration plant for OWD. This type of storage and service
capability will provide the OWD with an additional service alternative in the
event of future disaster or long term drought. Coupled with the completion
of the CW A pipeline 4EII, which will more than double the water service
capacity to the South County, OWD is the water service jurisdiction of
choice for the project."
12. Page 3.13-2 I, Proposed Mitigation, second bullet, delete the first sentence,
as the jurisdictional preference has been stated.
13. Page 3.13-21, Proposed Mitigation, third bullet, revise the first sentence to
read: "Following the adoption of the Otay Water District Water Service
Master Plan, an Otay Ranch Water Master Plan shall be prepared by the
applicant in conformance with OWD standards. The Otay Ranch Water
Master Plan will address, in detail, the following: - Design criteria and
assumptions In accordance with OWD standards and regulatory
authorities..." .
I
14. Page 3.13-21, Proposed Mitigation, add a fourth bullet to read: "A
Reclaimed Water Uses and Restrictions Plan shall be prepared by the
applicant in conformance with the Water Reclamation Plan and current
engineering and health standards, prior to any SPA Plan adoption. These
Uses and Restrictions shall be prepared in coordination with the appropriate
agencies to promote the maximum use of reclaimed water allowed by law,
within the project area.
dDr
Douglas Reid
October 1, 1992
Page 5
15. Page 4.9.14-1, Water Availability and Demand, Demand Generated, delete
first two sentences and replace with the following: "Based on the water
demand rates currently being utilized by the Otay Water District for their
Draft Master Plan, the water use for the Phase II Progress Plan Alternative
is estimated at 17.9 million gallons per day (mgd) for average day use. This
represents a 20 percent reduction from the 22.6 mgd demand shown in the
Draft EIR. This reduction in demand is due to a change in the overall
residential character. This same reduction in demand could be applied to all
other alternatives. Water conservation measures would reduce the potable
demand 121 gpd per unit, for a savings of 2.6 mgd, or 16 percent.
Approximately 90 percent of this demand is attributable to land uses within
the boundaries of Otay Water District.
16. Page 4.9.14-1, Water Availability and Demand, Reclaimed Water, add the
following to the end of the first Paragraph: "Based on discussion with local
agencies, the use of reclaimed water for irrigation on the two eastern parcels
may be permitted; if this occurs, the average reclaimed water demand is
estimated at 5.7 mgd. "
17. Page 4.9.14-1, Water Availability and Demand, Reclaimed Water, second
paragraph, delete "the unanswered question of which water jurisdiction will
ultimately serve the project," from the second sentence as the jurisdictional
preference has been stated as the Otay WateJ; District. This comment is
J
consistent for all alternatives discussed in Section 4.
)-:1
Douglas Reid
October 1, 1992
Page 6
These conclude my comments on the Water Availability and Demand Section.
Wilson Engineering
DSW:jaa
cc: Greg Smith, The Baldwin Company
Steve Doyle, Steven Doyle Consulting
C:\WPSl\MISCILET-MEMOu.oR-MS.l10
J/iJ
WILSON ENGINEERING
DEXTER S. WILSON. P.E.
ANDREW M. OVEN, P.E.
MARK A BURBRINK. P.E.
October 1, 1992
Otay Ranch Project Planning Office
315 4th Avenue, Suite A
Chula Vista, CA 91910
Attention: Douglas Reid, Environmental Review Coordinator
Subject: DEIR Otay Ranch
The following. comments are offered on the above referenced document,
specifically with regards to Section 3.13.2 Wastewater and Sewer Service.
1. Page 3.13-22, Section 3.13.2.1 Existing Conditions, third paragraph, delete
the second to last sentence. Add a new paragraph (as the fourth paragraph)
to read: "When upgraded to a secondary treatment facility, the Point Lorna
plant's capacity may be reduced to as little as 150 mgd if conventional
treatment processes are utilized. Currently, scientific tests are being run to
determine if an alternative chemical treatment of the influent will
substantially alter the effluent characteristics. The Federal Court has
granted the City of San Diego an 18 month tim.e frame to run the tests needed
to determine if the effectiveness of chemical treatment on the influent will
be equivalent to secondary treatment levels. The results of these tests and
the potential changes to the Clean Water Program will not be known for
some time. Additionally, the City of San Diego has identified a new sewage
treatment plan alternative (for capital facilities), which is based in part, on
the use of chemical treatment at Point Lorna. This new alternative, designed
"the Consumers Alternative", can not be fully analyzed until the Court rules
t/;
c-
703 PALOMAR AIRPORT ROAD. SUITE 300 . CARLSBAD. CA 92009
(6t9) 438-4422
FAX (619) 438-0173
Douglas Reid
October I, 1992
Page 2
on the results of the current testing programs. The State of California has
adopted new Special District Act legislation for the METRO Sewer Service
area. While changes to facility schedules and treatment alternatives have not
been finalized, the goal of providing sewage service to the Otay Ranch has
not been altered.
2. Page 3.13-26, Jurisdictional Alternatives, fifth paragraph down, which
begins" A jurisdictional alternative..." should be deleted and rewritten as
follows: "The jurisdictional preference for sewage service is the City of
Chula Vista in coordination with METRO or its new Special Act District.
For those areas of the project which will not be incorporated into Chula
Vista, the reviewing authority for facility design would be the County of San
Diego and transmission agreements with the City of Chula Vista would be
required to take the sewage flows through Chula Vista to METRO. This is
considered to be a potentially significant impact because the inter-agency
arrangements for the new Special Act District have not been completed at
this time.
3. Page 3.13-29, Wastewater Treatment Alternatives, the third paragraph which
begins: "A wastewater treatment alternative..." should be deleted and
rewritten as follows: "The wastewater treatment alternative shown as
number 3 above is the preferred solution for the Otay Ranch project. In
coordination with the Clean Water Program, City, of Chula Vista, County of
San Diego and Otay Water District a wastewafer treatment facility, suitable
for the production of tertiary treated, reclaimed water, would be constructed
on the site designated and approved in the Otay Valley. Issues of timing and
funding remain to be solved by the above agencies, but the phasing of the
Otay Ranch shows this facility would not be required until some time in
Phase II, which is consistent with the latest schedule of the Clean Water
Program. At the General Development Plan level of analysis, wastewater
facility/service impacts are considered to be potentially significant."
did-
Douglas Reid
October I, 1992
Page 3
4. Page 3.13-29, Proposed Mitigation, first bullet, delete the first sentence and
"In addition" from the second sentence. Because the applicant has proposed
to be service by the City of Chula Vista and METRO, this sentence is no
longer applicable.
5. Page 3.13-29, Proposed Mitigation, second bullet, delete the following
portion of the first sentence: "Following the determination of which
jurisdiction will provide sewer service to Otay Ranch,". See comment 4
above.
These conclude my comments on the Wastewater and Sewer Service section.
Wilson Engineering
--
DSW:jaa
cc: Greg Smith, The Baldwin Company
Steve Doyle, Steven Doyle Consulting
C:\WPSIIMJSC\LET-MEM0IL2DR~.110
"-1 /
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Thomas A. Davis
1657 Gotham street
Chula Vista, CA 91913
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october 5, 1992
otay Ranch Project Office
315 Fourth Avenue, suite A
Chula Vista, CA 91910
Re: Draft Environmental Impact Report, Otay Ranch, July
1992.
To Whom it May Concern:
As an interested citizen and resident of the City of
Chula Vista, I wish to submit comments on the Draft environ-
mental Impact Report (DEIR) for th~ otay Ranch project.
General
Comment #1. The DEIR offers no balanced treatment of
the project as it relates to the social and economic impact
it will have on the entire city of Chula Vista. In addition,
the principle assumption of the DEIR is that the project
will be approved, in the main, by the governmental entities
that have jurisdiction over the area proposed for develop-
ment, and that rejection of the project for any reason was
not considered. The elimination of the option to reject the
project represents a major fault in the DEIR, primarily
because no proof is offered that there is an adequate supply
of water available to support the project's requirements.
There is also a strong inference in the DEIR that a majority
of the citizens of Chula vista support the project, and that
they have participated in the development of the DEIR docu-
ment. The participation, in fact, was only by by a small
number of hand-picked individuals that have never examined
the overall project, and were given no authority to do
anything more that make "suggestions" (thi~ participation
only "rubber stamped" the developers pr;dposals). Under no
circumstances does this token participation represent the
views of the majority of city's residents.
Comment #2. Is not proven that the project will provide
long-term benefits for the social wellbeing of the city.
There is no reasoned argument presented that describes the
effects, and benefits, of increasing the population density
to the levels suggested by the DEIR, or any of the so called
alternative plans. There are unmitigatible and irreversible
effects described in areas such as land use, land form
d/tf
otay Ranch DEIR. Page 2.
alteration, biology, cultural resources, agricultural re-
sources, air quality, and noise that will forever have a
negative effect on the city and the region. In smaller
projects, the social and cultural impacts might be somewhat
less difficult to identify and assess. In the proposed
project, the negative impact on such frangible features
cannot be dismissed simply as "unavoidable", and the project
allowed to proceed. The DEIR is basically flawed in not
adequately dealing with provisions for social and environ-
mental protection for the city of Chula Vista and the re-
gion.
Specific comments
Land Use, Planning and Zoning - Section 3.1, and all
alternative plans. The DEIR indicates that there are incon-
sistencies between the proposed plan and the land use poli-
cies and zoning of the General Plans of the City of Chula
Vista and San Diego County, the county's Subregional plan
and Regional Land Use element. The proposed mitigation is to
change these plans to suit the proposed plan. There is no
argument or proof given that supports or explains the rea-
sons for changing the existing plans, other that the change
will make the project possible.
The project developer is not a simple land owner trying
to make the best possible use of his historical land hold-
ings. The project developer is engaged in land speculation
on a gigantic scale. All citizens and residents of the
region will be significantly and forever affected by this
proposed project. In order that the citizens and voters of
the city and county acknowledge the potential impact of this
proposed project, a change in the city or regional planning
documents should be allowed only after a majority of the
citizens approve a change in these documents through the
ballot process.
Landform Alteration/Aesthetics - S~ction 3.2, and all
alternative plans. The singular argume~t presented to justi-
fy changing or destroying, forever, landforms, uplands,
wetlands, vernal pool habitats, and a long list of wildlife
and plants, is that it.is the inevitable result of proceed-
ing with the project. The DEIR is basically flawed in that
there are no arguments presented, or developed, for a "no
project" decision to prevent the unmitigable impacts from
occurring at all. One of the basic purposes of the EIR
process is to provide the various decision-making bodies
(Planning Commissions of the City of Chula Vista and the
County, chula Vista City Council and the San Diego Board of
Supervisors) with all of the available data that effects the
impact of the project on the population and the environment.
. --~----~---- .
._..~_____.____""..___- ______. ~.u_...____ _ __.
otay Ranch DEIR. Page 3.
Since only the views and information that are favorable to
the proposed project developer are contained in the DEIR,
data for decision makers is automatically and fatally biased
and skewed, compromising the value of the DEIR.
Transportation circulation and Access. - section 3.10,
and all alternative plans. In any form, the key transporta-
tion link that is essential to the success of the project is
for the construction of SR 125 as a roadway of between ten
and twelve lanes, and multiple interchanges (5). No existing
plan or funding exists for construction of SR 125 that will
accommodate the assumptions made in the DEIR. The California
state transportation budget projections contains no con-
struction funds for this route out to and beyond the year
2015. There is no indication that even if a major alteration
in the allocation of highway funds did come about, that the
requirements described in the DEIR would be funded by the
state. The only other known option for construction of SR
125 involves a private company that proposes to build a toll
road on the SR 125 right-of-way. The tentative plans dis-
closed to the public describing the configuration of the
proposed toll road indicate that it would provide no where
near the required capacity or access necessary to support
-the proposed project. In addition, the DEIR fails to ade-
quately explain how, or when, extensions of SR 125, beyond
the immediate area of the project, would be phased or funded
so that the anticipated flow of traffic could reach distant
destinations.
As described in the DEIR, all surface streets that
currently exist in the areas of Chula Vista (East H street,
Telegraph Canyon Road, otay Lakes Road, Bonita Road, East
Orange Avenue, Naples, Palomar, and Main street, and others)
adjoining the proposed project must be widened by at least
one lane in each direction. The effect widening these roads
and streets, and the cost of acquiring additional
rights-of-way have not been identified or developed. For
example: All of the existing roads and st~eets have curbs,
landscaping, drainage sewers, sidewalk~: street lighting and
traffic signals that would be disrupted by the expanded road
and street requirements of the proposed project. The cost of
this work is not adequately developed in the DEIR, a criti-
cal consideration that may make the proposed project prohib-
itively expensive for the developer or the taxpayers. Addi-
tionally, the colossal visual and noise impacts of four, six
and eight lane surface roads on residential areas through
which these roads and streets pass, is ignored. The widening
of Otay Lakes Road is representative of this adverse impact.
southwestern College would be required to give up 30 feet of
frontage over the entire length of their property on Otay
Lakes Road, essentially destroying the appearance of the
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otay Ranch DEIR. Page 4.
College entrance. Similarly, a large portion of the lawns at
Bonita Vista High School and Bonita Vista Junior High School.
would be lost. The impact on th& residents of homes along
Otay Lakes Road, and other streets similarly affected," would
be unacceptable.
Air Quality/Noise - Sections 3.11 and 3.12 and all
alternative plans. The DEIR makes voluminous reference to a
long list of city, county, state, and federal air quality
and noise regulations, ordinances, standards and levels. In
many places the DEIR, the specific regulation that this
proposed project would violate (e.g. excessive emissions
from automobiles, state and federal air quality standards,
and standard maximum decibel levels) is identified, but the
presumption is that the regulations, ordnances and standards
will be ignored - completely. The official abrogation of
responsibility to protect air quality and noise standards
for the citizens is not explained in the DEIR. A straight
forward statement of the reasons for ignoring city, state
and federal regulations and ordinances in the areas of air
quality and noise standards should be drawn up and signed by
public officials responsible for approving this proposed
project before further action is undertaken.
Public Services and utilities - Section 3.14 and all
alternative plans.
Water Availabilitv and Supply. The primary retail water
supplier for the proposed project is the Otay Water Dis-
trict. The Otay Water District has no control over the
sources of water supply to this region, or the system that
delivers water to the region from the distant sources. The
district merely distributes water to local commercial,
public and residential users. Water availability, therefore,
is directly limited to the quantity that can be delivered by
the water wholesalers. The County Water Authority, the local
regional water wholesaler, delivers water through one large
diameter pipeline (five pipelines SUPplT San Diego County
with water, but only one of these supplies the area of the
proposed project. A second pipeline is under construction
for the south bay region, but this is to supply only
untreated water to water districts that have storage and
treatment facilities, which Otay Water District does not
have. The second pipeline will have no effect on the total
water supply to the proposed project).
The major water distributor for the state, south of the
Los Angeles basin, is the Metropolitan Water District of Los
Angeles. The Metropolitan Water District has three principal
sources of water: the Owens Valley, the Colorado River and
the California State Water Project - and all water from
these sources have rigid allocations assigned. Because of
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,.__ .~_..____._.n__'
otay Ranch DEIR. Page 5.
riparian control of water sources recognized in this state,
and the system of water distribution through pipelines and
aqueducts controlled by independent water agencies, the
amount of water available to the otay Water District .i~
finite, and less that the requirements of the proposed
project by a significant quantity (the District, for exam-
ple, is already required by the County Water Authority to
reduce water consumption by ten percent from the base year
1989). No significant additional sources of supply or deliv-
ery systems is anticipated in the foreseeable future.
The limits on the regional water supply are well known
to the City of Chula vista (who turned off the once landmark
fountain in front of city hall to "save" water) and the
Inter Agency Task Force (who has offices in a building where
an ornamental fountain was also turned off to "save" water).
The developer of the proposed project, contrarily, seems
unaware of the existance or extent of the situation. Despite
the known limitations of the water supply, the wording of
the DEIR considers that if the developer of the proposed
project simply drafts a "Water Master Plan", the "impacts"
of the water requirements of the proposed project will be
reduced below the "level of significance".
There is no realistic option or recourse that will
produce more water to support. the requirements of this
proposed project. To think that a paper Water Master plan
will accomplish this feat is the purest fantasy. The County
of San Diego, the City of Chula Vista, and the Inter Agency
Task Force are responsible for the critical issue of the
water requirements for the proposed project, not the otay
Water District. The shortfall in water availability is
already known, and no plan for local water storage or new
distribution systems within the area of the proposed project
will alter the lack of an identified source of water. There-
fore, The DEIR is basically flawed in not identifying the
critical and controlling effect that the lack of an adequate
water supply will have on the proposed project.
Waste Water and Sewer Service. Chu~a Vista has the only
excess sewerage capacity in the San Di~go Metropolitan Sewer
District. This excess capacity will not, however, cover the
additional flow generated by the proposed project. It ap-
pears that the DEIR fails to define the true waste water
disposal requirements of the proposed project.
Intearated Waste Manaaement. The south bay land fill in
otay Valley will reach permit limits by about the end of
this century (eight years), or earlier if other residential
and commercial development projects the city of Chula Vista
and the City of San Diego intend to go forward with on otay
Mesa. New land fill sites are extremely difficult to get
approved, and no new regional .sites seem likely to be opened
before the regional land fill reaches capacity. It is,
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_........_.._...,... .. _ ,'_'_ ~_ J.'
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otay Ranch DEIR. Page 6.
therefore, unlikely that the waste generated by the proposed
project can be met, indicating that the DEIR inaccurately
deals with waste disposal.
Police and Fire Protection. The DEIR does not consider
the out-year personnel costs of providing police and fire
protection for the area of the proposed project. The cumula-
tive impact of forever paying the personnel costs of the
increased number of police and firemen will have an impact
on the city's tax rates. The additional annual personal
costs will amount to millions of dollars that will have to
be supported by the general fund. Overlooking the signifi-
cant fiscal impact of out-year personnel costs represents a
major flaw in the DEIR.
Parks, Recreation, and Open Space. The DEIR presents an
unclear picture as to whether areas listed as parks will be
public or private. The distinction must be made since it
will have an impact on future applications for compensating
increases in density by the developer. It also appears that
a proposed golf course site is considered a "park", an
unacceptable condition. The DEIR seems not to mention how
the proposed project will affect the Lower Otay Lakes County
Park. while this park is currently not open, there seems to
be evidence that there are plans to keep this park in opera-
tion in the future. The DEIR does not make clear how this
park, and other existing park and recreation areas around
the Lower Otay Lakes reservoir will be effected by the
proposed project, other than the air park which will be
bought, destroyed and turned into profit-making land by the
developer.
Electricitv and Gas. During the years 1969 through 1973
there was a world-wide energy crisis. The extent reached by
this energy crisis led to the City of Chula vista and Cal-
Trans turning out a portion of freeway and street lights to
"save" energy. other measures were instituted at all levels
of government that affected every member of the population
in order to save energy - turning down hQusehold thermostats
in winter and setting air conditioning settings up in the
summer were products of this campaign. ,It is amazing that
now there seems to be no. concern about the availability of
adequate energy sources at all, and that doubling or tri-
pling the potential electric and natural gas requirements of
Chula Vista as a result of this proposed project, is no
problem. It is appropriate that the true energy situation be
determined before too much faith is placed in the ability of
SDG&E and the western power grid to reliably supply elec-
tricity to the region for the next fifty or seventy five
years.
This is well into the time-frame in which fossil fuel
resources are predicted to be exhausted. Since there have
been no nuclear power plants completed in the western United
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Otay Ranch DEIR. Page 7.
states in over fifteen years, no new plants are even in the
planning stages (to say nothing of the permitting process),
and new coal-fired plants are equally unlikely to be added
to the power grid, the predicted decline in oil reserves
seem certain to reduce the availability of. electric power to
Southern California. If this supposition is accurate, the
proposed project will accelerate and directly contribute to
the social and economic decline of the region, and result in
untold hardship on the population.
The DEIR for the proposed Otay Ranch project is funda-
mentally flawed in the areas of:
A balanced analysis of the benefits of the
project.
Lack of participation by the citizens of Chula
Vista.
The irreversible effects on the environment.
Adequate traffic circulation.
Provisions for adequate air quality.
Noise reduction.
Water supply.
Sewerage disposal.
Solid waste disposal.
Police and fire protection.
Park land.
Electric power.
The document should be rejected and the project sub-
jected to a more rigorous and unbiased analysis.
;;t:J {f~~
Thomas A. Davis
Copy to:
Ms. Lari Sheehon, Deputy Chief Administrative Officer,
San Diego County Admnistrative Center
1600 Pacific Highway
San Diego, CA 92101
cJ Ju
,iYl
E H C
PHONE ~IO.
235-0281
42276913
OCT. 6.1992 10:48AM P 2
leERS
'.ouIa Failla, MSW
"casldent
:niid Protective Services
.'Alchael Shame.
'.jiC9 PresIdent
JUUty Con-sumer Action Network
3eol,I, Barrozo.Roppe
Se<;;retary
VCSD/SDSU Par La Vida Project
Tony pelllna. MA
Treasurer
S,D. Community College District
)ARC OF DIRECTORS
DouQ Bolli.
'nrernotlonol Assoclatlon
of Iron WOrkers
Jim Bell
t;:cologlcol Ufe SystGms Institut~
Lou,erice L. Brunton, Ph.D.
VCSD Sc/1001 at Medicine
Mcty Carmichael
"candido Neighbors Against
:iiemlccl Toxins
,oll Chollleld
;, KG8FM
Aorc CummlnQ:Ii
Nothen Cummings Foundation
Ruth cuemler
Sierra Club
Anne-Marie Feenberg, Ph.D.
Unlvarslty of Redlands
Edword Gorham MPH
Neval Health Research Center
Ruth Helfelz, MO. MPH
UCSD School at Medicine
Richard Juarez
MetropoUton Area
Advisory Committee
Shoron Kolemklcrlon
Attorney
Lyn Lacy.
locya & A~roclotes
Oon McKltncn, PI't.O.
uCSD School 01 Med!cl""
Sylvia Mlclk. MD
North County Heelth Ser.lco'
Reynoldo PI.a~o
Joy Powell
~Ichatd Whorton
usa EnvlronmenTol Law Cllnlc
alone Takvorlon
:,Xecutiv$ Director
october 6,. 1992
Mr. Anthony J. Lettieri
General Manager
otay Ranch project
315 Fourth Avenue
Chula Vista, CA 91910
RE: otay Valley ErR Comments
Dear Mr. Lettieri:
Environmental Health coalition (EHC) would like to
make the following cornnents on the Otay Valley Ranch
EIR. Our primary concern centers around impacts to
water quality in the region and on San Diego Bay.
There are many structural Best Management Practices
(BMPs) that w~ll reduce the quantity and improve the
quality of runoff that should be included in the
mitigation measures in the ErR. Educational
programs, and policies can also be incorporated as
mitigation.
The ErR cites flooding concerns from inundation
during heavy rains. However, cencrete
channelization in the project area should be a last
resort. In the past we have exacerbated the
flooding problem through increase of impervious
surfaces in a watershed and by channelizing
drainages. This has exacerbated the problems of
runoff quantity and quality. / 'Requirements on this
project should include aggressive use of the BMPs
listed below.
BMPs fall into three categories:
BMPS that reduce pollutant generation (Process and
Educational BMPs)
BMPs that reduce pollutant transport
BMPS that treat polluted runoff
c2 :J/
ERe supports
transport of
ct1~lorlor'lS not&d fer k7anhrlcc lion plJrpose, onlV
BMPa that reduce the source and
pollution because treatment of polluted
:-. ~..-,-,..- ..__.~-----
M E H C
PHONE NO. 4227690
235-0281
OCT. b.1992 10: 48Rf'l P 3
urban runoff, the most costly appro~ch both economically and
environmentally, is what we are trying to ~voidl
Hitigat:lonto <)ffsetpollutahtgeJ1erlll.i:lOI1 through eduoationAi and
proCl.1I1I SMPll!
MITIGATION rOR AIR POLLUTION iMPACTS
1. Include programs that reduce the nUmber of car trips,
increase ridership on trolley and bus, and promote
alternative transportation, ,bike, walk, carpooling etc.
2. Include Oil Recycling Faoilities-Provide a free oil
recycling center 1n the watershed.
3. Incorporate programs that require that all vehicles are
inspected for fluid leaks during smog checks. Plan to
increase availability of automobile tuneups through
promotion, by a service station or a community college/high
school auto shop, of a "Free Tune-Up Day' for residents in
the watershed.
4. Require vehicle fleets in the area that run on compressed
natural gas. Natural gas powered cars emit 90% lese of the
harmful chemicals found in smog.
MITIGA!ION tOR P~STIC!DE cO~TAMINATION IMPACTS
In the discussion below our Use of "pesticide" is meant to
include herbicides, fungicides, and rodenticides as well.
Reduction of pesticide-caused pollution are easily reduced by
disallowing pesticide use in the project area.
1. Integrated Pest Management (IPM) should be required in a
covenant or other mandated arrangement for all project
aspects. IPM is suitable for all public places, municipal
parks, golf courses, and cemeteries and could be included in
the covenants in new developments. It is significant to
note that the San Diego Unified School District has taken
the lead by adopting an IPM policy district-wide, thereby
protecting children, teachers, and staff at school.
2. Use of chemical pesticides along planned streets and
highways by CALTRANS and other street maintenance staff
should be prohibited in this project.
3. Prohibit use of pesticides when precipitation is forecast
for the area. This will help prevent mOVement of these
chemicals out of the area intended for use and into the
waterways. In areas where there are heavy agricultural uses
of the land, pesticide contamination of runoff and ground
JJ~
:~, E H C
PHONE ~IO.
235-0281
4227E.90
OCT. 6. 19'32 10: 49;:>:1 P 4
water is a serious problem.
4.
Prohibit any use of pesticides that have been cancelled.
The fl.P.A. maintains '~ li~t'of those cancelled chemicals.
Require drip irrigation systems in all new development.
5.
MITIGATIOn ~O~ INCREASEn USE OF HOUSBHOLD TOXIes
1. Establish a Household Hazardous Materials Program for the
project that educates about proper disposal of household
toxies while aggressively promoting safe substitutes for
household toxics that pose less of a threat to the
environment from their manufacture I use, and disposal.
2. Require storm drains to be stencilled with a "no dumping" to
alert residents to the connection of the storm drain system
to sensitive downstream waters and to discourage use of the
storm drains for disposal.
3. Establish a hot-line so residents can report dumping and
regulators should take a strong position to assess fines for
illegal actions and to aggressively. Include street sign
posting that storm drains, are not for dumping.
1 .
MITIGATION ~OR INCREASED EROSION
2.
3 .
4.
Require site drainage design or other control measures that
will minimize runoff from construction sites.
Require incorporation of vegetated, infiltration, or
detention-based BMPs. Use planted areas to maximize
retention and infiltration.
Require significant use of permeable surfaces such as bark,
gravel, ground cover, cobblestones, or brick.
Require and implement requirements on erosion control at
construction sites--use sand bags, covers, straw bales to
hold soil in place during cOhstruction; and use temporary
detention ponds.
MITIGATION tOR IMpACTS OF GROWTH OH t~E A~A -- ~ROMOTE
SUSTAINABLE GROWTH
1. Establish policies that promote purchase of safe substitutes
to toxic materials, the purchase of organic food, energy
efficiency, mass and alternative transportation, and
recycled products in all aspects of the planning and
implementation of the project.
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1M : E H C
PHONE NO.
235-0281
4227690
OCT. 6.1992 10:50AM P 5
s~jtucromu. aMPS mA~ ltJrDUd~ P()LLtr1'AJrr T!UUfSPORT
1. Require that greenbelt ~nd bik~way links ere provided for in
all projects. This will ~n~ure that ~e are building an
alternative transportation irtfraetructure and mitigation by
planning green belt corridors.
2. Require aggressive re-forestation of the project area to
cool the "heat islands" that the project will contribute to.
REDUCE CONCRETE/PROMO~E PERMEASL~.SUR'ACES
1. RedUce the use of concrete, asphalt, tar, and other
impermeable surfaces where possible. Replacing paved
surfaces with permeable vegetated areas will slow the
runoff, and give rainwater more surface to soak into, thus
reducing the velocity and the volume of the runoff.
2. Reduce flows from parking lots and commercial properties.
This can reduce pollutant loading as much as 50%. Pavement
can be replaced by a variety of equally "parkable" surfaces
that promote infiltration rather than runoff. These are
already in use in many places, and bacteria exists in the
soil beneath the surface that can naturally degrade
pollutants. One possible model is shown on the attached
diagram.
USE MATURAL, UNLINED ORAINAGE CHANNELS WH!~ POSSISL~
Channelization of drainage systems reduces groundwater
recharge and increases flow and transport of pollutants into the
receiving water. It also does not eliminate flooding in the area
during the heavy rains. Natural drainages and swales allow for
groundwater recharge and lessening of the veloci.ty of the runoff.
Mitigation for inc~eA~e of surface Lmpermeabil~ty caused by the
project -- Vegetative BMPII "
Vegetated BMPs reduce pollution trarlsport naturally using
vegetation and natural infiltration into the soil to filter out
and, in some cases, treat pollutants. in urban runoff and to
reduce the velocity and volume of the runoff. They are generally
low cost and viewed as desirable by the community. They provide
significant community enhancement, beautification, and
mitigation. These should be widely used in the project.
GRASSI!:D.SWALI!:8
Placement of vegetation on sides of storm drain channels and
streets reduces the amount of pollutants in storm water runoff.
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:M : E H C
PHO~:E NO.
235-0281
4227690
OCT. 6.19'32 10: 50f'1t't P 6
Designate vegetated swales as a requirement for all projects
including parking lots.
Swales are an excellent supplement to other BMPs. They are
most successful when applied to residential and highway medians
as an alternative to curbs and gutters. Swales are less
expensive than curb and gutter systems, but if they are heavily
fertilized or treated with pesticides they can end up
exacerbating the problem. Addition of check dams can improve
infiltration rates, but underlying soils must be permeable for
the most effective use of swales. Roadside and backyard swales
can be managed aa natural areas. One drawback iSl that 'they are
not generally able to remove soluble pollutants, such as
nutrients.
FtLTEIt STltlrS
These are similar to grassed swales except that they accept
overland sheet flows of water. Runoff must be evenly
distributed. This method complements efforts of urban re-
forestation. Filter strips reduce watershed imperviousness and
runoff volume and velocity and cost almost nothing to construct,
especially if areas are preserved prior to construction. A well-
managed filter strip can be a valuable community amenity.
Filter strips are effective in removing sediment, organic
material and many trace metals as pollutants infiltrate soil and
are taken up i.n rooted vegetation cr by soil bacteria. Forested
stripe have greater pollutant removal than grass but need to be
twice as large as grass filter strips. The benefit is that
forested strips reduce runoff by 30-50%.
Once established, filter strips need little maintenance.
The edges must be maintained to ensure spreading of the runoff.
It could be fenced off where security is a concern. Shorter
grass strips shOUld be managed as a small meadow or lawn. They
should be mowed a couple times a year and inspected annually.
I
/'/
CONSTRUCTBD WETLANDS
Wetlands provide many valuable functions. Improvement of
water quality is one of the most important. Wetlands can also
control flooding, reduce stream velocity, and provide wildlife
habitat at low maintenance costs. The surface area of a
constructed marsh should constitute 2-3% of the total area of a
contributing watershed. In arid regions, some source of dry
weather water, either irrigation flows or groundwater, should be
available.
Pollutant removal in constructed 'Iletlands occurs by the following
mechanisms:
* Petroleum hydrocarbons may be evaporated, taken up in
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lM:EHC
PHONE NO.
235-0281
4227690
OCT. 6.1992 10:51AM P 7
plants or digested by bacteria.
* Nutrients will be taken up by wetland plants.
* Microbial degradation occurs in the substrate and root
surfaces. Heavy metals are converted to relatively
insoluble sulfides. Preliminary studies have not shown
significant b!oaccumulatlon of heavy metals although
heavy metals can be absorbed in the peat.
* Bacteria and viruses will naturally die off in the
detention pond and wetlands reducing health concerns.
While it has not been demonstrated that constructed wetLands
simulate all aspects of natural wetlands I they do achieve a
certain degree of the natural purification/filtration that
natural wetlands do. A constructed wetland can be very
effectively combined with infiltration or detention BMPs. This
entails creation of a shallow, lined pond-like depression that is
planted with wetland species. Two California natives, cattail
Typha latifolian and the bullrush Scirpus validus, have proven
highly effective for pollutant and nutrient removal. Vegetation
should be harvested every two years to guard against build up of
toxics if evident.
o I!:TI!:N'1' I ON PONDS
Detention/sedimentation basins are best in areas suffering
from sediment buildup and erosion. These ponds collect and store
runoff and, by releasing it slowly, allow the sediment to settle
out. Detention ponds are an effective, low cost means of
removing sediment and reducing water quality impacts of erosion.
If stormwater is detained 24 hours or more as much as 90% removal
of pollutants is possible. Positive impacts include creation of
habitat and recreational use associated with the inundated
portion of the pond. The draWbaCKS inclUde occasional nuisances
and aesthetic problems, weeds, mosquitos, trash. However, if
built in conjunction with a small constructed Wetland as
described above, these nuisances can be minimized.
INtILTRATION TRENCHES
,i
Infiltration systems allow water to soak into the ground, or
"recharge" ground waters. Infiltration trenches are an adaptable
BMP that remove both soluble and particulate pollutants. The
first flush runoff passes through stone, cloth, or soil to remove
pollutants. Trenches are very useful in small areas, margins,
perimeters, and other underutilized area of a development. They
work best if uBed with swales to remove coarse particulate
(sediment). Trenches receive high marks for protecting water
quality and downstream aquatic life. Naturally occurring
bacteria aid in pollutant removal and trenches will last 10-15
years with care. They are very unobtrusive, have low maintenance
requirements, and have little impact on humans. They are widely
used in Arizona.
JJt
OM E H C
PHONE NO.
235-0281
4227680
OCT. 6.1992 10:52AM P 8
INFILTRATION BASINS
Larger version of trenches are infiltration basins which are
effective in removing both soluble ~nd fine particulate ,
pollutants but not sediment. Thess are probably the b~st for
protectin'il' downstream aquatic life. The contributi.ng area for an
infiltrat~on basin should not exceed 50 acres and maintenance
consists of annual inspection and mowing, debris and litter
,removal, tilling and revegetation of soil if needed to improve
infiltration. If maintained, theBe can be used for recreation
such as ball fields or playgrounds but frequent testing and
maintenance is a must. These are widely used in Fresno and
managed as playing fields and Park areas.
Thank you for the opportunlty of commenting on this };:IR.
sincerely,
Laura Hunter, Director
Clean Bay Campaign
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1 : E H C
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235-0281
42276'30
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STOIIM $EWUI
"'lIUI'lI' :L Hyp<>lhekal Appllcalion 0/ . ~,"nb!llll1 . p~ "!"~. .
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.it.. wh.r. mar.h.. have blOn dredild. tllI.d, '
and/or chann'l.d IInd which could b. developed
at w.t1l1l1cb. . "
, I ,
Llttl, Information I. ayallabl. ralardlni' the
.{(ectlv.n... ot wetland. In removlnr oil and
p.a.e from .tormwlltu runo{!(Chan.! al..1981).
Since the majority of oil and ir.... In runo{( I.
nonnally (ound u,oclat.d wfth POI1ICllla'a.. it ,.
""onabl. to auum. lhat w.tland, would ad
prlmllrily U I ..dh,entaUon trap. PaUll tan'
r.moval from Ih. wat.r column would occur.. tha
p'l1lculatee ..leI.; with d'Q'1'ad"\ion reapon.lble
(or their ulthZlat' .lImlnation. Th. removal at
'therpollulante b.. Ide. all and it.... would al.o
,. anticlpat.d. An accurat. ..'eee.m.nt of 011 and
Irea.. r.moval POI.ntlal COil III not b. m4d, until
,ilo' UUdle. were condllct.d.
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Th. co.tt of 'wetlands appeu r./atlVely h1ih.
W.lIalld. requln II .Ilb.talllial quandty of land.
COIl.trllatloll 'co.~ (or 'lb. /In! wttllUld .re..
. "'ollld prob.bly b. hlll'her ihal1lho.. tor w.tlal1&u
buill aft.r lhe t~noloiY WII tully ~eVlloped
beclluu ot lh. lncn..td .at.ly taetorl n-.ded to
account for d..IJl1 ul1e...1-alZltl... Bill Ih.' hli'h
Initial cOQ.lruc!1cn co.te u.u&lIy would b, I...
IblZl tbl cod ot conY,nUoaal w"~wat8r trllat-
m.ni plan~. .
Whll. wetland developm.nt wOllld be rel.tiv.ly
.:rp.a,lv.. ill value would aol b. Umit<<d to water
tr'!llmln*. WeU&l1da Ilr. belZli' r..toro<l lAnd d.vel.
oped around the Bay Area IMIcaua...o/othtlr ae..
Ih,Ue, wildllll and recroariDnclnm." III ,oroe
ca.... Intell1'alini' water qllaIUr'cbQ~deraiioll'
Into plan. (or ,nhallcJni ...U....d....ourc.. cOlUcl
4: .
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Tony Lettieri, Director
Otay Ranch project
315 Fourth Avenue Suite A
Chula vista, CA 91910
0,,-
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October 5 ,'-IT9L.
Dear Mr. Lettieri:
After reading the Draft Environmental Impact Report for the Otay
Ranch project, I feel I can without question state-that the
document is completely unsatisfactory. It is unsatisfactory
because it is incomplete, dated, and presents illegal
alternatives.
It is incomplete because it does not answer vital questions:
1. What will be the impacts on historic and prehistoric
resources? The Draft EIR repeatedly states that these impacts
are unknown.
2. The source of needed water is unknown. According to the
Draft EIR "One half of the land is within the Otay Water District
which is currently experiencing water shortage." (3.13-17) The
DEIR further states that "Further analysis is necessary to
determine the magnitude of the impacts and to identify measures
appropriate to mitigate significant effects." (4.9.10-1)
Moreover, at present residents in the Otay Water District are
paying significantly more for their water than residents in the
rest of the city. More residents demanding service from an
already over-burdened system will compound the problem. The Otay
Water District is the least likely company to be able to provide
more water for more residents.
The DEIR is out-dated. It was begun before and apparently igores
the crisis which has occurred with Califonia schools. In the
last two years, millions of dollars have been withheld from
California schools; teachers have been dismissed; teachers'
salaries have been reduced (even teachers in San Diego); schools
construction has been halted. Yet the DEIR talks about building
between six and 32 new schools. Further~states that one-third
of the $378.6 million for school construction will come from
state funds. There is no longer any hope pf these state funds;
Governor Wilson says that the financial deficit is here to stay.
Moreover nowhere in the DEIR does the issue of techers' salaries
get addressed.
The DEIR presents illegal alternatives:
1. Pollution: "Soils contaminated with petroleum hydrocarbons
and pesticides have been identified in the area...the potential
exists for exposure to contaminated materials in excess of the
State of California standards." (4.7.15-1)
2. Damage to the. Least Bell's vereo. This .bird is a state and
federally listed endangered species. "Any net loss of individual
c:;'d<f
----~------_...------_.._._-_.._- ..
federally listed endangered species. "Any net loss of individual
or occupied habitat is not allowable for this species." (4.9.4-9)
3. Noise levels created by the project would exceed 60 dBA CNEL
standard.
4. Air quality: "Project emissions...would add to existing
violations of federal and state zone standards." (1-9).
Although not illegal, it does not make sense to negatively
impact:
1. Sensitive uplands, wetlands, and vernal pool habitat
2. Fifty wildlife species
3. Seven state-listed endangered plant species
4. The coastal cactus wren and the California gnatcatcher
5. Traffic on road segments and intersections
6. Existing county and Chula vista city plans and policies.
According to the DEIR all six of these will have "significant,
unmi tigable impact."
The Draft EIR is unacceptible. A new one must be prepared which
is complet~updated, and presents only legal choices.
Sincerely,
~~~-
Adrien Myers
1890 Ithaca Street
Chula Vista, CA 91913
-/
C)J-1;7
-. -~:- :------.,
..--. --_:.--- --- ; \
Douglas Reid
Otay Ranch project Planning Office
Environmental Review Coordinator
315 Fourth Avenue Suite A
Chula Vista, CA 91910
OCT - c
_ '_I
October 5, 1992
Dear Mr. Reid:
After reading the Draft Environmental Impact Report for the Otay
Ranch Project, I feel I can without question state that the
document is completely unsatisfactory. It is unsatisfactory
because it is incomplete, dated, and presents illegal
alternatives.
It is incomplete because it does not answer vital questions:
1. What will be the impacts on historic and prehistoric
resources? The Draft EIR repeatedly states that these impacts
are unknown.
2. The source of needed water is unknown. According to the
Draft EIR "One half of the land is within the Otay Water District
which TS-currently experiencing water shortage." (3.13-17) The
DEIR further states that "Further analysis is necessary to
determine the magnitude of the impacts and to identify measures
appropriate to mitigate significant effects." (4.9.10-1)
Moreover, at present residents in the Otay Water District are
paying significantly more for their water than residents in the
rest of the city. More residents demanding service from an
already over-burdened system will compound the problem. The Otay
Water District is the least likely company to be able to provide
more water for more residents.
The DEIR is out-dated. It was begun before and apparently igores
the crisis which has occurred with Califonia schools. In the
last two years, millions of dollars have been withheld from
California schools; teachers have been dismissed; teachers'
salaries have been reduced (even teachers in San Diego); schools
construction has been halted. Yet the DEIR talks about building
between six and 32 new schools. Further~states that one-third
of the $378.6 million for school constru~tion will come from
state funds. There is no longer any hope/of these state funds;
Governor Wilson says that the financial deficit is here to stay.
Moreover nowhere in the DEIR does the issue of techers' salaries
get addressed.
The DEIR presents illegal alternatives:
1. Pollution: "Soils contaminated with petroleum hydrocarbons
and pesticides have been identified in the area...the potential
exists for exposure to contaminated materials in excess of the
State of California standards." (4.7.15-1)
2. Damage to the Least Bell's vereo. This bird is a state and
~}~ \
"~'-'--'-'-::::';"""~'--"'--"'"~---'-"
---------,,=,-.--------- --., -_.---._---
\
federally listed endangered species.
or occupied habitat is not allowable
"Any net loss of individual
for this species." (4.9.4-9)
3. Noise levels created by the project would exceed 610 dBA CNEL
standard.
4. Air quality: "project emissions...would add to existing
violations of federal and state zone standards." (1-9).
Although not illegal, it does not make sense to negatively
impact:
1. sensitive uplands, wetlands, and vernal pool habitat
2. Fifty wildlife species
3. Seven state-listed endangered plant species
4. The coastal cactus wren and the California gnatcatcher
5. Traffic on road segments and intersections
6. Existing county and Chula vista city plans and pOlicies.
According to the DEIR all six of these will have "significant,
unmi tigable impact."
The Draft EIR is unacceptible. A new one must be prepared which
is complet~updated, and presents only legal choices.
Sincerely,
~~
Adrien Myers
18910 Ithaca Street
Chula Vista, CA 91913
I
I
dJd.-
URBAN SYSTEMS ASSOCIATES, INC.
transportation planning & traHic engineering
consultants to business and government
October 6, 1992
4540 Kearny Villa Road, Suite 106
San Diego, CA 92123-1573
(619) 560-4911 telephone
(619) 560.9734 facsimile
Mr. Doug Reid
Environmental Review Coordinator
CITY OF CHULA VISTA
276 Fourth Avenue
Chula Vista, CA 92010
~
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Dear Doug:
Thank you for providing the Otay Ranch Draft EIR (DEIR) for public review and comment. As
you know we are the traffic consultant for the Baldwin Company and in that capacity we would
like to offer the following comments. Overall the DEIR was thorough and complete however,
we would like to emphasize the following items.
On page 3.10-7, Impact Analysis Section, there are references to Appendix B which discusses
methodologies, threshold standards, etc. Since most citizens do not obtain or review
appendices, we would recommend that the following short supplement to the summary of
Appendix B (Paragraph 2, page 3.10-7) be included in the impact analysis section of the final
EIR.
"Trip Reduction Strategies include the promotion of travel by public transit,
promotion of ridesharing, careful land use planning in order to reduce the need
for auto trips and the encouragement of bicycle and pedestrian travel. Within
communities the use of golf carts for short trips is also proposed. Other
development strategies to reduce or control trip making include appropriate
parking standards, road design standards and incentives along with design
guidelines and design review procedures. Transit is strongly encouraged by
providing transit corridors and facilities in each village core, the provision of light
rail transit and bus facilities as appropriate. One of the most important tools to
control project traffic impacts and assure appropriate and adequate facilities are
available concurrent with need is the phasing of transportation improvements.
Phasing along with this General Development Plan and subsequent Specific
Plans, Tentative Subdivision Maps, Finai Subdivision Maps, Building Permits, and
ultimately Occupancy permits assure absolute control over what transportation
facilities will be built when and where. Mitigation of project impacts will therefor
be assured."
On page 3.10-12, first paragraph, Comparative Analysis of Impacts, the DEIR appropriately
states that "at this program level of review, the definition of project-only impacts is not
provided...". We would suggest that the statement be explained by inserting the following-
language in the final EIR.
0016B9A
<,--)
)~ 1
OTA YRCH3IS4
Mr. Doug Reid
October 6, 1992
Urban Systems Associates, Inc.
"Project level impacts are impossible to fully identify and address at this stage of
development of the new town plan because of uncertainty relating to what
ultimate street system is approved for the area. For example, will 125 be a
freeway or a toll facility? Will there be 2, 3 or 4 river crossings? These major
circulation issues significantly impact trips through the project area consequently
project level impacts can not be adequately identified at this time. During
subsequent planning efforts and preparation of subarea plans, these issues can
be quantified and mitigated."
On page 3.10-23, second paragraph, mitigation measures are alluded to but not specifically
mentioned. We would suggest that the final EIR include the following statement to further
explain or at least identify some of these mitigation measures.
"The plans for Otay Ranch provide a comprehensive, efficient and safe system
for a variety of transportation modes. Automobile oriented improvements do not
entirely define the scope of these improvements. Rather, they are just one
element of an integrated mobility system which includes bus, fixed guideway
transit, carts, bicycles, pedestrian ways and trails all linked to minimize or avoid
automobile travel."
Page 4.9.11-16 generally describes Project Specific Mitigation Measures however, the main
tools included in the plan which assure mitigation are phasing and the development process
which in itself assures careful, incremental review and approval of projects. We would
recommend the discussion be expanded to include the following in the final EIR.
"This traffic analysis is oriented toward future traffic conditions at the full buildout
of the project. However, buildout will occur over a number of years and it will be
necessary to provide an adequate transportation system for interim periods of
development. The following paragraphs describe recommendations to deal with
the phasing of development and transportation improvements.
Primary regional transportation facilities which impact the project area are SR-
125 and regional transit service (light rail or express busr With these regional
transportation facilities in place, it will be feasible to imj:J'iement any major portion
of development. If some of the development is proposed to occur before regional
transportation facilities are implemented, project phasing will require that a local
transportation traffic phasing analysis be conducted to identify alternative
transportation mitigation measures which may be necessary.
Additional traffic analyses will be conducted to determine appropriate phasing of
transportation improvements as interim phases of project development occur. As
documented by the Transportation Phasing Plan (TPP) developed by Chula Vista
for the Eastern Territories area, trip patterns and traffic impacts may change
significantly in the course of project development. Thus, it will be important to
001689A
2~Y
QTAYRCH3IS4
~_"."...",,,,.......__--......_,,,,"_,,,,_.\_.~~,,,,,,_~-,,,,,,~~~"_,,____,_.._ .~__-__~__,__ ... ._n _~.____.." _ __,~~~___'__',_'__
Mr. Doug Reid
October 6, 1992
Urban Systems Associates, Inc.
adequately assess the impacts of the Otay Ranch project at various phases of
development. This will require the development of a comprehensive
transportation phasing program which would be coordinated with each phase of
land use development. This Otay Ranch Transportation Phasing Program will be
coordinated with the ECV TPP conducted by the City of Chula Vista. The
development and implementation of each SPA or village will receive a site-
specific traffic impact evaluation to identify the potential impacts to the current
transportation network and recommend appropriate mitigation to maintain high
quality service on the local system."
Thank you for the opportunity to comment on the DEIR. We look forward to the completion
of a Final EIR and hearings on this important project.
Sincerely,
qJ~.
Andrew P. Schlaefli
Vice President
APS/vks
cc: Greg Smith
Steve Doyle
I.
I
001689A
:~.:):) ~
3
OTAYRCH3154
-. _......__..._....;........_~~'" -....- -- ~.. --,. .~--,~-- - -~ - -- - .__.."~-- ~~-- ..-...--.--.-.
SWEETWATER AUTHORITY
505 GARRETT AVENUE
POST OFFice BOX 2328
CHULA VISTA. CALIFORNIA 91912-2328
(619) 420-1413
FAX.(619) 425-7469
October 2, 1992
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GOVERNING SOARO
SUE JARRETT, CHAIRMAN
suo POCKLlNGTON, VICE CHAIRMAN
WAYNE W. SMITH
EOWIN J. STEELE
GEORGE H. WATERS
MARGARET A. WELSH
CARY F. WRIGHT
WANOA AVERY
TREASURER
OIAN J. REEVES
SECRE'TARY.AOMINISTAATIVE Aloe
Mr. Douglas D. Reid
Otay Ranch Project Planning Office
315 Fourth Avenue
Chula Vista, CA 91910
Subject: DRAFT PROGRAM ENVIRONMENTAL IMPACT REPORT FOR OTAY RANCH,
JULY 31, 1992 (CASE NO: EIR-90-01)
SWEETNATER RESERVOIR URBAN RUNOFF PROTECTION
Dear Mr. Reid:
Sweetwater Authority has reviewed the July 1992 Draft Program
Environmental Impact Report for the proposed 23, 088-acre Otay
Ranch. We have the following comments and recommendations.
The Sweetwater Authority is a water purveyor in the South Bay area
of San Diego County serving National City, Bonita, and portions of
Chula vista. The Authority operates Sweetwater Reservoir and
Loveland Reservoir to store water for its customers and utilizes
the Sweetwater River to transfer water from Loveland Reservoir to
Sweetwater Reservoir. The entire otay Ranch project site is
located outside of the drainage basin of the Sweetwater Reservoir,
as well as outside the service area of Sweetwater Authority.
However, the "Jurisdictional Alternatives" discussion in Section
3.13.1.1, "Water Availability and Demand" includes alternatives
which would affect Sweetwater Authority. In addition, some of the
information on Sweetwater Authority which is presented in the
Environmental Impact Report is incorrect ~page 3.13-8, 4th
paragraph). The treatment plant as opposed,to the reservoir, as
stated in the Environmental Impact Report, has an existing design
capacity of 2Q million gallons per day (not 24 million gallons per
day as stated in the Environmental Impact Report). The total
storage capacity for the Sweetwater Reservoir is 28.088 acre feet
at elevation 239.0 mean sea level as opposed to 38 million gallons
per day stated in the Environmental Impact Report. The current
system average daily demand is approximately 20 million qallons per
dav. The 24 million gallons per day figure shown in the
Environmental Impact Report approximates the warm weather peak
demand experienced during recent drought years but has been as high
as 35 million gallons per day prior to 1989.
d~
A Public Agency.
Serving NationtJi City. Chuia Visia and Surruunding Areas
Mr. Douglas D. Reid
otay Ranch project Planning Office
Re: otay Ranch
October 2, 1992
page 2
As stated in the Environmental Impact Report (pages 2-25 and 2-26) ,
implementation of the proj ect would require amendments to the
Public Facilities Element of the Chula vista General Plan and the
Water provision System section of the Public Facility Element to
the San Diego county General Plan, although it has not been
determined how water service would be provided to the site. Two of
the "Jurisdictional Alternatives" described in this section would
be unacceptable to Sweetwater Authority.
The "city of Chula vista" alternative includes the South Bay
Irrigation District being made a subsidiary district to the city of
Chula Vista, thus providing the city with a reservoir and treatment
system, as well as a number of connections to the San Diego County
Water Authority aqueduct. The document further states that "to
provide water service to the project, the city would either have to
become a member of both the San Diego County Water Authority and
Metropolitan Water District or retain the Otay Water District or
South Bay Irrigation District as a wholesale agency for the otay
Ranch project to provide for membership in the San Diego County
Water Authority and Metropolitan Water District." Such an action
would be at the expense of the Authority's existing customers in
National City and Bonita and would require that the rights to water
service of our existing customers be subordinated to future
residents of the Otay Ranch.
The system, including dams, treatment plant and transmission and
distribution system belongs to the Sweetwater Authority. Making
the South Bay Irrigation District a subsidiary District to the City
of Chula vista would gain access to imported water but would not
gain the reservoir and treatment works. Purchase of Sweetwater
Authority would be required for access to the physical facilities.
This may not be possible without a vote of the voters in the
service area.
I
The "Sweetwater Authority" alternative recommends the annexation of
the project into the South Bay Irrigation District, and thus into
Sweetwater Authority's service area. This alternative would
require the extension of a major pipeline to the project property
which is at a location ranging from 3.5 to aver 13 miles from any
existing SWA facilities. Sweetwater Authority currently serves a
population of approximately 160,000 persons, distributing an
average of 20 million gallons per day. The Environmental Impact
Report estimates that the Otay Ranch population at build out would
be 149,810 persons (within 30 to 50 years), with the project
consuming water at an average rate of 40.2 million gallons per day.
This is twice the amount of water currently provided by Sweetwater
Authority. Providing service to otay Ranch would necessitate the
,Jy:.; ';
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_............_~::._~,~~.--...>--_________._.._h..._.h.__~_~____.h_. "_'~_'_"___'_____~_"'_~.""_"'- ._ _"___N'_N_"_''''-_ .
Mr. Douglas D. Reid
Otay Ranch Project Planning Office
Re: Otay Ranch
October 2, 1992
page 3
construction of major facilities, including a new treatment plant
and a pipeline to Loveland Reservoir. If this alternative were
implemented, the project proponent would be required to finance
these additional facilities required to service the project. The
estimated cost of these two facilities above could exceed
$100,000,000.00. Annexation to the Sweetwater Authority service
area, if approved, would add another $59,000,000.00 to the capital
requirements.
In summary, the Authority requests that the "City of Chula vista"
and "Sweetwater Authority" Jurisdictional Alternatives be included
as alternatives considered but rejected in favor of the "Preferred
Water Distribution " alternative.
Thank you for the opportunity to comment on the draft program
Environmental Impact Report. The Sweetwater Authority appreciates
your consideration of the above requested revisions to the
document. If you have any questions, please contact Ms. Troy Davis
at 420-1413, extension 244.
Very truly yours,
SWEETWATER AUTHORITY
Q~~
Chief Engineer
RAR:TD:le
i:\troy\wp51\letters\otayranc.ltr
pc:
Mr.
Ms.
Ms.
Mark Montijo, Jamul-Dulzura Community Planning Group
Andrea McGuire, San Diego Chapter'Director, Sierra Club
. . f .
Norma Sull~van, South County Env~ronmental Work~ng Group
d33
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Jamul, CA 91935
October 5, 1992
Otay Project Planning Office
ML Douglas Reed
315 4th Ave. Suite A.
Chula Vista, CA 91910
Re: Comments on Otay Ranch Environmental Impact Report
Dear Mr. Reed,
I live in Procter Valley, very close to the Nortern border of the Procter Valley
Parcel. My comments will focus on the impacts that will directly effect my
neighbors and my family. As a biologist, I will also point out impacts to the
wildlife and as a resident, to the degradation of my quality of life. I will keep my
comments confined to broad issues since, I hope, you were planning to have
more detailed analysis in subsequent site-specific documents.
First, I must comment that despite its massive size, your EIR lacks substance.
Although problems such as available water, urban runoff, and police protection
are described, solutions are not. It seems reasonable that you would not
. undertake this project without many of these unknowns being addressed. I
would like to see your EIR resubmitted, for a reasonable review period, with
substantial analysis of these concerns.
I do not believe a credible overview of environmental impacts would be
complete without a thorough map of wildlife corridors. The EIR only contains a
single map, with very little detail, for the entire Procter Valley parcel. I live near
the northern border, and suspect that the number of raptors in the area were
underestimated. I also feel your maps are misleading, in general, because
they fail to distinguish between individual animals (or plants) and
larger numbers in a small area. There needs to be a way to quantify which
areas have breeding pairs of animals and which have sij1gle individuals. You
have virtually ignored endangered reptiles. I feel surveys by a qualified
herpetologist are necessary for an environmental review,
Also, it is appropriate to have composite maps that correlate sightings with your
corridors. If the sightings do not support the location of your corridors, the
corridors are not properly sited. Also, your overlay maps are misleading. You
typically overlay sensitive habitat maps with either early phases of building or
more environmentally friendly plan alternatives. You should use your New
Town Plan, if you feel it is a good plan.
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. -. ~.,,~."~"-- -- .P ,_._ ".._ '..-.'~_~~_ ~ __"'__~__._______"_~___ - .._ ., ..- _'___._.. --____.." . ... .
--..------..----.-----. - .,. --..--- --. -- ..- --. ---- ----- ---. . .-.....---.-.--.. ...- ,.
Your corridor plan also does not correlate with those of surrounding plans. I
was informed by an Otay representative that a major wildlife corridor that bisects
the Hidden Valley Estates project adjascent to the Procter Valley parcel will not
connect to Otay's corridor system. He said that the corridor was of "low quality".
After speaking with Southwest Diversified, it appears that both Otay's and their
corridor studies were performed by Ogden Engineering, and they are
contradictory. The County biologists support this corridor extending to the .
Sweetwater reservoir. This illustrates the need for the County to be the lead
organization for management of the Otay Ranch open space, because we
cannot expect consistent information from the developer.
I would also like to express my outrage with Baldwin's agricultural uses of the
Procter Valley Parcel. The cattle have purposes other than raising revinue,
which must be minimal. They have grazed the Coastal Sage Scrub so that
Baldwin can classify itas all "disturbed" CSS. Also, it keeps tresspassers out,
which assures the locals cannot claim any of the land for trails and keeps
environmentalists from challenging the claims of the developers. Last, Baldwin
has insisted on running barbed wire fence to the edge of Procter Valley Road,
even though that ignores the full size of the road easement. It endangers
runners, bicyclists, or equestrians who want to use Procter Valley Road. It also
eliminates any safe road shoulder, making the road more dangerous for
motorists. This has been mentioned to Baldwin on several occasions, but they
choose to keep it there. Baldwin has not proven to be a very good neighbor in
the past. The locals should be apprehensive about living with Otay Ranch.
Last, I wish to state that the environmental review process for this project has
been a travesty. The idea that the review process started before the publication
of the EIR, and so a short review period for this 1000+ page document is
appropriate, is unjustifiable. The granting of lead agency status to the Chula
Vista City Council by the County has left my neighbors and myself without
representation. I feel that the City Council, County authorities, and the
developer have not worked responsibly. Perhaps you should start over, with a
desire to include the proper documentation, review period, lead agency, and
community input. It would lead to a better development.
Si",~
r <2~
Jay A. Haran, Ph.D.
c2LfD
-------
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DEPARTMENT OF BIOLOGY
COLLEGE OF SCIENCES
SAN DIEGO STATE UNIVERSITY
SAN DIEGO CA 92182-0057
October 1, 1992
(619) 594-6767
To whom it may concern,
My name is Mark Dodero, I am currently working on a Master's
degree in Systematic Botany at San Diego State University. As a native San
Diegan of 34 years, growing up in southern San Diego County, I have seen
the long term effects of development on the flora and fauna of this region.
I have had a deep interest in biology since my early childhood. Roaming
the canyons of the county (including the Otay Mesa-Proctor Valley area)
has allowed me to develop an understanding and appreciation of the
special habitat requirements of animals and plants that inhabit this region.
Over the years, I have watched as canyon after canyon has become
isolated by development, with the inevitable decline in species diversity.
This decline has not been limited to a single species or class, it has affected
everything from Black-shouldered Kites, cactus wrens, California
gnatcatchers, burrowing owls, and bobcats, to San Diego Horned Lizards,
Orange-throated whip tails, various snakes and even butterflies. Though
many of these canyons still have suitable habitat for sensitive species, the
fact that they have been isolated from other areas of appropriate habitat,
has resulted in a significant drop in species diversity. The detrimental
effects of habitat fragmentation have been well documented (Soule' et al.
Conservation Biology vol. 2, no. 1 1988). Elimination of large predators
such as coyotes disrupts the ecosystem, causing an increase in small
predators (including domestic cats). Over time, these smaller predators
eliminate bird and reptile species such as the California gnatcatcher and
San Diego horned lizard. Retaining wildlife corridors and buffer zones for
animal movement is absolutely essential to the longterm viability of
populations, and the maintainance of natural predjttor-prey interactions,
including top predators such as Golden eagles and'Mountain lions.
In 1991, ten state and federal agencies signed a Memorandum of
Understanding (MOU) to conserve California's biological diversity
(Hoshovsky Fremontia vol. 20, no. I 1992). This agreement laid the
groundwork for the development of an ecosystem approach to biological
conservation. Past conservation efforts have most often focused on the
preservation of individual species and this approach has not worked.
According to California Fish and Game's 1990 annual report on Significant
Natural Areas (SNAs), the Otay Ranch is the site of no less than 10 SNAs
including, but not limited to, areas of vernal pools, California gnatcatcher
-;)1/ /
THE CALIFORNIA STATE UNIVERSITY
and cactus wren habitat, Tecate cypress forests, and other rare plant.
habitat such a maritime succulent scrub. Maritime succulent scrub
vegetation is found no where else in the United States except southern San
Diego County and is in need of protection. It is obvious from reading the
Fish and Game report, the DEIR, and from many visits to the area over the
years, that the Otay Ranch area is a biological jewel unrivaled in coastal
southern San Diego County. This underscores the importance of developing
a well designed, integrated, series of habitat reserves with adequate buffer
zones to maintain the biological diversity of the area. The Otay Ranch
property gives us all a unique opportunity to work together to develop a
plan that can accomodate both people and wildlife.
From reading the DEIR, it is readily apparent that all of the Project
Alternatives except the Environmental Alternative are unacceptable and
unrealistic from a biological resource standpoint. The numerous significant
and unmitigable impacts to coastal sage and maritime succulent scrub,
wetlands, vernal pools, Cypress Forest, Oak woodlands and priority rare
plant species would ensure the loss of many populations of sensitive
animal and plant species and could ultimately lead to the extinction of the
Otay Mesa-mint (Pogogyne nudiuscula). The permanent loss of wildlife
corridors as projected for the New Town Plan and Phase I Plan would lead
to a drastic decline .in species diversity in the newly isolated canyons, a
fate seen all too often in coastal San Diego County.
In summary as proposed under the Environmental Alternative, all
significant wildlife corridors should remain open to ensure that animals
have the ability to move freely between canyons. Adequate buffer zones
should be left around wildlife habitat to reduce disturbance and to prevent
trampling of sensitive plant species. Establishing habitat reserves will give
the many sensitive species present on Otay Ranch a greater chance of long-
term survival. Thank you for your attention.
Sincerely, n (J .
-~uJ.~
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Mark W. Dodero
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DEPARTMENT OF BIOLOGY
COLLEGE OF SCIENCES
SAN DIEGO STATE UNIVERSITY
SAN DIEGO CA 92182-0057 ,U. S. A.
PHONE: (619) 594-7827
INTERNET: smcmilla%sunstroke@sdsu.e.du,
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(619) 594-6767
5 October 1992
OCT - c
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Douglas D. Reid
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
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Dear Mr. Reid:
My name is Scott McMillan and I am a graduate student at San Diego State University
working on the taxonomy, phylogeny, and biogeography of the genus Pogogyne. I have been
working on the genus for two years and have spent the last two seasons attempting to locate all
remaining localities of Pogogyne nudiuscula. Because of this, I feel that I am qualified to comment
on the status of Pogogyne nudiuscula, and the impact this project will have on the species.
In the past, Pogogyne nudiuscula has only been known to occur on Otay Mesa and in Valle
dellas Palmas, Mexico. Over the last year I have come up with good evidence that the population
in Mexico is a distinct species, and I am in the process of describing it as such. This means that
the only place in the world that Pogogyne nudiuscula is found is on Otay Mesa and if the
populations of Pogogyne nudiuscula on Otay Mesa are desuoyed, then the species will no longer
exist.
On page 3.3-81 of the Draft Environmental Impact Report (DEIR) for the Otay Ranch
General Development Plan, it states that Pogogyne nudiuscu/a would be lost from the largest
populations (J~23, J-24, and J-25) on Otay Mesa. It also states that the species would be retained
in the majority of the J-30 complex on Otay Mesa, but possibly threatened by proposed
development along the the southern perimeter near the J-30 pools. Finally it states that the number
of vernal pools with Pogogyne nudiuscu/a that would be developed is 80 out of 97 pools, or 82
percent. As far as Pogogyne nudiuscula is concerned, the J-25 pools are far more important than
the J-23 and J-24 pools, and the J-23 and J-24 pools are far more important than the J-29 and J-30
pools. In a rough estimate, I would say that over 90 percent of Pogogyne nudiuscula located
within the boundaries of this project are located in the J-25 pools. So, with the destruction of 82
percent of the vernal pools, there will be more than 90 percent destruction of the species found
within the boundaries of the project. If this occurs, the population in the J-29 and J-30 pools will
have incredibly low numbers, will have very low genetic diversity, and will be very isolated from
the only population outside the project. Once this happens, the J-2~ and J-30 pools are likely to
disappear completely. "
In my opinion, the only feasible alternative to the proposed plan is to either eliminate all
development being cU!Tently proposed, or to change the sites of development. If development is to
take place, it should not be on the J-23, J-24, or J-25 pools, because these pools represent the
majority of Pogogyne nudiuscula found within this project's boundaries. Development on the J-29
and J-30 pools would be far less damaging as far as Pogogyne nudiuscula is concerned.
If you have any questions concerning my comments, please feel free to contact me. Thank
you for your attention.
S incerel y , ,
jd/;~c(L~
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Scott McMillan
THE CALIFORNIA STATE UNIVERSITY
Pacific Southwest Biological Services, Inc.
Post Office Box 985, National City, California 91951.0985 . (619) 477.5333 . FAX (619) 477,1245
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OCT - 6
6 October 1992
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Olay Ranch Project Planning Office
Environmental Review Coordinator
315 Fourth Avenue, Suite A
Chula Visla CA 91910
Dear Mr. Reid:
Re: EIR 9O-D 1
Log # 89-14-98
SCH # 89010154
I have reviewed the draft EIR and appendices for the Otay Ranch project. The document is well organized
and I found it to reflect accurately the understanding I have regarding the biological resources in the region. As
you know, I was the original vernal survey biologist in the area and have been involved with many biological
assessments in the project area for clients other than the proj~t proponent.
Of the several on-site alternatives analyzed in the document, it is my opinion that either the Fourth
Alternative or the Project Team Alternative would be feasible plans to approve since they have equivalent,
acceptable biological impacts. The Environmental Alternative is also a desirable alternative but I do not think it
is a feasible alternative unless acquisition of proposed open space is funded by a conservation agency to compensate
for lost, developable acreage.
Table 4.10-1 is extremely useful in comparing the on-site alternatives. What would be of greater value
there, however, is having relative quantitative impact values given rather than just significant or non-significant
notations. This use of values was done in several of the biological impact assessment and this allows a much greater
confidence in understanding the relative impacts. Using significance thresholds does not prove very useful in
evaluating relative impacts.
I was very interested to see the off-site alterative assessments. Unlike most 'paper tiger' approaches, these
appear to have some credibility. Unfortunately several of our survey projects occur in these sites and the level of
planning in the alternative analysis conflicts with what our clients have proposed for their land. I don't think they
would be pleased to bave planners suggest land uses for their sites. I reali= these are preliminary analyses but too
often these documents are used out of context. This is something to consider in the future.
J.
J
CongratulatioDB on accomplishing the draft EIR effort. It has "= a epic effort and all the facts seem to
be out on the table for review.
Sincerely,
-??~
R. Mitchel Beauchamp
President
mdp/OT A YRNCH.
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ATTACHMENT B
SUMMARY OF PROPOSED PROJECT
AND PROJECT AL TERNA TIVES
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ATTACHMENT B
SUMMARY OF PROPOSED PROJECT
AND PROJECT ALTERNATIVES
Pronosed Proiect
Under the New Town Plan, 50,733 new residential dwelling units would be
constructed on 12,054 acres of the Otay Ranch property over a 30- to 50-year buildout
period (Table 1). Upon completion, approximately 149,810 new residents would occupy
the Otay Ranch development, for an average population density of approximately
12.5 persons per acre across the site. Fifteen villages would be situated on the property,
each composed of a mix of residential areas, neighborhood commercial uses, schools,
neighborhood parks and other community uses (i.e., churches, police stations, libraries or
civic uses). Villages would be interconnected by a comprehensive system of greenbelts
and open space containing a series of pedestrian walkways and bike paths. Linkages
would also be provided to major open space areas, regional parks, and commercial centers.
Five categories of increasing residential density are designated under the New
Town Plan, ranging from a low of 3 dwelling units per acre to a high of 27 dwelling units
per acre. Residential densities generally decrease eastward toward the rural communities of
Jamul and Dulzura, with the highest density residential areas occupying the Otay River
parcel. Approximately half of the Proctor Valley parcel would remain as open space, while
the balance of the parcel would be planned for lower density uses. Land uses within the
San Ysidro parcel are predominantly large-lot, low and low-medium residential densities.
Commercial development would occur at the neighborhood and regional scale
throughout Otay Ranch. Major commercial uses would be situated along the freeway and
major roadways. Two focal points of commercial activity would be the Town Center
development, along the northern shore of Lower Otay Lake, and the Eastern Urban Center,
along the freeway corridor on the Otay River parcel. Restaurants and commercial services
would predominate the Town Center. Regional shopping would be offered from the
Eastern Urban Center. Industrial land, supporting research and development and light
industrial use, would be located near the freeway and atop Otay Mesa. The university site
would be located west of Lower Otay Lake, in the vicinity of Salt Creek.
Parks and open space would complement development on Otay Ranch. As shown
in Table 1, 6,609 acres would be natural open space, while 357 acres would be
manufactured open space. Seven community parks, containing active recreational uses,
have been identified in the New Town Plan. Additional parkland would occur in
association with schools and golf-courses developed onsite.
Infrastructure improvements associated with the New Town Plan include the
installation of a comprehensive circulation network; public transit; pedestrian, bicycle, and
hiking trails; water distribution systems; sewer conveyance systems; and a runoff
protection system for the reservoirs. Three river crossings, including SR-125, are
proposed for the project. Public transit opportunities would be offered by light rail transit
and bus service available from development of the Otay River parcel. Linkages between
major traffic generators, such as the Eastern Urban Center, Town Center, University, and
commercial centers are planned to minimize vehicle use through the area.
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L Low
LM Low Medium
M Medium
MH Medium High
H High
Commercial
C Commercial
VC Visitor Commercial
RC Retail Commercial
Industrial
RI Research / lnd ustrial
Public & Open Space
PQ Public & Quasi Public
P Park and Recreation
Special Plan Area
EVC Eastern Urban Center
TC Town Center
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Land Use Designation
RESIDENTIAL2
Low
Low Medium
Medium
Medium High
High
Total Residential
COMMERCIAL
Retail Commercial
Visitor Commercial
INDUSTRIAL
Research Industrial
PUBLIC, QUASI- PUBLIC
AND PARKS
Public & Quasi Public
Parks and Recreation
EASTERN URBAN CENTER
Residential
Office
Regional Shopping
TOWN CENTER3
RURAL ESTATE PLANNED
COMMUNITY4
OPEN SPACE
Natural
Manufactured
FREEWAY
TOTALS
Residential
Density!
(du/ac)
0to3
3to6
6toII
11 to 18
18 to 27
Table 1
LAND USE STATISTICS FOR NEW TOWN PLAN
Otay River Proctor Valley San Ysidro Otay Ranch
Parcel Parcel Parcel Total
Dwelling Dwelling Dwelling Dwelling
Acres Units Acres Units Acres Units Acres Units
237 455
2,723 11,447
1,428 11,808
419 3,470
167 3.014
4,974 30,194
366
802
1,679 3,390
1,630 7,380
270 2,261
3,579 13,031
82
677 1,334
493 2,493
33 204
1,203 4,031
406 -- --
1,071 78 956
100 1,500 -- --
113 --
150 -
-- 163 795 --
1,235
357
44
9,618 31,694
4,013
7,915 13,826
I Based on Chula Vista General Plan density ranges.
2 Residential acreage includes adjacent slope and parkway /greenbelt areas.
3 half of Town Center acreage allocated to residential uses at 6 to 11 dWac.
4 Rural Estate Panned Community total acreage of 2,035 includes an estimated 825 acres of additional open space.
Source: Baldwin Vista, New Town Plan, 1989; as revised by Ogden, 1992.
2,035 1,182
1,361
5,555 5,213
2,593
5,179
4,846
21,320
1,731
14,273
419
3,470
167
3.014
9,756 47,256
366
82
802
406
2,105
100
1,500
113
150
163
795
2,035
1,182
6,609
357
44
23,088
50,733
Proiect Alternatives
CEQA requires an evaluation of alternatives to the proposed project which could
feasibly attain the basic project objectives while reducing or eliminating significant
environmental effects of the proposed project. Eight on-site alternatives to the New Town
Plan, including the No Project Alternative, were jointly developed by the Project Team in
cooperation with the Interjurisdictional Task Force and resource agencies; all eight are
addressed in the Draft EIR. The various alternatives represent a range of development
densities and land use planning options for the Otay Ranch property. Several similarities
exist among the land use characteristics of the project alternatives. Each alternative
proposes a mix of multi-and single-family residential uses; State Route-125 would be
extended north-south across Otay Ranch by Caltrans and Paseo RancherolHeritage Road
would cross the river valley; and a proposed water treatment plant would be located in the
Otay River Valley. The following table summarizes the number of dwelling units and
development acreage for the project alternatives.
Table 2
SUMMARY OF PROJECT ALTERNATIVES
Alternative
No. of
Dwelling Units
Acres of
Development
Phase II-Progress Plan Alternative
Phase I-Progress Plan Alternative
Fourth Alternative
Project Team Alternative
Composite General Plans Alternative
Low Density Alternative
Environmental Alternative
No Project Alternative
30,0591
29,773
27,418
24,064
20,470
10,287
9,251
o
10,4982
12,104
9,815
9,646
18,7773
9,631
6,107
o
1 Includes 1,151 dwelling units of future EastLake development.
2 Includes 169 acres of future EastLake development.
3 Coun1y General Plan does not include open space designation.
Below are descriptions of the various project alternatives as analyzed in the Draft
EIR:
Phase I1-Proll'ress Plan. The most recent land use plan developed for the Otay
Ranch property is the Phase II-Progress Plan Alternative. Under the Phase II-Progress
Plan Alternative, a maximum of 28,908 dwelling units would be constructed, resulting in a
population of approximately 83,980. An additional 1,151 dwelling units and
2,982 persons would be allowed on approximately 170 acres of development on the Otay
River parcel that will be transferred to EastLake for inclusion in a separate General
Development Plan (refer to Table 3 for details). The EastLake acreage and its associated
population was included in this alternative to enable the EIR to evaluate the same land area
(23,088 acres) as the other Otay Ranch project alternatives. In addition to residential
acreage, the EastLake portion of this alternative contains land designated for office,
freeway commercial, and open space use.
8-4
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Table 3
LAND USE STATISTICS
FOR PHASE II.PROGRESS PLAN
Otay River Proctor Valley San Ysidro Otay Ranch
Residential Parcel Parcel Parcel Total
Densily Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Units Acres Units Acres Units Acres Units
RESIDENTIAL
Very Low 0101 686 272 858 144 1,544 416
Low 1103 242 367 863 1,406 109 307 1,214 2080
Low-Medium 3106 2,435 10,561 348 924 197 535 2,980 12,020
Medium 6to 11 244 1,876 83 489 327 2,365
Medium-High 111018 556 7,358 105 1,181 36 508 697 9,047
Limited Developmenl Area --1.Q.2 --1l.li JlQ ....ll!i 1...ill. ---llQ
Subtotal Residential: 3,477 20,162 2,454 4,398 2,016 1,598 7,941 26,158
COMMERCIAL
; Freeway Commercial 77 77
\~ Mixed Usc' 270 86 150 23 379 150
v",\ INDUSTRIAL
~ Limited ManuIacluring 313 313
PUBLIC/QUASI-PUBLIC
Public Facilities 77 77
Schools 67 4 5 76"
PARKS 76 8 84***
EASTERN URBAN CENTER
Residential 70 2,600 N/A N/A 70 2,600
Commercial 45 45
Office 105 105
Public/Quasi-public 14 14
School 10 10
Park 45 45
RESORT 213 213
OPEN SPACE
Sensitive Resources Sludy Area 62 14 76
Manufactured 582 107 41 730
Scenic Corridor 812 26\ 34 1,107
Natural 3,212 4,768 3,422 11,402
FREEWAY -1li ---L.!l.l
Olay Ranch Subtotal: 9,449 22,762 7,915 4,548 5,555 \,598 22,919 28,908
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Table 3 (Continued)
LAND USE STATISTICS
FOR PHASE II.PROGRESS PLAN
Land Use Designation
Residential
Density
(du/ac)
Otay River
Parcel
Dwelling
Acres Units
Proctor Valley
Parcel
Dwelling
Acres Units
San Ysidro
Parcel
Dwelling
Acres Units
Otay Rancb
Total
Dwelling
Acres Units
EASTLAKE
Low-Medium Residential
Medium-High Residential
Higb Residential
Office
Freeway Commercial
Open Space
EastUlke Subtotal:
TOTALS
28
45
24
22
45
---2
169
9,618
72
596
483
N/A
N/A
5,555
1,598
28
45
24
22
45
----2
72
726
483
1,151
23,913
7,915
4,548
169
1,151
30,059
23,088
. Mixed use category varies by village and includes acreage for commercia~ communiLy purpose facilities and parkland.
.. Additiona1280 acres of schools combined wiLh mixed use and residential acreage.
... Additiona1122 acres of parks combined wiLh mixed use and residential acreage.
Source: FORMA Systems, 1992; as revised by Ogden, 1992.
The Phase II-Progress Plan falls between the Phase I-Progress Plan Alternative and
the Fourth Alternative in terms of developed area. Residential uses would be located on
8,038 acres, approximately 55 percent of the total being detached homes. Figure 2
illustrates land uses proposed for the Phase II-Progress Plan Alternative. Land uses would
generally be arranged in villages, with most of the proposed homes (23,913 residences)
located in the 12 villages on the Otay River parcel. The Proctor Valley parcel would feature
two villages, while the San Ysidro parcel would be developed with one village. Rural
estate development is also planned for the eastern parcels. An extensive open space system
and circulation system, including greenbelt parkways and hiking trails, would connect the
various development areas and parcels of Otay Ranch. A Resource Management Plan
(RMP), including a management preserve, would be implemented for this alternative.
The Otay River parcel would be dominated by the Eastern Vrban Center (EVC).
This mixed use area of 289 acres would fearure a wide variety of office-professional, retail
commercial, commercial, civic, cultural, park, and high density residential uses. Within
the EVC, pedestrian traffic would be encouraged by the close proximity and mixed nature
of the uses. The extension of the Light Rail Transit (LRT) line, which would run north to
south through the EVC, would also encourage non-vehicular travel. In general, villages
around the EVC would decrease in residential density with distance from the EVe. Each
village would be internally designed to encourage pedestrian traffic featuring mixed-use
village centers near the core. All villages would be connected by a system of paths and
trails.
Other major uses on the Otay River parcel would include a regional park in the Otay
River Valley and City of San Diego industrial land south of Otay River. The regional park
would be part of a 12,509-acre open space system for this alternative. A major four-year
university may locate in the far eastern portion of the Otay River parcel adjacent to Wueste
Road, although actual acreage has not been allocated under this land use plan. Should a
university site be identified on the parcel, the approval would require appropriate
discretionary action by the relevant jurisdiction and associated environmental review.
Land uses on the Proctor Valley parcel would generally be confined to three
geographically distinct areas arranged around the Jamul Mountains. These three areas
include the resort center village, Central Proctor Valley Village, and North Proctor Valley.
The resort center village consists of 793 acres and would include 2,438 homes and a
destination resort. This village would be located on the mesa northeast of Lower Otay
Lake. It is anticipated that the resort would be developed with a village concept, residential
neighborhoods being arranged around the resort. The Central Proctor Valley village would
be located in a gently rolling valley, bounded by San Miguel Mountain on the west and the
Jamul Mountains to the east. Residential densities would vary from low to low-medium to
medium, with one village center. Approximately 1,712 homes would be located in this
827 -acre village. A golf course or equestrian complex would be situated within this portion
of the project. The 1,104-acre North Proctor Valley area would allow for 398 residences.
Lots would be a minimum of 2 acres in size, with most areas featuring lots of 3-acre
average size. No villages would be located in this area.
Land uses on the San Ysidro parcel would be clustered in two distinct areas. A
small Estate Village would be located on the western portion of the parcel in a village of
approximately 1,350 homes located on 409 acres. A mixed-use village center would also
be situated near the residences. Circulation would be provided by rural roads, which
would attempt to follow natural topographic contours. The eastern portion of this parcel
would feature very low density residential intermingled with "limited development" on
steeper slopes. Residential densities would vary based on terrain, slope, and proximity to
developed areas; a lot minimum of 4 acres would be required in the northern region near
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HS High School
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Otay Lakes Road, minimum lot sizes increasing east and southward to approximately
8 acres in the more remote locations of the parcel near Dulzura.
Commercial and institutional uses, schools, and parks proposed in the Phase
II-Progress Plan Alternative would be distributed throughout the entire Otay Ranch. The
majority of commercial uses would be located in the EUC. Each of the 15 village centers
would also contain a small component of commercial, office, and quasi-public/public uses.
Freeway commercial would be situated on the Otay River parcel adjacent to SR-125.
The Phase II-Progress Plan Alternative proposes the allocation of 12,509 acres of
natural open space, encompassing the Otay River Valley, Jamul Mountains, and San
Y sidro Mountains. A RMP would be established to preserve and manage the resources and
ensure their viability. In addition, a system of paths and trails would connect the urban
villages and their parks, forming a passive and active recreation network throughout the
project.
The circulation system would feature an integrated system of prime arterials, major
roads, and collectors to maximize circulation efficiency. Three Otay River crossings would
be provided to carry traffic to and from Otay Mesa: SR-125, Heritage Road, and La Media
with reservation to provide a fourth crossing east of SR-125 (Alta Road), if necessary.
The roadway network would be supplemented by a system of paths and trails to encourage
bike and pedestrian uses. A public transit system (e.g., LRT, buses) would parallel
Telegraph Canyon Road and traverse the central portions of the Otay River parcel before
paralleling the southern extension of SR-125 through the Otay River Valley. These
pedestrian and public transit components would provide the project with alternative means
of transportation.
Phase I-Progress Plan. Under the Phase I-Progress Plan Alternative, a maximum
of 29,773 residential dwelling units (du) would be constructed on 8,250 acres of land
within the 23,088-acre site (Table 4). Adoption and implementation of this alternative
would result in approximately 86,456 new residents in the project area. Approximately
54 percent of the housing proposed under this alternative would be single-family
residences, while the remainder would be multifamily attached units. As illustrated in
Figure 3, the residential densities would vary across the site, although the majority of the
residences would be constructed within the II proposed villages on the Otay River parcel
at an average net density of 6.60 du/ac. The Proctor Valley parcel would be characterized
by low to medium density residential development, most of which would be single-family
detached homes at an average net density of 2.42 du/ac. Large lots, ranging in size from
0.33 to 2 acres and larger, and special grading criteria are proposed for those homes on
foothills and in the vicinity of the community of Jamul. Residential areas on the San
Ysidro parcel would consist mostly of low density uses and would be concentrated in the
western portion near Lower Otay Lake and in the eastern portion near Dulzura. Lots on the
San Ysidro parcel would range in size from 2 to 8 acres, with an area of medium density
residential development in the lake vicinity. The net residential density would average
0.88 du/ac on the San Ysidro parcel.
Commercial acreage, industrial development (i.e., business park and limited
industrial), schools/public facilities, park/recreation facilities, and "Special Plan Areas" may
encompass an additional 1,817 acres of development. A majority of the commercial land
uses would be concentrated in the Eastern Urban Center on the Otay River parcel, with San
Y sidro featuring a small pocket of commercial development in a village center near Lower
Otay Lake. Thirteen village centers, featuring mixed uses, elementary schools, and
neighborhood parks are planned under this alternative. The village centers, Eastern Urban
8-9
::);If
Table 4
LAND USE STATISTICS
.'OR PHASE I-PROGRESS PLAN
Otay River Proctor Valley San Ysidro Otay Rancb
Residential Parcel Parcel Pa,rcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Units Acres Units Acres Units Acres Units
RESIDENTIAL
Single Family 2,349 1,512 627 4,488
Multifamily 693 190 57 940
Special Grading Criteria 582 781 1,363
Restricted Development - 414 -2.l8. l.11l
Total Residential: 3,042 18,491 2,698 6,358 2,423 2,324 8,163 27,173
COMMERCIAL
Retail Commercial 100 100
Freeway Commercial 112 112
) INDUSTRIAL
'r.(' Research Industrial 280 280
c " Limited Manufacturing 26 26
0~~\
\ Business Park 106 106
PUBLIC/QUASI-PUBLIC
Public Facilities/Schools 300 10 310
PARKS/SQUARES 166 27 193
EASTERN URBAN CENTER
Residential 87 2,600 87 2,600
Retail Commerica1 203 203
Parks 15 15
RESORT 151 151
CONFERENCE CENTER 19 19
SPECIAL STUDY AREA (Ranch House) 132 132
OPEN SPACE
Vemal Pool Study Area 50 50
Man-made 1,591 383 13 1,987
Naruml 3,420 4,482 3,082 10,984
FREEWAY --1l.Q ---1.l!!
TOTALS 9,618 21,091 7,915 6,358 5,555 2,324 23,088 29,773
Source: Robert Bein, William Frost & Associates 1991; as revised by Ogden, 1992
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Open Space
I I Man Made Open Space
~ Restricted Development
1:::::::::::::1 Vernal Pool Study Area
~ Special Study Area
* Potential Active
Recreational Areas
Residential
SF Single Family
MF Multiple Family
SFg Special Grading Criteria
MFVC Multiple Family jVillage Center
Commercial
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Industrial
BP Business Park
Isd City of San Diego Industrial
I Limited Manufacturing
Pu blic & Open Space
HS High School
JH Junior High School
CP Community Park
PR Park & Ride facility
WS Water Storage
PQ Public/Quasi-Public
Special Plan Area
EUC Eastern Urban Center
R Resort
CC Conference Center
VC Village Center
...... .
Hwy 125
Parkway
Transit corridor
Primary arterials
Otay Ranch property
FIGURE
3
I
Center, Proctor Valley resort, and conference center uses are "Special Plan Areas" under
the Phase I-Progress Plan Alternative.
To balance the developed portions of the site, this alternative also proposes the
preservation of 10,984 acres of undeveloped open space encompassing the Otay River
Valley, San Ysidro Mountains, and Jamul Mountains. A resource management plan would
be implemented for this alternative. Fifty acres have also been identified as a vernal pool
study area near Lower Otay Lake. Several community and neighborhood parks would
supplement the natural open space and trail system with active recreation areas, including
parkland within the Otay Valley Regional Park. Man-made open space, composed of
parkway and greenbelts, would be integrated into the trail system. A potential university
site has been identified adjacent to the Olympic Training Center and the western shore of
Lower Otay Lake; the exact acreage and configuration would be determined in the future.
Approval of a university would require discretionary action by the relevant jurisdiction and
associated environmental review. Future studies are proposed under the Phase I-Progress
Plan Alternative to evaluate potential uses for the rock quarry site upon facility closure, the
university site, western developable area on the San Y sidro parcel, and to identify
appropriate uses for central Proctor Valley and the Ranch House Estate. These studies
would also involve environmental review at some later stage.
The circulation plan for the Phase I-Progress Plan features a series of prime
arterials, major roads, and collectors. Four Otay River Valley crossings, including SR-
125, La Media Road, Heritage Road, and Alta Road through O'Neal Canyon would
provide regional access from the Otay Ranch property to the Otay Mesa industrial area. To
supplement the roadway network, a transit corridor is planned along the SR-125 corridor
and Telegraph Canyon Road.
Fourth Alternative. The Fourth Alternative developed for the Otay Ranch
represents a more moderate overall level of development than the New Town Plan and
Phase I-Progress Plan alternatives (Table 5). The "Fourth" Alternative was so named
because it was the fourth alternative to be developed by the Otay Ranch Project Team for
analysis in the EIR. Development under the Fourth Alternative would result in a maximum
of 27,418 residential units on 7,120 acres of land, resulting in a population increase of
approximately 80,408 persons. Approximately 50.7 percent of the housing would be
single-family detached units, while the remaining 49.3 percent would be attached
multifamily units. As illustrated in Figure 4, the majority of the residences
(16,691 units), including those in medium-high and high density categories, would be
situated on the Otay River parcel. Approximately two-thirds of the residential development
would be multifamily housing. This alternative would not include a university. There
would be four roads across the Otay River Valley.
Under the Fourth Alternative, the Proctor Valley and San Ysidro parcels would
devote most of this residential acreage to the low density category, resulting in an average
net density of 2.63 du/ac and 1.43 dulac, respectively. On the Proctor Valley parcel,
clusters of higher density residential development would occur in a village center, near the
center of Proctor Valley and the northwestern property boundary, and in a village center
above the northern shore of Lower Otay Lake. Larger residential lots (0.25 to 0.5 dwelling
units per acre) would be situated in the vicinity of Jamul. Only a small amount of acreage,
55 acres on the San Ysidro parcel, would be planned for medium density residential.
Otherwise, large lots (0.25 to 0.5 dwelling units per acre) would predominate in the eastern
portions of the property.
In addition to the residential component of the project, approximately 1,539 acres
of the property would contain commercial, industrial, and public/quasi-public uses such as
8-12
'1(,'/7
~_Y.j !
Table 5
LAND USE STATISTICS
FOR FOURTH ALTERNATIVE
Otay River Proctor Valley San Ysidro Otay Ranch
Residential Parcel Parcel Parcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Unils Acres Units Acres Unils Acres Units
RESIDENTIAL
Low Ot03 681 1,292 967 834 1,623 980 3,271 3,106
Low Medium 3106 1,361 5,391 727 3,438 416 1,962 2,504 10,791
Medium 6 to 11 774 4,768 83 697 55 416 912 5,881
Medium High 11 to 18 433 5,240 433 5,240
High 18-27 -- n -
- -
Tola! Residential 3,249 16,691 1,777 4,969 2,094 3,358 7,120 25,018
COMMERCIAL
Retail 90 20 12 122
\~ Freeway 165 165
'," \ INDUSTRIAL
'-~'\ General IndusLrial 324 324
Research IndusLrial 112 112
PUBLIC/QUASI-PUBLIC
Public Facilities/Schools 318 25 10 353
PARKS/SQUARES 240 50 25 315
EASTERN URBAN CENTER
Residential 175 2,400 175 2,400
Retail Commercial 148 148
RESORT 222 222
CONFERENCE CENTER 154 154
OPEN SPACE
Narural 4,441 5,562 3,270 13,273
Manufactured 270 105 144 519
Freeway ----B..Q ~
TOTALS 9,618 19,091 7,915 4,969 5,555 3,358 23,088 27,418
Source: Robert 8ein, William Frost & Associates, Project Team Land Use A'lernatjve~ - Owy Ranch, 1990, as revised by Ogden, 1992
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Residential
L3 Low 3
12 Low 2
11 Low!
L Low
1M Low Medium
M Medium
MH Medium High
H High
Commercial
RC Retail Commercial
FC Freeway Commercial
Ind ustrial
RD Research/Development
Isd City of San Diego Industrial
I Limited Manufacturing
Public & Open Space
PQ Public & Quasi Public
HS High School
JH Junior High School
ES Elementary School
NP Neighborhood Park
CP Community Park
Special Plan Area
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R Resort
CC Conference Center
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Parkway
Transit corridor
Primary arterials
trAil Way
Otay Ranch property
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Fourth Alternative
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schools and parks. As in the other project alternatives, four special plan areas are defined
under the Fourth Alternative: the Eastern Urban Center, Proctor Valley resort along
northern Lower Otay Lake, Proctor Valley conference centers at the Ranch House and in
the foothills of the Jamul Mountains, and various village centers. Commercial uses would
be distributed throughout the Otay River parcel and concentrated in the Eastern Urban
Center, where a regional shopping center is planned. Two small areas of commercial
development are planned, one near the center of the Proctor Valley parcel to service the
nearby residents and the other to service the residential development north of the lakeshore.
Commercial acreage in the San Y sidro parcel is limited to the high density cluster near the
eastern arm of the lake. Twelve elementary school sites, two junior high school sites, and
a single high school site are proposed under this alternative, the majority of which would
be situated on the Otay River parcel. A second high school site has been identified for an
outparcel owned by the FAA. No university site occurs under this alternative.
The remaining 13,273 acres of the Otay Ranch property, (over one-half of the site)
would be retained as open space, featuring passive recreation and resource management
areas in the Otay River Valley, Jamul Mountains, and San Ysidro Mountains. A resource
management plan would be implemented for this alternative. All greenbelt areas between
land uses and connecting open space areas, recreation facilities, and villages would be
approximately 300 feet in width. Several community and neighborhood parks would
supplement the natural open space and trail system with active recreation facilities in close
proximity to the villages.
The circulation network would be composed of a series of primary, major, and
collector roadways and the southern extension of SR-125, which would form four
interchanges with the freeway and four north-south crossings of the Otay River. The four
proposed river crossings are SR-125, Otay Lakes Road, Hunte Parkway, and Alta Road.
In addition to the eastern extensions of East "H" Street, East Orange Avenue, and Otay
Valley Road, Otay Lakes Road would be realigned under this alternative and an existing
segment along the northern lakeshore would be closed to automobile traffic and maintained
for pedestrian use only. The alignment of Proctor Valley Road would be adjusted slightly.
An access road around the southern tip of Lower Otay Lake, South Dam Road, is
preliminarily proposed and may only be constructed if warranted by the traffic analysis.
The regional transit corridor would extend from the City of Chula Vista along Telegraph
Canyon Road, and would circulate east and south along the local street network, linking the
various villages, commercial uses, industrial development, and Eastern Urban Center on
the Otay River parcel. The transit corridor would only parallel the freeway near the
southern edge of the Otay River Valley; a transit-oriented village is proposed along this
corridor.
Proiect Team Alternative. The Project Team Alternative also represents a moderate
level of development on the Otay Ranch property. Approximately 6,317 acres of land
would support the development of a maximum of 24,064 residential dwelling units for an
estimated population increase of 67,046 residents. The Project Team Alternative differs
from the others mainly on its emphasis on multifamily residences (i.e., 60.4 percent of the
total) and reliance on clustering. Proportionally, this alternative places more dwelling units
on the Otay River parcel and fewer on the two eastern parcels. Approximately 39.6 percent
of the units proposed under this alternative would be single-family homes. In general, a
full range of residential densities would occur on the Otay River parcel, density being
higher there than on the other two parcels (Table 6). A majority of the Otay River parcel
units would be located near SR-125, (Figure 5) and the net residential density on the Otay
River parcel would average 8.04 du/ac. Residential uses would be arranged in villages,
each with its own mixed use village center. Low density residential uses would surround
the periphery of Wolf Canyon on the Otay River parcel, occur on the foothills of the Jamul
B-15
--~U\
Table 6
LAND USE STATISTICS
FOR PROJECT TEAM ALTERNATIVE
Otay River Proctor Valley San Ysidro Otay Ranch
Residential Parcel Parcel Parcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Units Acres Units Acres Units Acres Units
RESIDENTIAL
Low 0103 675 1,076 1,658 1,809 2,102 1,030 4,435 3,915
Low Medium 3106 749 3,351 308 1,426 73 315 1,130 5,092
Medium 6 to 11 354 2,497 7 68 56 416 417 2,981
Medium High 111018 524 6,616 524 6,616
High 18-27 144 .2.22Q - - --1.11 3960
Total Residential 2,446 17 ,500 1,973 3,303 2,231 1,761 6,650 22,564
OFFlCE"COMMERCIAL
Retail Coounerical 88 7 12 107
Freeway Conunerical 61 61
~., INDUSTRIAL
General Industrial 222 222
!~-. Research Industrial 152 152
.~ Limited Manufacturing 169 169
PUBLIC/QUASI-PUBLIC
Public Facilities/Schools 244 24 10 278
University Site 384 384
PARKS/SQUARES 215 37 16 268
EASTERN URBAN CENTER
Residential 55 1,500 55 1,500
Retail Coounerical 76 76
General Office 100 100
Park 30 30
PubliclQuasi-Public 25 25
RESORT 236 236
CONFERENCE CENTER 161 161
OPEN SPACE
Natural 4,747 5,415 3,280 13,442
Manufactured 518 62 6 586
FREEWAY ---.-lii! ---.-lii!
TOTALS 9,618 19,000 7,915 3,303 5,555 1,761 23,088 24,064
Source: Robert 8ein, William Frost & Associates, Project Team Land Use Alternatives- Ulay Ranch, 1990; as revised by Og.un, /992
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Parkway
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Otay Ranch property
F I (; l! R I,:
5
I
Mountains on the Proctor Valley parcel, and in the foothills and eastern portions of the San
Ysidro parcel. Large lots (2 to 4 acres) would be planned in the vicinity of the existing
Jamul community (for a net residential density of 1.75 du/ac) and on the eastern portions of
the San Ysidro parcel, near Dulzura (for a net residential density of 0.75 du/ac). A
greenbelt area or wildlife corridor would separate the low density residential from the
moderate use areas in both cases.
To complete the community under the Project Team Alternative, the land use plan
proposes 2,355 acres of non-residential development, including commercial, industrial,
and public/quasi-public uses (i.e., schools and park/recreation acreage). The majority of
the commercial uses would be distributed among several village centers throughout the
Gtay River parcel and occur within two small parcels (approximately 10 acres each) on the
Proctor Valley and San Y sidro parcels, respectively. In addition to the industrial area
designated by the City of San Diego for property south of the Gtay River Valley, the Gtay
River parcel would also support limited manufacturing/industrial land uses in the
southwestern comer, adjacent to the Gtay Landfill, and research and development uses in
the central portion of the parcel. A 384-acre university site is proposed between the
research industrial area and the northern edge of the Gtay River Valley, west of Salt Creek.
Public facilities proposed under this alternative include 11 elementary schools and 2 junior
high schools. A high school site is planned on an outparcel which is currently owned by
the FAA.
As noted in Table 6, 268 acres of this alternative are devoted to community and
neighborhood parks, and approximately 14,028 acres to natural and man-made open space
uses, including passive recreation areas. The majority of the open space proposed under
this alternative (13,442 acres) would be placed in a managed preserve with implementation
of a resource management plan. A botanical garden would be developed in the community
park alongside the Salt Creek open space. An extensive greenbelt system (composed of
man-made open space and parkways) along most of the arterial roadways would link all
portions of the Gtay River parcel and open space areas.
Five special plan areas are identified under the Project Team Alternative: Eastern
Urban Center, Proctor Valley resort, Proctor Valley conference center, Village Centers, and
potential active recreation areas within the Gtay River Valley. The Eastern Urban Center
would comprise 286 acres of mixed, but predominantly high density residential, uses
located in the center of the Gtay River parcel. The resort is planned for two locations along
the northern shore of Lower Gtay Lake, south of Gtay Lakes Road. The resort would
contain a medium to low-density golf course community, a tourist-oriented commercial
center, and rural residential area. The conference center would be situated at the same
location as in the Phase I-Progress Plan, Fourth, Low Density, and New Town Plan
alternatives. The village centers would feature mixed residential, civic, and commercial
uses. Four active recreation areas would be situated in the Gtay River Valley.
The circulation plan of the Project Team Alternative proposes a series of prime
arterials and major and collector roadways to provide access to the entire site (Figure 5).
Four crossings of the Gtay River Valley are proposed and include extensions of SR-125
and Heritage Road and two new roadways, Alta Road and La Media Road. An additional
roadway, "A" Way, is potentially proposed south of Lower Gtay Lake to provide access
between the Gtay River and San Y sidro parcels. This access will only be constructed if the
detailed traffic analysis identifies a need for the roadway. As with other project
alternatives, a transit corridor is designated on the Gtay River parcel to supplement the
proposed roadway network. The corridor would run from western Telegraph Canyon
Road through two village centers east of the freeway, freeway commercial areas, Eastern
Urban Center, university site, and research industrial area. The transit corridor would link
B-18
". i ::,
.-c.)r; ~
to the SR-125 alignment near the southern slopes of the river valley before entering the
Otay Mesa industrial area. The proposed villages are arranged to maximize transit use
opportunities.
Com DO site General Plans Alternative. Development of the Otay Ranch property
under the Composite General Plans Alternative would utilize the land use designations
within the City of Chula Vista Eastern Territories Plan, the County of San Diego Otay and
Jamul-Dulzura Subregional Plans, and the City of San Diego Otay Mesa Community Plan
(Table 7 and Figure 6). Development of the Otay River parcel would be governed by the
policies and provisions of the City of Chula Vista and City of San Diego, while both
eastern parcels would be subject to County of San Diego plans and policies.
Implementation of the City of Chula Vista land use designations on the Otay River parcel
would allow for up to 12,112 single-family residences (70.9 percent of total) and
4,971 multifamily units. The county's land use designations on the Proctor Valley and
San Ysidro parcels would result in the construction of a maximum of 3,387 single-family
residences. The City of San Diego land use plans do not include a residential component
for the project area. Overall, buildout of this alternative would involve a maximum of
20,470 dwelling units at an average net density of 0.85 dulac, and generate approximately
62,487 additional residents in the southern San Diego County area. Approximately
80.6 percent of the homes would be single-family, while the balance would be multifamily
residences. The majority of the residences and the higher development densities would
occur on the Otay River parcel, at an average net density of 4.2 dulac, in comparison to the
0.12 dulac density on the eastern parcels. Higher density uses would be concentrated in
the center of the parcel, with low density (0-3 dulac) development on the northern slopes of
the Otay River Valley. It is assumed that amendments to the County of San Diego and City
of Chula Vista general plans would not be required for this alternative.
The county land use designations only allow for residential development on the San
Ysidro and Proctor Valley parcels, but the cities of San Diego and Chula Vista provide
acreage dedicated to non-residential use to service residences on the Otay River parcel.
Approximately 1,521 acres onsite would be devoted to commercial, industrial/office, and
public/quasi-public uses. Within the Eastern Urban Center of the Eastern Territories Plan,
professional and administrative commercial (offices) and retail uses are planned. Research
and limited manufacturing uses are proposed adjacent to the freeway and a 160-acre
university site. Additional industrial lands are planned on the Otay Mesa portion within the
City of San Diego; Public uses associated with the Chula Vista plan include three
elementary school sites, a single junior high school site, and a high school site.
Community and neighborhood parks are distributed throughout the Otay River parcel.
The undeveloped 4,311 acres of this alternative, located on the Otay River parcel,
would be left as open space, including the Otay River Valley and the Salt Creek area.
Agriculture would occupy 226 acres onsite. The Composite General Plans Alternative
does not preserve open space in the eastern parcels. A greenbelt trail system is proposed
under the City of Chula Vista General Plan through the Otay River Valley, the Salt Creek
drainage, and up to the southern shore of Lower Otay Lake. No trail system is proposed
beyond the lake under the county General Plan. Plans for the Otay Valley Regional Park
would continue evolving and be implemented during buildout. A separate comprehensive
resource management plan would not be adopted to conserve and manage sensitive
biological and cultural resources onsite. Resources on portions of the alternative within the
eastern parcels would be protected by the Multiple Species, Wildlife, and Open Space Plan
currently being prepared by the County.
The roadway network on the Otay River parcel includes two river valley crossings,
one by SR-125 and the other would be Heritage Road. Eastern extensions of Orange
8-19
._~/H
_/ljT
Table 7
LAND USE STATISTICS FOR
COMPOSITE GENERAL PLANS ALTERNATIVE
Otay River Proctor Valley San Ysidro Otay Ranch
Residential Parcel Parcel Parcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Units ALTCS Units Acres Units Acres Units
RESIDENTIAL
Multiple Rural 1 du/4-8-20 ae 7,483 1,870 5,555 1,389 13,038 3,259
Estate 1 du/l-4 ae 255 128 255 128
Low o to 3 1,151 3,453 1,151 3,453
Low Mcdiuro 3 t06 1,498 8,988 1,498 8,988
Mcdiuro 6 to II 282 3,102 282 3,102
Medium High 11 to 18
0 High 18-27 - -- --
- -
Total Residential: 2,931 15,543 7,738 1,998 5,555 1,389 16,224 18,930
COMMERCIALIOFFICE
Retail Commercial 25 25
General Office 17 17
INDUSTRIAL
Research Industrial 541 541
General Industrial 358 358
PUBLIC, QUASI-PUBLIC
AND PARKS
Public & Quasi Public 309 20 329
Parks and Recreation 772 772
EASTERN URBAN CENTER
Residential 34 1,540 34 1,540
Retail Commerical 100 100
General Office 151 151
AGRICULTURE 69 157 226
OPEN SPACE Dll 4,311
TOTALS 9,618 17,083 7,915 1,998 5,555 1,389 23,088 20,470
Source: City ofChula Vista (1990) and COWlty of San Diego (1984); as revised by Ogden /1)92.
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L Low
Ul Low Medium
M Medium
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Commercial
RC Retail Commercial
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Ind ustrial
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Public & Open Space
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P /SP PUblic/Semi-Public
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Special Plan Area
EUC Eastern Urban Center
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.......
Hwy 125
Parkway
Transit corridor
Primary arterials
Otay Ranch property
--
I
Avenue and Dtay Valley Road would provide circulation on the Dtay River parcel. No
alignments have been identified for local roadways accessing the eastern parcels; however,
roadway improvements on the San Ysidro and Proctor Valley parcels would follow county
standards. Otay Lakes and Proctor Valley roads would not be realigned, and an access
road would not be constructed around the southern shore of Lower Dtay Lake. Roadway
improvements within the City of San Diego industrial area, as adopted in the community
plan, would include Dtay Valley Road and widening of Lonestar Road, and similar
facilities.
Low Densitv Alternative. Adoption of this alternative would result in 7,423 acres
ofresidential development and allow for a maximum of 10,287 dwelling units at an overall
density of 0.44 du/ac. The local population would increase by approximately 32,544
residents upon buildout of the Low Density Alternative (Table 8). Approximately
87.9 percent of the new units would be single-family, while the remaining 12.1 percent
would be multifamily units. This alternative emphasizes single-family residential and
represents the second lowest development density of the project alternatives evaluated in
this document.
In comparison to the eastern parcels, residential densities would be higher on the
Otay River parcel (Figure 7) and would result in an average net density of 3.06 du/ac.
Moderate density residential would be situated in the center of the Dtay River parcel and in
the vicinity of the freeway. A majority of the peripheral residential areas would feature low
density development (up to 3 du/ac). No land would be dedicated to medium-high or high
density residential use anywhere onsite and no residences would be situated in the Eastern
Urban Center. Residential areas throughout the Proctor Valley parcel would be
characterized by large lots (I to 2 acres), slightly decreasing in size in the vicinity of Jamul
(I to 4 acre minimums). This same pattern of large residential lots would be present above
the northern shore of Lower Otay Lake, resulting in an average net density across the parcel
of 0.53 du/ac. The San Ysidro parcel would also feature rural, large lot residential
development under this alternative (at an average net density of 0.29 du/ac). The
fundamental difference between this land use pattern and the New Town Plan, Phase 1-
Progress Plan, Fourth and Project Team alternatives is that the residential areas would not
be arranged in villages. The densities would be too low to make such an arrangement
feasible.
Commercial and industrial land uses are reduced in size under this alternative
compared to other alternatives and represent approximately 911 acres of the development
on the property. A majority of the commercial acreage is contained in the Eastern Urban
Center, near the center of the Dtay River parcel. The remaining commercial acreage is
distributed among several small areas across the Dray River parcel and at a single location
within the Proctor Valley and San Ysidro parcels. In addition to the industrial lands on
Dtay Mesa, limited manufacturing uses are planned in the vicinity of the industrial area
along Otay Valley Road near the landfill. The research and development uses would occur
in the center of the Dtay River parcel, near the East Drange Avenue interchange with
SR-125. The remaining non-residential acreage would be devoted to schools, parks, and
other public/quasi-public facilities. The Low Density Alternative proposes five elementary
school sites and one junior high school site on the Dtay River parcel. A high school site is
proposed on the property currently occupied by the FAA. No school acreage is planned for
the eastern parcels. Seven neighborhood parks and three community parks are planned
under this alternative, a majority of which would be located on the Dray River parcel.
Along with the Eastern Urban Center, the Proctor Valley resort and conference
center are identified as special plan areas for future planning studies. As under other
project alternatives, the resort would be located along the northern shore of Lower Otay
8-22
. -)t~(
Table 8
LAND USE STATISTICS FOR
LOW DENSITY ALTERNATIVE
Otay River Proctor Valley San Y sidro Otay Raneh
Residential Parcel Parcel Parcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (dujac) Acres Units Acres Units Acres Units Acres Units
RESIDENTIAL
Low Ot03 2,086 3,186 1,871 1,013 2,112 681 6,069 4,880
Low Medium 3t06 1,163 4,158 1,163 4,158
Medium 61011 191 1,249 191 1,249
Medium High lito 18
High 18-27 - -- -
-
Total Residential 3,440 8,593 1,871 1,013 2,112 681 7,423 10,287
COMMERCIAL
Freeway 63 63
Retail 86 17 12 115
INDUSTRIAL
U Limited Manufacturing 385 385
f~ Research Industrial 140 140
(~,~,
PUBLIC/QUASI-PUBLIC
Public Facilities;Schools 191 191
University Site 213 213
PARKS/SQUARES 138 19 7 164
EASTERN URBAN CENTER
Retail Commercial 208 208
RESORT 203 203
CONFERENCE CENTER 160 160
OPEN SPACE
Natural 4,448 5,588 3,421 13,457
Manufactured 215 57 3 275
FREEWAY ---2...l ---2...l
TOTALS 9,6]8 8,593 7,915 1,013 5,555 681 23,088 10,287
Source: Roberl 8ein. William Frost & Associ.::ltt's, Project Team Land Use Alternatives- ()tay Ranch, /990.- as revised by Ogden 1992
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Residential
1.3 Low 3
I2 Low 2
Ll Low 1
L Low
LM Low Medium
M Medium
MH Medium High
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Commercial
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Industrial
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Public & Open Space
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HS High School
JH Junior High School
ES Elementary School
NP Neighborhood Park
CP Community Park
Special Plan Area
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R Resort
CC Conference Center
.......
Hwy 125
Parkway
Transit corridor
Primary arterials
"A" Way
Otay Ranch property
I
Lake. Two conference center locations are identified, a smaller one in a narrow drainage of
the Jamul Mountains and a second on the property of the Ranch House. The smaller site is
the same conference center location proposed in the New Town Plan, Project Team,
Fourth, and Environmental alternatives. In addition, a 213-acre site for a community
college or private university is identified near the Salt Creek open space.
The remaining undeveloped portion of the Low Density Alternative, 13,457 acres,
would be dedicated to natural open space. The open space system would link the Otay
River Valley, San Ysidro mountain area, and the Jamul Mountains. As in the other project
alternatives, a greenbelt system between the developed areas is proposed to connect the
natural areas with the local park facilities and residential areas, and a trail system travels
throughout the open space. No resource management plan would be adopted to protect the
resources within natural open space, since the lower densities would not make such a plan
feasible. Instead, the County's Multiple Species, Wildlife, and Open Space Plan would
protect the resources of Otay Ranch.
The circulation system of the Low Density Alternative would be composed of
primary and major roadways interconnected with smaller collector streets. Three Otay
River Valley crossings are planned and include SR-125. Hunte Parkway, and Heritage
Roadway. The eastern extensions of Telegraph Canyon, Orange Avenue, and Otay Valley
Road would form interchanges with the freeway on the Otay Ranch property. Otay Lakes
Road would be realigned to a more northerly location, while the segment along the
lakeshore would be dedicated to pedestrian use through the resort. An access road around
the southern tip of Lower Otay Lake, "A" Way, is preliminarily proposed if traffic analyses
indicate that it is necessary for local circulation. The transit corridor would strictly parallel
the freeway the entire length through the Otay River parcel, rather than traversing through
residential, commercial, and industrial lands.
Environmental Alternative. This alternative was developed to minimize
environmental impacts of the proposed project, especially effects on steep slopes (greater
than 25 percent) and sensitive biological and archaeological resources. In comparison to
other project alternatives, the Environmental Alternative would result in the lowest gross
density. Adoption of this alternative would result in 4,553 acres of residential
development and allow for a maximum of 9,251 dwelling units at an overall density of
0040 du/ac (Table 9). The local population would increase by 28,863 residents upon
buildout of the Environmental Alternative. Approximately 7304 percent of the homes
would be single-family detached units, while the remainder would be multifamily attached
units. As illustrated in Figure 8, a majority of the residential units would be situated on the
Otay River parcel and developed in clusters of low, low-medium, and medium densities
(average net density of 4.15 du/ac). No residential units would be located in the Eastern
Urban Center. Development on the Proctor Valley parcel would be restricted to an area of
large lot single-family residential (0.5 to I du/ac) above Lower Otay Lake and a small area
of low density residential adjacent to the community of Jamul, making for an average net
density of 0.38 dulac. Large lot single-family development on the San Y sidro parcel would
occur at an average residential net density of 0.33 du/ac and be restricted to the northeastern
portion of the property. Residences would not be arranged in villages.
Under the Environmental Alternative, 16,981 acres of the 23,088 acre property
would remain as open space, including the San Ysidro and Jamul Mountains areas. Many
of the open space areas are characterized by slopes over 25 percent. A large portion of the
Proctor Valley and San Ysidro parcels would be contained in the proposed open space
system. No formal protection of resources would, however, occur since a resource
management plan would not be proposed. Instead, Otay Ranch would be subject to the
provisions of the Multiple Species, Wildlife, and Open Space Plan currently being
8-25
-.=)/;
~. v
Table 9
LAND USE STATISTICS
FOR ENVIRONMENTAL ALTERNATIVE
Otay River Proctor Valley San Ysidro Otay Ranch
Residential Parcel Parcel Parcel Total
Density Dwelling Dwelling Dwelling Dwelling
Land Use Designation (du/ac) Acres Units Acres Units Acres Units Acres Units
RESIDENTIAL
Low 0103 799 1,496 573 205 1,718 572 3,090 2,273
Low Mediwn 3t06 1,187 4,513 1,187 4,513
Mediwn 6 to II 276 2,465 276 2,465
Mediwn High lito 18
High 18-27 -- - n
- -
Total Residential 2,262 8,474 573 205 1,718 572 4,553 9,251
~ COMMERCIAL
~ Retail Commercial 78 78
~ Freeway Commercial 62 62
INDUSTRIAL
Research Industrial 62 62
PUBLIC/QUASI-PUBLIC
Public Facilities/Schools 209 209
University Site 225 225
PARKS/SQUARES III 7 118
EASTERN URBAN CENTER
Retail Commercial 186 186
RESORT 40 40
CONFERENCE CENTER 132 132
OPEN SPACE
Natural 5,999 7,152 3,830 16,981
Manufactured 339 18 357
FREEWAY ~ -8.2
TOTALS 9,618 8,474 7,915 205 5,555 572 23,088 9,251
Source Robert Bein, William Frost & Anociates, Project Team Land Use Alternatives - Olay Ranch, 1990; as revised by Ogden, /992.
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Environmental Alternative
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LEGEND
1,/',:+/:1 Open Space
I I Man Made Open Space
Residential
L3 Low 3
L2 Low 2
L1 Low 1
L Low
LM Low Medium
M Medium
MH Medium High
H High
Commercial
RC Retail Commercial
FC Freeway Commercial
Industrial
RD Research/Development
Isd City of San Diego [ndustrial
I Limited Manufacturing
Public & Open Space
PQ Public & Quasi Public
HS High School
JH Junior High School
ES Elementary School
NP Neighborhood Park
CP Community Park
Special Plan Area
EUC Eastern Urban Center
R Resort
CC Conference Center
.......
Hwy 125
Parkway
Transit corridor
Primary arterials
Otay Ranch property
F I (; U R E
8
I
developed by the County. To supplement the open space onsite, community and
neighborhood parks are planned as active recreation areas. In addition to residential, park,
and open space uses, this alternative proposes commercial uses along the freeway and retail
commercial uses distributed throughout the Otay River parcel.
The Environmental Alternative specifies four special plan areas for detailed
evaluation in the future: the Eastern Urban Center on the Otay River parcel, a conference
center on the Ranch House property between the lakes, a resort on the northern shore
overlooking Lower Otay Lake, and several village centers (permitting mixed residential,
civic, and commercial uses). Several elementary, junior high, and high school, and a 225-
acre university site are also planned for the Otay River parcel under this alternative.
Infrastructure plans are similar to those of the other alternatives, although sizing of
facilities would be reduced. Regional access to the site would be gained from the future
extension of SR-125 and eastern extensions of East Orange Avenue, Otay Valley Road,
East H Street, and East Palomar Street. As part of the proposed circulation plan, the
Environmental Alternative features two Otay River Valley crossings, SR-125 and Heritage
Road, and a public transit corridor paralleling the entire length of the freeway. Overall,
roadway widths would be reduced under this alternative due to decreased vehicle
generation.
No Proiect Alternative. Under the No Project Alternative, a coordinated planned
community would not be developed, and the property would remain in its present condition
as rural agricultural land and undeveloped open space. It is anticipated that dry fanning and
grazing uses would continue to occur on the majority of the property. No formal resource
management plan for the protection of biological and cultural resources would be
implemented. The eastern extension of East Orange Avenue and construction of Hunte
Parkway would still occur to accommodate regional traffic from the EastLake development,
but both roadways would terminate at the edges of EastLake. The SR-125 could still be
extended through the Otay Ranch property by Caltrans.
Offsite Alternatives
In compliance with CEQA, offsite alternatives were selected for analysis in the
Program ErR. Four alternatives were identified and analyzed to assess their potential to
eliminate or minimize significant impacts in comparison to the proposed project. The
criteria for selection of alternatives included the following:
. Location in the San Diego metropolitan area in order to satisfy the objective of
providing additional housing in this area
. Primarily rural area of approximately 20,000 acres, excluding large areas of
public land
. Developable area (slopes less than 25 percent) of at least 10,000 acres
. Location within or adjacent to an urban limit line and water district boundary
Based on the above criteria, four offsite locations were selected for analysis in the
EIR (see Figure 9):
. Greater Dulzura - This site is located directly east of Otay Ranch in an
unincorporated area of San Diego County.
8-28
I). J '
,_r/_~
. West Ramona - This elongated site is located in and surrounds the western end
of Ramona in San Diego County; the site is partially within the Poway and San
Diego city limits.
. East Ramona - This site is located in an unincorporated area of San Diego
County east of the town of Ramona and west of the community of Santa
Y sabel.
. Rancho Guejito - This site is located approximately 3 miles east of the town of
Valley Center, 4 miles east of the City of Escondido, and 3 miles north of the
San Diego city limits.
None of the offsite alternatives was environmentally preferable over Gtay Ranch.
", ")! /
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8-29
DE LUZ
RIYe,.lde County
Com.
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OTAY RANCH
PROJECT SITE
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GREATER DULZURA
Q
NOT TO SCALE
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LEGEND
Possible Site Alternatives
OGDEN
Regional Map of Offsite Alternatives
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SOURCES: SANDAG, J8F & Associates, and Dames & Moore
F I (; l' R F
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.....
developed by the County. To supplement the open space onsite, community and
neighborhood parks are planned as active recreation areas. In addition to residential, park,
and open space uses, this alternative proposes commercial uses along the freeway and retail
commercial uses distributed throughout the Otay River parcel.
The Environmental Alternative specifies four special plan areas for detailed
evaluation in the future: the Eastern Urban Center on the Otay River parcel, a conference
center on the Ranch House propeny between the lakes, a reson on the nonhern shore
overlooking Lower Otay Lake, and several village centers (permitting mixed residential,
civic, and commercial uses). Several elementary, junior high, and high school, and a 225-
acre university site are also planned for the Otay River parcel under this alternative.
Infrastructure plans are similar to those of the other alternatives, although sizing of
facilities would be reduced. Regional access to the site would be gained from the future
extension of SR-125 and eastern extensions of East Orange Avenue, Otay Valley Road,
East H Street, apd East Palomar Street. As pan of the proposed circulation plan, the
Environmental Alternative features two Otay River Valley crossings, SR-125 and Heritage
Road, and a public transit corridor paralleling the entire length of the freeway. Overall,
roadway widths would be reduced under this alternative due to decreased vehicle
generation.
No Proiect Alternative. Under the No Project Alternative, a coordinated planned
community would not be developed, and the propeny would remain in its present condition
as rural agricultural land and undeveloped open space. It is anticipated that dry farming and
grazing uses would continue to occur on the majority of the propeny. No formal resource
management plan for the protection of biolog'ical and cultural resources would be
implemented. The eastern extension of East Orange A venue and construction of Hunte
Parkway would still occur to accommodate regional traffic from the EastLake development,
but both roadways would terminate at the edges of EastLake. The SR-125 could still be
extended through the Otay Ranch property by Caltrans.
Offsite Alternatives
In compliance with CEQA, offsite alternatives were selected for analysis in the
Program EIR. Four alternatives were identified and analyzed to assess their potential to
eliminate or minimize significant impacts in comparison to the proposed project. The
criteria for selection of alternatives included the following:
. Location in the San Diego metropolitan area in order to satisfy the objective of
providing additional housing in this area
. Primarily rural area of approximately 20,000 acres, excluding large areas of
public land
. Developable area (slopes less than 25 percent) of at least 10,000 acres
. Location within or adjacent to an urban limit line and water district boundary
Based on the above criteria, four offsite locations were selected for analysis in the
ElR (see Figure 9):
. Greater Dulzura - This site is located directly east of Otay Ranch in an
unincorporated area of San Diego County.
8-28
0)_
,_ /1,_
'"~ It:
. West Ramona - This elongated site is located in and surrounds the western end
of Ramona in San Diego County; the site is partially within the Poway and San
Diego city limits.
. East Ramona - This site is located in an unincorporated area of San Diego
County east of the town of Ramona and west of the community of Santa
Y sabel.
. Rancho Guejito - This site is located approximately 3 miles east of the town of
Valley Center, 4 miles east of the City of Escondido, and 3 miles nonh of the
San Diego city limits.
None of the offsite alternatives was environmentally preferable over Gtay Ranch.
8-29
\'/.~'
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DE LUZ
NOT TO SCALE
Alnnlde County
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OTAY RANCH
PROJECT SITE
S.n Diego
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GREATER DULZURA,
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LEGEND
Possible Site Alternatives
SOURCES: SANDAG. JBF & Associates. and Dames & Moore
F I (; I' R I.:
OGDEN
.....
Regional Map of Offsile Alternatives
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9
ATTACHMENT C
LETTERS OF COMMENT
RECEIVED ON EXTENSION OF
PUBLIC REVIEW PERIOD
/'
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SWEETWATER COMMUNITY PLANNING GROUP
P. o. BOX 460
BONITA, CA 91908-0460
VALLE DE ORO COMMUNITY PLANNING GROUP
P. o. BOX 3958
LA MESA, CA 91944-3958
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June 22, 1992
Mrs. Anne Ewing, County Principal Planner
Otay Ranch Joint Planning Project
County of San Diego - City of.Chula Vista
315 Fourth Avenue, Suite A
Chula Vista, CA 920.10
SUBJECT: EIR and Associated Documents for Otay Ranch Project;
Request for 90-Day Formal Review Period.
In recent conversations with County Staff, we have been apprised of the
unusual magnitude of subject environmental documentation. We understand
that the basic EIR will contain approximately 1,500 pages with technical
appendicies of 2,000 additional pages.
Given the extensive nature of the proposed project and its wide-spread
effect on surrounding communities and the environment, we understand the
need for a large document to address alternatives and environmental
issues. Our concern is that the normal 45-day review time will not be
adequate for review and development of accurate responses by the affected
commun it i es.
Our experience in dealing with large-scale projects indicates that 90 days
will be the minimum required to review adequately the 3,500 pages of
information and to prepare appropriate responses. A lesser review time
will result in the discovery of major issues in the final public hearing
phases of the project and may invalidate the final environmental document.
Si ncere 1 y,
dL~~
John Hammond
Chairman, SCPG
Jack L. Phillips
Chairman, VDOCPG
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ENDANGERED HABITATS LEAGUE
Dedicaled 10 the protection or Co&$taJ S.cc Scl"Ub and olher IhrcalcnecJ ecO$)'Slcms
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Dan Silver, Coordinator
1422 N. Sweetzer Ave. #401, Los Angeles, CA 90069
Phone: (213) 654-1456
July 13, 1992
Anne Ewing
Otay Ranch Project Project Office
315 4th Ave., Suite A
Chula Vista, CA 91910
RE: Otay Ranch EIR
Dear Ms. Ewing
The Endangered Habitats League is a coalition of 36 conservation groups
dedicated to land use solutions and coastal sage scrub preservation. We will be
reviewing the above referenced document, and wish to request a minimum 90 day
comment period.
The Otay Ranch project is unprecedented in size, scope and complexity of
issues, and it is of great importance to the future of our region. The EIR is reportedly in
excess of 2000 pages. A 90 day period for review is thus indicated and will serve the
public interest.
In addition, may we please be placed on the mailing list to receive a copy of the
EIR at the letterhead address.
Thank you very much.
Sincerely,
<:J::: ~
Dan Silver
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July 15, 1992
Mr. Anthony J. Lettieri
General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, suite A
Chula Vista, CA 91910
RE: ENVIRONMENTAL IMPACT REPORT
Because of the size of the otay Ranch Project and its effect on the
environment, I am writing on behalf of the Chaparral Greens (local
East County Green Party) to request that 90 days rather than 45
days be given to review the Environmental Impact Report.
We feel that it would be a travesty to have only 45 days to review
such an enormous and important report.
Also, may we be included on your list to receive a.copy of the EIR.
Thank you for your consideratiori.
CAR~PP~
Member, Chaparral Greens
P.O. Box 1009
Jamul, CA 91935
"
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SAN DIEGO AUDUBON SOCIETY
~ MORENA BLVD. S,C. Rl8 . SAN DIEGO, CA 9211'" 619/~S Rlr~
~~I 'l.7S-0r"S'7
July 18, 1992
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Anthony J. Lettieri, General Manager
Otay Ranch Project Office
315 Fourth Avenue
Chula Vista, CA 91910
Dear Tony,
Audubon people., both general and Board members, are vitally interested in
the Otay Ranch Project. We are attending the joint workshops, and enjoyed
your presentation very much. Several Board members have enjoyed the field
trip hosted by Fred Arbuckle-- terrific! -- and several more hope to take
the tour in the future, including a Regional staff person, John McCaul 1 ,
from Sacramento. We have also joined a new group, the South County Environ-
mental Working Group, in order to share knowledge and ideas.
Many of us will be reviewing both' the Resource Management Plan and the
EIR, when they are made public. We understand that the EIR will no doubt
exceed 2000 pages, that is, wi 11 run three or four ti mes longer than an
ordinary EIR, and that there are nine alternativ~s!!! on site and four off
site. A daunting task, to provide responsible review. And yet we plan to
do just that.
And so we have a request: please extend the comment period to at least
90 days, or, better yet, 180 days. The sheer length and complexity would
seem to justify such. We will also be sharing our copies among ourselves,
and we're all busy, and volunteers only, but we don't want you wasting
trees by printing unnecessary copies.
We find much that is exciting and innovative in the project. We aim to
help in making it not just the biggest, but the best of all possible projects
for South County.
Thank you for your consideration, and please let me know about the extended
comment period.
fJ.n ..~
Norma Sullivan, Conservation Chair
5858 Scripps St.
San Diego, CA 92122
452-0787
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Nancy Nicolai
South County Environmental
Working Group
364 Elkwood Avenue
Imperial Beach, CA 91932
July 18, 1992
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Mr. Anthony Lettieri, General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 92010
Subject: Baldwin Otay Ranch EIR Review Period.
Dear Mr. Lettieri:
Please consider lengthening~the comment period for
the above-referenced project. The following are a few
reasons why I ask your consideration.
I believe lengthening the comment period is necessary
to give the EIR adequate review. The nature of the project
and the size of the EIR place it in an "excep1ri.onal
circumstance" to the general 45-day comment period. The
proposed Otay Ranch Development is:
the largest development in California history,
presently the largest in the U.S.,
has multiple complex and intact biological resources,
and has a joint agency for the lead.
Thank you for your consideration of this request.
*
*
*
*
~~~
Ecologist
. ;;tr{
JAMUL-DULZURA COMMUNITY PLANNING GROUP
P.O. Box 6~3
Jamul, CA 9~935
. .- --.- - - --
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July ~8, ~992
TO:
Tony Lettieri, General Manager, otay Ranch Joint Planning
Project
FROM:
Jamul-Dulzura Community Planning Group
RE:
otay Ranch Environmental Impact Report
At the July ~4th, ~992, meeting the Jamul-Dulzura Community
Planning Group voted unanimously to request that the public review
period for the otay Ranch Environmental Impact Report be lengthened
from 45 days to a minimum of 90 days.
Due to the extraordinary size of the document, the group feels that
a six week period is inadequate for a thorough and conscientious
evaluation and commentary.
The planning group needs adequate time to notify community members,
form subcommittees, set up meeting dates and locations, and
thoroughly review the material. A forty five day time limit makes
this impossible to achieve.
Also, the review period falls during a time when
group and community members are on summer vacation.
decreases participation and input.
many planning
This further
We urge you to carefully consider this request and recommend a more
reasonable length of time.
sin~y,
/1~ h~d<o.-
Kathy Frasca for
Mark Montijo, Chairman
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ruth D'Spain
Descanso, CA 91916
Anthony J. Lettieri
General Mgr. Otay Ranch Joint Project
315 Fourth Ave. Suite A
Chula Vista CA 91910
Dear Mr. Lettieri;
It has corne to my attention that the Otay Ranch Joint Planning
Project DEIR is, or will be out for public review. I am respectfully
requesting two things in this letter.
First, and most importantly, that the time limit for public review
for the very large DEIR be extended to 120 days, in order for local
Planning and Sponsor Groups to review it adequately. Because the
Groups meet on a monthly basis, the time element from the time
it is presented to the Group is very short.
Secondly, Since one alternative suggests a Biological Preserve
extending throughout the Sweetwater River, we in Descanso are very
concerned and possibly the Planning Group would support that concept.
We have not been "kept up to speed" on this impending project,
however would like to be included in mailings concerning the project
and most significantly be sent a copy of the DEIR.
As a member of the Descanso Sponsor Group and the Secretary, I
felt personal obligation to write asking you for these considerations.
As I was apprised of the time for review on the DEIR only today,
I have not been able to bring this to the Group, however will do
so.
Thank you for your attention to my concerns.
(
ruth D'Spain
:;JJ 7
Mr. Anthony J. Lettieri
General Manager,
Otay Ranch Joint Planning Project
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Dear Mr. Lettieri,
We are writing to urge that the public co=ent period for the Otay Ranch ErR be
extended from the 45 days to a minimum of a 90 day co=ent period.
We feel that due to the magnitude of the project size, it's impacts on the site and the mass
of information in the EIR require further investigation. It seems that this can not be
aocomplished in the normal 45 day co=ent period.
Again, in fairness to the public we ask that the co=ent period be extended to a minimum
of 90 days.
M~
Del Mar, Ca 92014
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July, 15, 1992
MR. ANTHONY J. LETTIERI
GENERAL MANAGER
OTAY RANCH JOINT PLANNING PROJECT
315 FOURTH AVENUE, SUITE A
CHULA VISTA, CA. 91910
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RE: PUBLIC COMMENT PERIOD FOR THE OTAY RANCH E.I.R.
Dear Mr. Lettieri,
I am writing to urge that the public comment period for the Otay
Ranch E.I.R. be extended past the usual 45' day comment period.
As we are all aware, there is very little that is "usual" about
this pro}ect. The scale of this project, it's impact on San
Diego, and the almost intimidating amount of information that is
cont.ined in the E.I.R. demands thorough and comphrensive con-
sideration. This simply cannot be accompolished within the normal
comment period.
In recogniti~n of the significance of this proj~c-t, and in fair-
ness to the public, I urge you and the other decision makers to
extend the comment period to a MINIMUM of 90 days.
Thank you for your consideration.
""1JU7:eL
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Mr. Anthony J. Lettieri
General Manager,
Otay Ranch Joint Planning Project
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Dear Mr. Lettieri,
We are writing to urge that the public comment period for the Otay Ranch EIR be
extended from the 45 days to a m;n;mum of a 90 day comment period.
We feel that due to the magnitude of the project size, it's impacts on the site and the mass
of information in the ErR require further investigation. It seems that this can not be
accomplished in the normal 45 day comment period.
Again. in fairness to the public we ask that the co=ent period be extended to a minimum
of 90 days.
u
~dAti--//
(\C";
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Mr. Anthony J. Lettieri
General Manager,
Otay Ranch Joint Planning Project
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Dear Mr. Lettieri,
We are writing to urge that the public co=ent period for the Otay Ranch EIR be
extended from the 45 days to a minimum of a 90 day co=ent period.
We feel that due to the magnitude of the project size, it's impacts on the site and the mass
of information in the EIR require further investigation. It seems that this can not be
accomplished in the normal 45 day co=ent period.
Again, in fairness to the public we ask that the co=ent period be extended to a minimum
of 90 days.
, r,
Sincerely,
1 ;' .
J!;tL{tU'1Af...--
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17 July-J..9-9?
Anthony J. Lettieri
General Manager
otay Ranch Joint Planning Project
315 Fourth Avenue, suite A
Chula Vista, CA 91910
Dear Mr. Lettieri:
Please consider a 120 day extension to the review period for
the otay Ranch EIR. It is my understanding that otay Ranch
is the largest development project in california, and perhaps
in the nation. A project of this magnitude needs the most
careful scrutiny in order to satisfy the needs of the owners,
developers and users of the property while still preserving
environmental integrity.
Thank you for your consideration.
Sincerely,
~~
Clark F. waite
~91916
'...,. ~.~..~~,r"',,,,,,,,,,,,,
,c .
C) 10'
Mr. Anthony J. Lettieri
General Mana~r,
Otay Ranch Joint Plamring Project
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Dear Mr. Lettieri,
We are writing to ur~ that the public comment period for the Otay Ranch EIR be
extended from the 45 days to a m;,nmum of a 90 day comment period.
We feel that due to the magnitude of the project size, it's impacts on the site and the mass
of information in the EIR require further investigation. It seems that this can not be
accomplished in the normal 45 day comment period.
Again, in fairness to the public we ask that the comment period be extended to a minimum
of 90 days.
, .~tl:~/,...tC :"~<h,",.'_"\
W~
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Mr. Anthony Lettieri,
General Manager, Otay Ranch Project Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
,
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July 16, 1992
Dear Mr. Lettieri,
I am writing to strongly urge you to extend the length of
the public review and comment period for the Otay Ranch
Development Project's EIR to a minimum of 120 days. My reasons
for this request reflect the extraordinary circumstances which
surround this Project. Due to the ma~nitude of the document
(1,700 pages!), the complexity of the appendices, and the scale
of this largest development project in all of California, (23,000
acres!) a shorter review period is inappropriate and, in my
opinion, irresponsible.
The Otay Ranch Project has an unprecedented level of
potential. It has the awesome potential to demonstrate
successful innovations in planning, land use and design which
meet the urgent needs of ecology, economy and community in
Southern California. It also has the enormous potential to
destroy the functioning of healthy ecosystems as well as quality
and diversity of life within these interwoven and interdependent
domains. Time is needed for the public to gain perspectives and
consensus which would lead to solid support for true win-wins
among these three areas of ecology, economy and community.
The stakes are high. A minimum of 120 days of public review
and comment, given the extraordinary conditions surrounding this
Project, would prevent a hasty and only cursory treatment of the
proposed plan and alternatives; it would also reduce the
potential for conflict and litigation over the proper
interpretation of CEQA review time allowances for extenuating
circumstances such as the ones mentioned.
Ultimately, for the sake of protecting our precious
-environment, bolstering our precarious economy and respecting the
deserving public and future generations, a minimum of 120 days
public review and comment is needed to attract the most rational,
resourceful, constructive and creative input from all quarters.
The rest of the State, and perhaps the nation, looks on.
How we treat this decision-making process will have a direct
effect on the legacy we help leave.
Respectfully,
6l1-frv ~\.,,---
Lyn Snow
Environmental Planner, Co-author,
Otay Ranch: Maximizing Eco-nomic
Sustainability
cc: South Coast Environmental Working Group
6!n)
';~ "r ;~~ (:~~ ~3 'j ~ ~,~ _~ .-
Larry Hendrickson. P.O.B. 155. JuHan. CA 92036
,.
- \_,
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~
July 18, 1992
Mr. Anthony J. Lettieri
Genera 1 Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, Su1te A
Chula Vista, CA 91910
Subject: Request for an Extentlon of the Public Comment Period for the Otay Ranch
Project E.I.R.
Dear Mr. Lettieri:
I would like to recommend that the pUblic comment period for the project EIR be
extended from 45 to 90 days, at the minimum. A project of this magnitude and
with such serious implications for the future of San Diego County deserves a
thorough and reasonable opportunity for pUblic input into its planning. As my
father often said, anything worth doing is worth doing we 11. Let's do this one
well.
~SUb
Larry E. Hendrickson
619/765-0385
iJ-P1
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Cottonwood Creek Conservancy
Anthony J, Lettieri, General Manager
Otay Ranch Project Office
315 Fourth Ave.
Chula Vista, Calif. 91910
July 19,1992
Dear Mr, Lettieri,
I am on the board of directors of the statewide Urban Creeks Council and founder of
the Cottonwood Creek Conservancy in Encinitas, I understand that the Otay Ranch
Project will be 7 square miles, the size of San Francisco, at build-out
This will have such a huge impact on our bioregion's resources and biological
diversity, that I must be able to comment on the EIR. I also understand that the EIR/EIS
will be 2000+ pages. Since this is four times the size of an average EIR, I am writing to
ask you to please allow at least 180 days for review.
As a third generation southern Californian, I believe it is time for the type of innovative
and precedent-setting development which your company is proposing in its
environmental plan. It is time to stop the profligate waste of our land and resources
and to insist that we can and must, live with nature, The old style of land development
has brought our state to the verge of ecological collapse,
Our climate and quality environment compensate for the high cost of doing business
here, while the attractiveness of our natural resources is key to keeping investments
here.
Thank you for your consideration of my request to extend the comment period.
Yours for Greenway Corridors (small, medium and large),
-~7n. U
Mary Renaker
jt:+
P.O. BOX 232422, ENCINITAS, CALIFORNIA 92023-2422 . (619) 942-1506
- "- ..-.
---.------
- -
Juiy 20, 1992
;i'.
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Tony Lettieri
General M=er
'-
Olay Ran:h Joint Planning Proj ect
315 41h Ave, Ste. A
Cimla VIola CA 91910
RE: EIR EXTENSION OF PEPJOD FOR PUBLIC REVIEW
Dear Mr. Lettieri:
I haye recently been informed that the Environmenlal Imp<ct Report for tne Olay P.a'1Ch Project is expected to
be approximately 1500 pages. Due to the len.;,otli of this document and the extraardiffiry complexity in.olved
with a project that may be the largest of its kind in California I am writing to request that the public review
period be extended beyond the minimum 45 days required by CEQA
Please consider extending the period to 180 days. as even 90 days 'iii!! not be sufficient to study the details
necas~ay to detenni.!le u'le impacts to an area of land which. ooce impacted by development will neyer be
relUmed to it:; mrural condition Consider the fact that t!-.is area is larger than the Qt] of San Fran::isco, ,IDd
should be plarmed carefully and without haste, in order to make the best dec~ons for the resolllces of the
region as well as for the exi>1ing and future populations of humans living in the area Consider also thaI !b.i5
project shouid possibly wait for completion of the Muitiple Species Conservation Program to make some of it:;
iinai land use dec~ons. as some of their rec=endations may need to be in:OlDorated into this clan
. , .
Thanks for your time and consideration
Sandra Cieisz
..- .,-.
San Diego, CA 92107
iJ-Z8
~THE
CALIFORNIA NATIVE PLANT SOCIETY
P.O. Box 1390, San Diego, CA 92112
July 22, 1992
:fr:::\D iF 0 is 0 \\1' rc.;> /-
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Mr. Anthony J. Lettieri
General Manager
Otay Ranch Project Office
315 Fourth Avenue
Chula Vista, CA 91910
Subject: Public Review Period for Otay Ranch Environmentallmpact Report and Technical Appendices
Dear Tony:
On behalf of the San Diego Chapter of the California Native Plant Society, 1 respectfully request that the public review
period for the Otay Ranch environmental impact repor: (ElR) be extended to 180 days.
While 1 realize that this is considerably longer than the public review period allowed for most projects, you would have to
agree that Baldwin's Otay Ranch project is unique in both its size and complexity. A comprehensive review of the biologic:ll
issues related to nine on-site and four off-site alternatives and associated resource management plan for the development of
23,000 acres requires substantial coordination on the part of our organization. This type of review cannot be done in 45 days.
If it is determined that 180-day public review period is not possible, we request that the review period be no less than 90
days.
In addition to receiving the EIR, we need to receive a copy of all technical appendices, including the resource management
plan. In order to expedite our review process, 1 would request that, in this instance only, the EIR and technical appendices be
sent to me at my home address: 3643 Waco Street, San Diego, CA 92117.
Thank you for your consideration of our request.
Sincerely,
~
Julie Ivi. Vanderwier
Conservation Chair
JMV:arh
cc: James C. Dice, President, San Diego Chapter.CNPS
Larry Hendrickson, San Diego Chapter CNPS
Norma Sullivan, South County Environmental Werking Group
Jl'i!
DEDICATED TO THE PRESERVATION OF CALIFORNIA NATIVE FLORA
J.
:'
July 23, 1992
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT:
Determination
for the Draft
Ranch Project
of an "adequate" period of public review
Environmental Impact Report for the Otay
of the Baldwin Co. in San Diego county.
Project Team:
As a citizen of San Diego county, and a member of the Valle de
Oro Community Planning Group, I have been following the progress
of the Otay Ranch Project Team. I have also attended the joint
planning commission workshops and field tours. I write to you
now, and to the other decision-makers involved, to address the
issue of adequate public review for the forthcoming draft EIR.
The State Guidelines for CEQA refer to this aspect of the
process in several articles:
Article 7. EIR Process - Public Review of Draft EIR (page 108)
15087. (c) In order to provide sufficient time for public
review, review periods for draft EIRs should not be less than 30
days nor longer than 90 days from the date of the notice EXCEPT
IN UNUSUAL SITUATIONS. (emphasis mine)
Article 8. TimeLimits
Public Review (page 124)
15105. (a) Same statement as above citation.
Article 10. Considerations in Preparing EIRs and Negative
Declarations Page Limits (page 147)
15141. The text of draft EIRs should normally be less than 150
pages and FOR PROPOSALS OF UNUSUAL SCOPE OR COMPLEXITY SHOULD
NORMALLY BE LESS THAN 300 PAGES. (emphasis mine)
Article 13. Review and Evaluation of EIRs and Negative
Declarations Adequate Time for Review and
Comment (page 177)
15203. The Lead Agency shall provide adequate time for other
public agencies and members of the public to review and comment
on a draft EIR or Negative Declaration that it has prepared.
~~
, -
lam told by Anne E~ing that the current single-spaced draft of
the EIR is running over,1600 pages ~ith appendices and supporting
technical reports of some additional 2000 pages.
If an EIR of "unusual scope or complexity" should co~e in under
300 pages, the Otay Ranch Project draft EIR must surely qualify
as a one-of-a-kind. submittal. We all certainly recognize the
unusual character of this project.
I haven't been in school for some time no~, but my arithmetic
tells me that if 300 pages deserve 90 days, then 1600 pages (and
more) deserve about 450 days for adequate revie~. I realize this
is not practical and I suggest a compromise period of 180 days.
I will be attending your meeting on July the
comments public. Please place this letter in your
my intention to establish an administrative
project.
30th to make my
file as it is
record on this
Sincerely,
{pzJ r- /~
Daniel Ford Tarr
J ~ '.
El Cajon, CA 92020
619 588-4863
cc: Otay Ranch Project Team, Chula Vista City Council Members,
Members of the Board of Supervisors, Valle de Oro Community
Planning Group, State Dept. of Fish and Game, U.S. Fish and
Wildlife Service, State of California Office of Planning and
Research, South County Environmental"Working GrouJP ^ ~l\...l ~
!{!~D; jv_'-U..{-c-_}~I--~ (fG "' 1>,-,
I
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-"~<le~,, 19"- I
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;?tJL
JERRY C. HAr:1MON
~AYCR
CIVIC CENTER PLAZA
201 North Broadway. Escondldo
California 92025-2798
(819) 741-4610
<JI'I~ OF G,8QOl1UIDO
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" ,- "Ii
July 23, 1992
, ~\
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IV
Anthony T. Lettieri
General Manager
Otay Ranch Project
315 4th Avenue
Chula Vista, CA 91910
Dear Mr. Lettieri,
This is to request you extend the EIR review period to 90 days in order to give
public adequate opportunity to review what is likely one of the longest EIR's in
the history of the region. Even a 90 day review period for a 2,000 page
document seems inadequate.
Your positive consideration of this request will be greatly appreciated. ,
A'\."".~ fi:.........'~~:_.~~::1~{~J,....
Since~
Jerry C. Harmon
Mayor
:d ;) -1
.E=RY C. HA,::;MC~j. ~..lA V':R 310 HCL~SJS. ,'.-1A '(C:=t PRO T~\1 2:!...:.lE::i c. -:A\:=;;C:~~ =:-::-;'':0.':'. :=C-37Ei=i :""::=1 '_.::..:- ~=:::L'=:~
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SIERRA CLUB. SAN DIEGO CHAPTER
San Diego and Imperial Counties
3820 Ray Street
San Diego. CA 92104
-'
Anthony J. Lettieri, General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
July 23, 1992
Dear Mr. Lettieri:
This letter is to request an extended public review period for the upcoming EIR on the
Otay Ranch Project. The EIR is to be of an extraordinary size, in keeping with the
scope of the project, and will warrant an extended review time. We are requesting a
120-day review period for submitting comments on the draft EIR. Thank you.
Sincerely,
p~ G-.e./v\.QcU,Lk.;
Patricia Gerrodette, Chair
Land Use Committee
~!g
.-
~,.~'~:.'~~ _7:-~ u '}..! _.f "
..~
July 23, 1992
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
SUBJECT:
Determination
for the Draft
Ranch Project
of an "adequate" period of public review
Environmental Impact Report for the Otay
of the Baldwin Co. in San Diego county.
Project Team:-
As a citizen of San ~iego county, and a member of the Valle de
Oro Community Planning Group, I have been following the progress
of the Otay Ranch Project Team. I have also attended the joint
planning commission workshops and field tours. I write to you
now, and to the other decision-makers involved, to address the
issue of adequate public review for the forthcoming draft EIR.
The State Guidelines for CEQA refer to this aspect of the
process in several articles:
Article 7. EIR Process - Public Review of Draft EIR (page 108)
15087. (c) In order to provide sufficient time for public
review, review periods for draft EIRs should not be less than 30
days nor longer than 90 days from the date of the notice EXCEPT
IN UNUSUAL SITUATIONS. (emphasis mine)
Article 8. Time Limits
Public Review (page 124)
15105. (a) Same statement as above citation.
Article 10.
Considerations
Declarations
in Preparing EIRs and Negative
Page Limits (page 147)
15141. The text of draft EIRs should normally be less than 150
pages and FOR PROPOSALS OF UNUSUAL SCOPE OR COMPLEXITY SHOULD
NORMALLY BE LESS THAN 300 PAGES. (emphasis mine)
Article 13. Review and Evaluation of EIRs and Negative
Declarations Adequate Time for Review and
Comment (page 177)
15203. The Lead Agency shall provide adequate time for other
public agencies and members of the public to review and comment
on a draft EIR or Negative Declaration that it has prepared.
~l>1
,
I am told by Anne Ewing that the current single-spaced draft of
the EIR is running over 1600 pages with appendices and supporting
technical reports of some additional 2000 pages.
If an EIR of "unusual scope or complexity" should come in under
300 pages, the Otay Ranch Project draft EIR must surely qualify
as a one-of-a-kind submittal. We all certainly recognize the
unusual character of this project.
I haven't been in school for some time now, but my arithmetic
tells me that if 300 pages deserve 90 days, then 1600 pages (and
more) deserve about 450 days for adequate review. I realize this
is not practical and I suggest a compromise period of 180 days.
I will be attending your meeting on July the
comments public. Please place this letter in your
my intention to establish an administrative
project.
30th to make my
file as it is
record on this
Sincerely,
~Jl r-
-
/~
Daniel Ford Tarr
.., -
El Cajon, CA 92020
619 588-4863
cc: Otay Ranch Project Team, Chula Vista City Council Members,
Members of the Board of Supervisors, Valle de Oro Community
Planning Group, State Dept. of Fish and Game, U.S. Fish and
Wildlife Service, State of California Office of Planning and
Research, South County Environmental Working Group
~/D
Mr. Anthony J. Lettieri
General Manager,
Otay Ranch Joint Planning Project
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Dear Mr. Lettieri,
We are writing to urge that the public comment period for the Otay Ranch EIR be
extemled from the 45 days to a minnnum of a 90 day comment period.
We feel that due to the magnitude of the project size, it's impacts on the site and the mass
of infOImation in the EIR require further investigation. It seems that this can not be
aa::omplished in the normal 45 day comment period.
Again. in fairness to the public we ask that the comment period be extended to a minimum
of 90 days.
Sincerely,
~/!
JERRY C. HARMON
MAYOA
qlT~ OF <6,800111)11)0
CIVIC CENTER PLAZA
201 North Broadway. Escondida
California 92025-2798
(819) 741-4610
July 23; 1992
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Anthony T. Lettieri
General Manager
Otay Ranch Project
315 4th Avenue
Chula Vista, CA 91910
Dear Mr. Lettieri,
This is to request you extend the EIR review period to 90 days in order to give
public adequate opportunity to review what is likely one of the longest EIR's in
the history of the region. Even a 90 day review period for a 2,000 page
document seems inadequate.
Your positive consideration of this request will be greatly appreciated.
Ie""'" ("" war~on
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Mayor
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~E~RY C. HARMON, ~,fA YCR SID HOLLJ:-jS. .\1A YOR PRO TE~.1 E!......1ER c. CAME.='C'J ,=lCHARO A. FCS7E::1 ~C:F;:;l hOLT .~F::iL='::;
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July 26, 1992
Tony Lettieri, Director
Otay Ranch Project
315 Fourth Avenue Suite A
Chula Vista, CA 91913
Dear Mr. Lettieri:
I am very happy to hear that the EIR for the Otay Ranch Project
will be available at the end of this month. I am anxious to
thoroughly read and evaluate this valuable document.
I sincerely hope that I will have ample time to do this. The
project is so mammoth, and the EIR is so important, that I hope
intereted people and groups will have the maximum time to study
it, not the minimum 45-days!
To allow people only ~ ~ for study would greatly restrict
interested citizens from effectively becoming involved in the
future of their city. Please allow mamimum time for careful
study.
Thank you.
Sincerely,
~~
Adrien Myers, Secretary
South Bay Sierra Club
1893 Ithaca Street
Chula Vista, CA 91913
;ill 3
WILLIAM J. ROB ENS
July 27, 1992
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Tony Lettieri
General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
Dear Tony:
My understanding is that the Draft EIR for the Otay Ranch Project is to be issued
to the public for comment on July 31.
It will require an extended public review and comment period. This EIR is
voluminous, with technical addenda, it contains well over 2000 pages. Given
the size of the EIR, the importance of the project, and the potential immense
environmental damage that the project couid cause, the minimum 45 day period
will not be enough time for an adequate review.
I hereby request that the public review period be extended to 120 days.
Thank you for considering this request.
Sincerely,
IV ~gLci:-!<-~ f . /~/t.!/,
William J. Robens
Bonita, CA 91902
(619)479-7955
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__Bonit~, California 91908 . (619) 479-7955
,
Carol Freno
President
Bill Robens
Vicc.President
Will Hyde
Treasure:
Mem~
Lowell BlankfOrl
A1;.n Ca:.npbc~l
William Cannon
Jennie Fulasz
George GilIow
Jerry Griffith
Tom Pasqua
Frank Scott
. Peter Watry
Cary Wright
CROSSROADS
RESIDENTS WORKING TO KEEP CHULA VISTA A NICE PLACE TO LNE
----;- :--:--'-:-:.:.' -:., '
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July 27, 1992
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Mr. Tony Lettieri
General Manager
Otay Ranch Joint Planning Committee
315 Fourth Avenue, Suite A
Chula Vista CA 91910
Dear Mr. Lettieri:
We have been advised that the Environmental Impact Report on
Otay Ranch will be issued July 31 and at that time the City
Council will decide the timing of the review process.
In view of the size of this project and the citizen involvement
in the planning up to this date we believe a minimum of 120 days
would be necessary for all concerned to complete input in this
review. It is our understanding the EIR will be over 2,000 pages
so a proper amount of time should be allowed.
Thank you for your consideration.
Sincerely,
Ca ro 1 Freno
President
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United States Department of the Interior-
FISH AND WILDLlFE SERVICE
FISH AND WILDLIFE ENHANCEMENT
Southern California Field Station
.Carlsbad Office
2730 Loker Avenue West
Carlsbad, California 92008
31
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July 30, 1992
Anthony J. Lettieri, AICP
General Manager
Otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, California 91910
Re: Review of the Environmental Impact Report for the Otay Ranch, San Diego
County, California
Dear Mr. Lettieri:
It is the Fish and Wildlife Service's (Service) understanding that you are
presently determining the appropriate comment period length for the
Environmental Impact Report for the otay Ranch. Based on the exceptional
length of this document and the complexity of the subject project, the Service
recommends a 180 day comment period to allow a thorough review of this
unusually complex project. If 180 day comment period is not possible, no less
than a minimum 120 day comment period should be provided.
We appreciate your consideration of this request. If you have any questions
or comments, please contact Nancy Gilbert of this office at (619) 431-9440.
Sincerely,
~~.~~
f-RiChard Zembal .~
Deputy Field Supervisor
cc: CDFG: La Mesa, CA (Attn: T. Stewart)
3Jb
OFFICERS
.-
laura Failla, MSW
President Mr. Anthony J. Lettieri
Child Protec~ve Services General Manager
Mlchoel Shames h .
Vice President Otay Ranc Pro) ect
Utility Cansumer Action Networi315 Fourth Avenue
BeatrizBarraza-Rappe Chula Vista, CA 91910
Secretary
UCSD/SDSU Par Lo Vida Project RE: Request for Otay Ranch EIR
Tony Pettine, MA
Treasurer . .
S.D. Community College DistMctDear Mr. Lettlerl:
BOARD OF DIRECTORS
Doug Ballls E:nvironmental Health Coalition requests a copy of the
IntemahonalAssociation Environmental Impact Report (EIR) for the Otay Ranch
of iron Workers Project when it is released for public comment. .We
Jim Ben. . are very interested in this project for a variety of
Ecological Ute Systems Institute reasons. First, it is a very large watershed area
Laurence l. Brunton, Ph.D. that drains at least in part into San Diego Bay
UCSO SchOOl of Medlcrne '.'. .
Mary Carmichael Our Clean Bay Ca;npalgn has been. worklng for. the
Escondida Neighbors Against cleanup, restoratlon, and protectlon of San Dlego
Chemical Toxins Bay's multiple beneficial uses since 1987. Increased
ScottChalfield urbanization in the Otay River watershed will severely
101 KG8FM. impact the water quality of San Diego Bay if proper
Marc Cummings . Best Management Practices and structural
Nathan CummIngs Foundation . .
"thO I conslderatlons are not properly addressed. Further,
.u uemer '. d' . d d
Sierra Club we are lnterested In expecte pestlcl e use an
Anne-Marie Feenberg, Ph.D. locations of toxics and hazardous using materials
UniversityotRedlands businesses within the project and project impacts on
Edward Garham MPH air quality
Naval Health Research Center .
Ruth Heitetz. MD, MPH
UCSO School of Medicine
Richard Juarez
Metropolitan Area
Advisory Committee
Sharon KoJemkiarian
Attomey
l yn Lccye
Lacye & Associates
Dcn McKirnan, Ph.D.
UCSO School of Medicine
Sylvia Mlcik. MO
NOrth County Health Services
Reynaldo Pisano
Jay Pawen
Richard Whartan
usa Environmental Low
August 5, 1992
11>",-
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Since we understand that this is a large EIR due to
the size of the project we are requesting that at
least a 90-day review period be granted. As you know
public comment is necessary for any project to go
forward and the extra time would allow more meaningful
public comment on the project.
Thank you for your consideration.
Diane Takvorian
Executive Director
ely,
Hunter, Director
Campaign
affiliations noted for identlt'lccrion purposes only
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August 21il, 1992
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Council Members
Chula Vista City Council
276 Fourth Street
Chula Vista, CA 91911il
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.Dear Chula Vista Council Members:
I received, a copy of the Draft EIR for Otay Ranch last evening.
It took me over one week to obtafiilt. I do not think that
sitting in a library to read this massive, confusing document is
a viable option for anyone. When I requested a copy at the Otay
Ranch office, I was informed I would have to pay $51il for it. The
EIR is difficult to access.
For this and for other reasons, 'I am greatly dismayed that the
review period is only sixty days. How can people who work a 40-
hour week possibly evaluate this massive document in two short
months? How can you adequately evaluate the document in such a
short period? Your decision on the Ctay Ranch will change Chula
vista forever. Surely, you need and deserve more time to
evaluate and decide.
The EIR is confusing. Does it describe one project or three?
,
The EIR is incomplete. Where is the "wildlife Corridor Study?"
Surely you will not decide without it. Under the heading of
schools, the Draft EIR states, "Prior to SPA Plan approval, the
project applicant shall provide documentation confirming school
site locations and school district approval of the
locations.... (3.13-54)." Where is this documentation? Surely
you will not decide without it. Furthermore, who honestly
believes that, with the state budget as financially unsound as it
is, school districts can possibly approve the construction of
more schools? California does not have the money to educate the
students who will live in the Otay Ranch Project!
The Draft EIR for Otay Ranch is inaccessible, overly-massive,
confusing, and incomplete. I implore you to grant more time for
responsible citizens (including yourselves) to adequately study
and respond to it.
Most sincerely,
~'-M
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A rlen Myers
South Bay Sierra Club
l891il Ithaca Street
Chu1a Vista, CA 91913
cc. Greg Moran San Diego Union-Tribune
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SIERRA CLUB. S....N DIEGO CHAPTER
San Diego and Imperial Counties
3820 'Ray Slreel
San Diego. CA 92104
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Mayor and City Council of Chula Vista
276 Fourth Avenue
Chula Vista, CA 91910
August 20, 1992
~
Dear Mayor and Councilmembers:
,
~
On behalf of the Sierra Club Land Use Committee, I wish to protest your recent
decision to allow only 60 days to review the EIR for Otay Ranch. Given the .
extraordinary size of the project and EIR, this project seems to fit the CEQA definition
of "unusual circumstances."
Our intent is to respond to the EIR as completely as possible in the 60-day time frame,
then continue working on issues that we have not had time to address and get those
comments to you as quickly as possible.
I would also like. to point out that previous opportunities for citizen involvement in this
project are irrelevant when considering the EIR review period. This is now a public
document and there should be adequate time provided for public review.
Sincerely,
-PoXu.Oa. G-~
Patricia Gerrodette
Chair, Land Use Committee
:3-/0
Dan Silver . Coordinator
1422N. Sweetzer Avenue #401
Los Angeles, CA 90069-1528
213 .654. 1456
.....
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ENDANGERED HABITATS LEAGUE
Dedicated to the Protection of Coastal Sage Scrub and Otha Threatened Ecosystems
August 24, 1992
Douglas Reid
Otay Ranch Project Planning Office
315 Fourth Ave., Suite A
Chula Vista, CA 91910
RE: Otay Ranch draft EIR
Dear Mr. Reid:
Our group wishes to give the Otay Ranch EIR thorough review and analysis.
After beginning our review, however, we find that the unusual length and complexity of
the document, along with its lack of clarity, will preclude completing such analysis
during the 60 day comment period granted.
We concur with counsel for the County of San Diego that the intent of CEQA
guidelines is to provide for longer review in cases with these extraordinary
circumstances. A reasonable period for public review requires a 60 day extension of
the current comment period, for a total review period of 120 days, and we hereby
formally request an extension to this length.
Sincerely,
<J:::.. ~
Dan Silver
cc: Chula Vista City Council
San Diego Board of Supervisors
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ENDANGERED HABITATS LEAGUE MEMBERS
Laguna Hills Audubon Society
Palomar Audubon Society
San Diego Audubon Society
Los Angeles Audubon Society
Buena Vista Audubon Society
Pomona Valley Audubon Society
Palos Verdes Peninsula Audubon Society
Pasadena Audubon Society
Sea and Sage Audubon Society
EI Dorado Audubon Society
Sierra .Club San Diego Chapter
Sierra Club Angeles Chapter
Friends of Penasquitos Canyon
Shoreline Study Center
Carlsbad Arboretum Foundation
Cottonwood Creek Conservancy
Ecology Center of Southern California
Friends of the Hills (UC Irvine)
Defenders of Wildlife
Orange County Fund for Environmental Defense
Laguna Canyon Conservancy
Mountain Defense League
Save Our Coastline 2000
Laguna Greenbelt, Inc.
Friends of Batiquitos Lagoon
Friends of the Tecate Cypress
San Diego Biodiversity Project
Rural Canyons Conservation Fund
Friends of the Santa Ana River
Tri County Conservation League
Los Alamos Neighborhood Association
California Native Plant Society
Committee for the Environment (Orange County Bar Assoc.)
San Bernardi.no Sage Friends
Save Our Forest and Ranchlands
Friends of the Foothills
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August 26,-l-9-9-2
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Douglas Reid
Otay Ranch Project Office
315 Fourth Ave Suite A
Chula Vista, CA 91910
Dear Sir:
Last week I picked up a copy of the Otay Ranch Draft EIR.
It is very thick. I only have my spare time to review the
document as I am gainfully employed in an unrelated field.
I respectfully request an extension of the review period
so that I can give the document more than a cursory review.
An additional 60 days would be nice but any time would be
helpful.
Sincerely,
~~~
~ind~Burrascano
.
Chula Vista, CA 91910
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AUGUST 27, 1992
MAYOR TIM NADER
CHULA VISTA CITY COUNCn.
CHULA VISTA, CA
DEAR MAYOR NADER:
AS A CONCERNED CITIZEN OF CHULA VISTA AND AS A PERSON VERY
CONCERNED ABOUT THE ACCELERATED USE OF RESOURCES IN MY
COUNTRY I AM VERY UNEASY ABOUT THE DEVELOPMENT OF OTAY
RANCH INTO A "NEW TOWN".
DEVELOPMENT OF OPEN LAND MAY BE INEVITABLE BUT IF IT MUST BE,
..
IT SHOULD BE DONE WITH CAREFUL CONSIDERATION OF FUl'URE NEEDS.
IT ALSO SHOULD BE DONE WITH THE ACTIVE SOLICITATION OF CITIZEN
INVOLVEMENT. THE LATTER, IN MY VIEW HAS NOT BEEN PURSUED WITH
THE. AGGRESSIVNESS THAT A PROJECT. OF THIS SIZE WOULD" SEEM''rO
WARRANT.
I HAVE A COPY OF THE EIR FOR THE OTAY RANCH DEVELOPMENT. '
AS YOU KNOW IT IS VERY LONG AND VERY TECHNICAL IN NATURE.
THE 60 DAYS THE CITY COUNCn. HAS ALLOWED FOR CITIZEN
REVIEW IS TOTALLY INADEQUATE. FOR A PROJECT OF THIS SIZE
THAT Wll..L ADD 149,000 PEOPLE TO THE SOUTH BAY AND Wn.L
DRASTICALLY CHANGE THE CHARACTER OF THE SOUTH BAY IT WOULD
SEEM TO ME THAT YOU SHOULD AGRESSIYELY.ENCOURAGE THE
PARTICIPATION OF THE CITIZENS. I SUBMIT THAT A 60 DAY REVIEW
PERIOD FOR THE EIR TENDS TO SHUT OUT THE CITIZEN INVOLVEMENT.
A MUCH LONGER REVIEW PERIOD IS IN ORDER. A PERIOD OF AT LEAST
120 DAYS MAY BE ADEQUATE.
(OTAY. MEMO)
REGARDS,
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SEP 2 1 1992
JAM.lL-OOLZURA o:MiJNITY PIAlINlllG GROOP
.. Box 613
Jattul, CA 91935
, .
September 9, 1992
George Bailey, Chairman
San Diego County Board of Supervisors
1600 Pacific Highway
San Diego, CA 92101
Dear Chairrran Bailey:
r am writing to request the Board's support for an exteoded review pericxl on
the Draft Environm=ntal I:llpad; Report for the otay Ranc.lJ..
The Jarnul-Dulzura Community Planning Group originally asked for a 90 day
review and were disappointed with the decision to limit public review to 60
days. However, we established hv.. sub-camri.ttees to divide the work, and
have attempted to rr~intain a schedule whereby a thorough analysis of the
docunent and th",nine volures of technical appendices could be cCJ:lilleted on
time. The task has proven iIq;>ossible.
This project has the potential to becane an exceptional land developnent. We
all recognize the unique benefits ~reheo.sive planning can offer on the otay
P.anch. However, these benefits can only be assured by adequate review. The
concepts we have cooperatively developed over the past five years will not
booamo ro~li~~ unlooc tho ~lamontinq prooodur~ 2rQ clQar ~- ~roci~..
Enviroomental impacts Ill.ISt be adequately assessed and proposed mitigations
rrust be convincingly supported.
Therefore, the Jarml-Dulzura Ccmmnity Planning Group has voted unarrilmusly
to request a 60 day extension beyood October 7, 1992, for public review. It
has becane clear that without this additional tiJre, we will be forced to limit
the scope of our review ;md <-..."."-'Uts on this enonrous docunent.
Respectfully suhnitted,
Mark Monti jo, Chair
j):Jy
CAROLINE E. COULSTON
ATTORNEY AT LAW
141.8 SOUTH EL CAMINO REAL, SUITE 111
ENCINITAS, CAUFORNIA 92024
(619) 94J.l061
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September 11. 1992
Anthony J. Lettieri
Otay Ranch Project Plarming Office
315 Fourth Avenue. Suite A
Chula Vista. California 91910
RE: Comments by South County Environmental Working Group
Otay Ranch Draft Program Environmental Impact Repon
EIR 90.01 (City of Chula Vista)
Log #89-14-98 (County of San Diego)
SCH #89010154 (State of California)
Dear Mr. Lettieri:
I have been retained to legally represent the South County Environmental Working Group. a
fact finding educational' organization formed for the purpose of examining the Otay Ranch Project.:
The South County Envirorunental Working Group is hereby formally requesting an extension of the
public review period for the 4000 page Olay Ranch Draft Program EIR until December 7, 1992.
I need not remind you that the beneficial effect of public participation on the environmental
review process is one of the strongest themes running through the body of CEQA law. One of the
major functions of the EIR is to ensure that all reasonable alternatives are thoroughly assessed. An
EIR serves to demonstrate that the lead agency has in fact analyzed and considered the ecological
implications of its actions.
No meaningful consideration of this document, which will have significant impact on the
entire region. can possibly be made in the 60 days alloned by the City of Chula Vista City Council.
The Lead Agency'must provide the public adequate time for review and comment on a. Draft EIR.
(CEQA Guidelines ~ 15203). Of course. failure to comply with the CEQA guidelines may constitute
abuse of discretion justifying the issuance of a writ of mandate. Benton v. Board of Supervisors of
Naoa CounlV. 226 CaI.App.3d 1467, 277 Cal.Rptr. 481 (1991).
The unprecedented scope. complexity and length of the EIR requires an extension of the
~:;
South County Envjronmental Worldng Group
Otar Ranch Comments
S.p.....ber 11, 1992
2
review period. The CEQA Guidelines specifically provide for a 90 day review period except in
"unusual circumstances." (CEQA Guidelines ~ 15105). This document is 4000 pages long, whereas
proposals of unusual scope or complexitY should "normally be less than 300 pages." (CEQA
Guidelines ~ 15141). The 23, 088 acre size of this project and the 4000 page length of the EIR
clearly qualifies as "unusual circumstances." The suggested 60 day extension of the review period
provides a reasonable balance of the interests of the applicants to move expeditiously and the public to
adequately respond to the EIR.
It is particularly imponant in this case that sufficient review time be given since this is a
Progr.ll"!l EIR which will have long lasting effects. All environmental documents on later parts of the
program need only focus on new effects not considered in the Program EIR. (CEQA Guidelines ~
l5l68(d)(2)). Documents penaining to subsequent projects can incorporate by reference all materials
from the Program EIR. Therefore, the Program EIR acts as an analytical superstructure for
subsequent analysis and must provide an ecologically sound basis for later projects.
The transcript of the July 30, 1992 hearings indicates that the decision to limit the review
period to 60 days was based in part on review periods granted for recent local EIRs. The EIRs
discussed, including the Black Mountain EIR and Central Mountain Update, are all documents of less
than 500 pa~es. Funhermore, these projects often concerned only one or two salient issues.
Comparisons between this EIR and those of General Plans are further misleading in that a project EIR
will necessarily be more detailed in the specific effects of the project than will be an EIR on the
adoption of a general plan. (CEQA Guidelines ~ 15146(a)). The Geay Ranch EIR is unlike the EIRs
mentioned at the hearing as it concerns the largest project in California and is an all inclusive
manuscript addressing all issues.
The limited review of the EIR which has been possible to date indicates that this Draft EIR is
not a comprehensive document as required by CEQA. (CEQA Guidelines ~ 15120). First, discussions
. with Baldwin staff have indicated that an additional "staff recommendations" document will be
submitted to the Planning Group this month providing yet another alternative. Naturally, such a
document should be made part of this EIR in order that all proposed alternatives can be examined
simultaneously. If, subsequent to public review signlficant new information, such as the proposed staff
recommendations, is made available then the agency must issue a new notice and must recirculate the
,,~d-tc
South County Environmental Working Group
QtaT Ranch. Comments
September 1~ 1992
3
EIR for additional commentary and COnsultation. (Pub. Resources Code. ~ 21092.1; See also ~
Sensible Planning. Inc. v. Board of Suoervisors 122 CaLApp.3d 813, 822 (3d Dist. 1981). Efficiency
. demands an. extension. of .the present. comment. period. in order :that the. forthcoming alternative' can be'
thoroughly considered.
Second, the document alludes to an upcoming Wildlife Corridor Study, which only became
avallable 30 days after the review period began. and to a Resource Management Plan Phase II which
will only be avallable if this EIR becomes certified. As much of the New Town Plan appears to rely
on these studies as the basis for the EIR analysis it is clear that no reasoned decision can be reached
on the basis of the current document. The public and the decision makers cannot be expected to view
these documents in isolation from one another and still fulfIll the goals of CEQA.
Third, the EIR directly makes reference to substantial changes in the San Diego County
General Plan. The General Plan Amendments are not due for public review until the end of this
month. Again,. the documents must be reviewed at the same time in order to meaningfully analyze
consistency of the EIR with the amendments.
Fourth, the Draft EIR is incomplete in that it does not yet include correspondence between the
applicant and the applicable agencies. A request has been made, pursuant to the California Records
Act of 1968 (Government Code ~~ 6250 - 6265). that all documentation in the form of letters. reportS
and all forms of written correspondence exchanged during the processing period of the Otay. Ranch
Development EIR be subrnined as official filings to become part of the EIR's permanent record. (See
Letter from Pat Parris to Otay Ranch Joint Planning Project (Aug. 19, 1992)). The anorney's office of
the City of Chula Vista ha~ indicated an unwillingness to comply with the request and will not supply
the information. Recent case law indicates the prudence in continuing to insist on the inclusion of
these materials. (Del Mar Terrace Conservancy v. City of San biego. San Diego Sup. Ct. # 537406
on aooeal Ct. App. 4th Dist # D015851) (Court held that, even though correspondence between
applicant and city indicated intent to thwart the CEQA process, the intent of the documents could not
be assessed by the court since the documents were never made part of the CEQA record for the
preliminary decision makers to review.) Until these documents become part of the EIR it will remain
only a partially complete document.
iP-1
South County Environmental Working Group
Olay Ranch Comments
September 11. 1992
4
The South Coast Environmental Working Group intends to participate in the public process
and thoroughly review and analyze the Draft EIR. Indeed, members have already begun the massive
,
.. undertaking;,; However;. the;unprecedented.range..and content of.the.document:and the; fact that the
document is incomplete make it clear that useful examination will not be possible in only.60 days. To
preserve the integrity of the process the citizens of. San Diego County must be given the. opportunity to
fully and carefully analyze the EIR.
For all the above reasons, we are hereby formally requesting an extension of the comment
period until December 7, 1992.
ZL?::1
Caroline E. Coulston ~
Attorney for South County Environmental Working Group
cc: Mayor Tim Nader, City of Chula Vista
George Bailey, Chair San Diego County Board of Supervisors
Oerk San Diego Board of Supervisors
Christine Kinney, Attorney for California Resources Agency
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SEPTEt'lBER 11, 1992
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TO WHOM IT MAY CONCERN,
1 Ar--l CI:)t---ICERNED THAT THE 1':E\)1 EH PERIOD FOR THE EJ R
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INADEOUATE FOR ,;UFFI Cl ENT ,::;TUDY. 1 FEE!... THAT THE AREA THAT
I S PROPOSED FOR DEl)ELOPl"lENT HAS f"lANY SEl'.~:3 I T I1v1E r :33UE3
RELEl')A~'.JT TO OUR OPEf...j SPACE3, HAE: I TAT Pf?ESEF:I.)ATI cr.l ~t)D "THE
GENERAL PLAN AI'lEr-mr"lEt'iT.
PLEA,;E EXTEND r-1Y A8 J L I TY TO UNDERSTAND THE J r-1PL J CAT 1 or..j,;
l/JITHIt...j THE rt.-1FACT Or.::- :.::UCH A DE')ELOFl'1E~'.)T _ E>~TENDrr.l:3 THE
RE') J E1,<) PER I OD FOR t-1YSELF AND OTHE1':'::;.
THAt',ll< \'ClU,
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Sept. 12, 1992
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To Members of the County of San Diego and City of Chula
Vista Planning Commissions,
This is a request from the Chaparral Greens of East County
to extend the review period for the EIR regarding the Otay
Ranch/Baldwin project by at least another 90 days.
Our group has been worKing diligently to help represent the
thinKing in our community regarding this development. It is
one of the largest proposed developments in the country, let
alone our county and from the 1 imited time which we have had
to study thE- progr-.:..m, '}oJ'? h.;,v€' m.3.ny concerns and quest ions.
The Chaparral Greens feel that the extraordinary nature of
this program is more than adequate reasoning for an
extension of the review period. Our group has been
represented at most County and City meetings to gain
cle.rification and to give our input, but we feel that the
short period for review has left us frustrated, especially
with our public representatives.
As voting citizens we are greatly annoyed that the only
voice that seems to get recognition is that of the Baldwin
Corporation; whose short term involvement with our community
cannot compare with the responsibil ity which those of us who
I ive and worK here will have to endure.
Please respond to our request by granting another 90 days
for us to worK together to insure that as many people as
possible will 'I."in' in the future of this proposed
de'Jt? 1 opmen t.
Sincerely,
~70~l~:r
Chaparral Greens
'J~;> !..)
C)3-
September 12, 1992
Anthony Lettieri
General Manager
Otay Ranch Joint Planning Committee
315 Fourth Avenue, suite A
Chula Vista, CA 91910
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Dear Mr. Lettieri:
since the release of the Otay Ranch Draft Program
Environmental Impact Report for public review I have been
studying the sections relating to groundwater, an area in
which I have some experience and a good deal of concern. I am
a geologist by education (though not by profession) and I
participated in the drafting of the recently adopted County
Groundwater Ordinance, as John Peterson of the Department of
Planning and Land Use can attest.
On the subject of Otay Ranch groundwater, I am very concerned
about some potential problems that the EIR does not address _
at least not that I can find. The areas which concern me are:
1) There are a number of references to the lOa-year
floodplain and what should be done to avoid encroachment,
or to avoid impacts where encroachment is allowed. It is
also stated that each plan will increase impermeable
surface area by some amount (57 percent, in the case of
the New Town Plan). However, I do not find any discussion
of how much the area of the lOa-year floodplain will be
expanded by the increased runoff: or whether, in fact, the
lOa-year flood will become a la-year flood because of
increased runoff.
2) Section 3.9.2.2 makes some statements which I simply do
not understand about groundwater recharge in the river bed
making up for reduced recharge elsewhere: there is
apparently some leap of logic here which surpasses my
knowledge of groundwater hydrology.
3) The discussion (section 3.9.3) of the projected downstream
effects of increased runoff of fertilizers and pesticides
from developed areas is minimal, and refers to a 1991
study which must be analyzed to understand the mitigation
proposed.
4) I find no discussion of saline inflow into the groundwater
dependent areas of the project due to lowering of the
water table from increased pumping and decreased recharge:
is this a potential problem?
1
3~i
It is possible that all these questions are addressed in one
or more of the five prior studies referenced. in paragraph
3.9.1," or . in' other-documents 'mentioned .throughout. the' text,
and I intend to review them as quickly as I can. The problem
is time. The Board of Supervisors and the City Council
allocated a very limited period of.time to. review a document
the size of the Otay Ranch EIR. Upon initial examination of
almost any section of the EIR, the reader finds, as I did in
the case of groundwater, that there are several other
documents that must be studied in order to make a fair and
rational assessment of the EIR.
At your joint meeting on July 30, you agreed that the review
period for the EIR could be extended if warranted. If my
experience in studying the groundwater issue is any
indication, such an extension is clearly necessary if you
want to have a meaningful review of this EIR.
Sincerely,
Clark Waite
.-...
Descanso, CA 91916
cc: George Bailey, Tim Nader
""
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Hon. Brian P. Bilbray
Board of Supervisors - District 1
Hon. George F. Bailey
Board of Supervisors - District 2
Hon. Susan Golding
Board of Supervisors - District 3
Hon. Leon L. Williams
Board of Supervisors - District 4
CHULA VISTA
COUNCIL MEMBERS:
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Septp-mbp-r 12, 1992
Shirley Grasser-Horton
Jerry Rindone .
Leonard Moore
David Malcolm
Hon. John MacDonald
Board of Supervisors - District 5
Mayor Tim I.M. Nader
City of Chula Vista
276 4th Avenue
Chula Vista, CA 91910
County Administration Building
1600 Pacific Highway
'San Di~90, CA 52101
Kr. Anthony J. 'Lettieri, General Manager
otay Ranch Joint Planning Project
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
~XT~NSION OF TIME TO REVIEW ENVIRONMENTAL IMPACT REPORl
DrAY RANCH PROJECT - HEARING DATE: SEPTEMBER 16, 1992@S P.M.
;. jJ"~~:~~'..;.....,:....~~~
As a citizen of San Diego County and a proponent of
ecologically sound community development I request that the
publ ic revie", period of the Otay Ranch Environmental Impact
Report IEIR) be extended an additional sixty days to the date of
Oecmeber 07, 1992.
It is imperative that the EIR revie", period allo", for
thorolJgh and complete analysis of the ecological impacts of this
project. Without such al I o",ance , violation of the COli ifornia
Envi.onmental Qu~1 ity Act ICEQA) guid~1 ;nes may be al leg8d.
CEQA ",as
participation
the ",isdom and
enacted primarily for the benefit
in the environmental revie", process.
foresight to grant this request for an
of pub I i to
Please: h;;vp.
ext~nsion~
I~espect flJ I 1 Y Subm i t t ed,
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Se pt. 13, 1992
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Dear Sirs and Madams,
I have concern over the short time allowed for reading the
ErR regarding the Otay Ranch project. I bel iev" that an
~xt~ntion of r~view period is appropriate due to the length
of compl icated materials in'Jolved in eX@Tlining and time to
respond to such a huge. project.
I am requesting that more time be given so that information
and qu"stions r"garding this program can be "xplored to the
satisf~ction of concerned citizens. I think that at least 3
more months be allowed for the reading and digesting of this
m~.ter'i2.1 .
I appreciate your attention to this matter.
40"#r~
Hal1~iams
/-, ::iLl
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Saptember 13, 1992
An~hony J. Lettieri
Otay Ranch Project Planning Office
315 Fourth Avenue, Suite A
Chula Vista, CA 91910
RE: Public Comment Period, Draft Environmen~al Impact Repor~
Otay Ranch Development
Dear Mr. Lettieri,
I am a member of the South Coast Environmental Working Group. a
coalition of concerned citizens examining issues related to the
proposed Otay Ranch Development. We recognize the need for re-
sponsible public participation within the California Environmental
Quality Act review process, lnd would like to take this oppor-
tunity to comment on the review period that hes been granted for
the Draft Environmental Impact Report.
The Draft EIR reflects the scale of this proposed development in
its legnth and complexity. It i. our desire to provide imput
into this process within the legal intent of CEQA (Article I,
Section 15002-j). After reviewing portions of the Draft ErR, it
has become clearly evident that an extension of ~he revi~w PQriod
is necessary in order to assess the adequacy of this document
under CEQA.
A"minimum of 60 days, beyond the origional comment period "dead-
line~-Ts-necessary in order to gi're this dOCument a fair and
thorough analysis. Included are SOme is~ues that ne~d clacific-
at.ion.
1) RESOURCE MANAGEMENT PLAN
While the RMP is intended to be t.he equivalent of the County's
Resource Protection Ordinance (1992 Work Program Report from
ArCp General Manager, April 29, 1992); it is dlfficult to see
how ordinanca protection can b. applied to a IMP that. "does not
define the "amount of a key resource that should be preserved".
There seems t.o be a direct conflict between the intentions of the.~
two statements.
Objective #6 of the RNP states that it is an objective to "es-
tablish functional connections to on-site resources and in-
1. Y ~
<33.'::>
tegrat~ the management preserve into a larger regional system.
This statement is reinfcrc~d in t11e Draet ErR and yet ~here. is
no cross rQference between the various alternatives in the Draft
EIR and the goals, criteria or preserve design of either the
MSCP or the South County ~CCP.
A prese~ve system as defined in a Final EIR must surely ~~ i~-
tegrated wiht these programs. The MSCP has overlapping juris-
dictional concerns with the proposed Otay Ranch development
and is even being prepared by the sarna biological consultant
(OGDEN), and yet there is no tangllble reference to coordin-
ation of preserve design in the Draft EIR. Without this infor-
mation it is impossible to Objectively assess ~he impacts of
the various alternative plans on a regional preserve srst~ln.
Additionally, Table 1.1-1 states that regional wildlife corridors
would be Significantly impacted and that par~ of the mitiga~ion
for this impact would be the implimentation of the RMP. This
;mitiga~ion is confusing in that it is .not clear which of the
alt.r~atives meet RMP standards.
2)
Section 3.9-14
CHANGE IN SURFACE WATER FLOW RATES
Due to the increase in impermable surface area, increased run-
off would be significant. This section states that drain~ge
facilities would be aligned "ith. creek bottoms.'and lloul,}-.u..-. .."."."
.. ...."..
open "where pu5sibletl. The impa.cts 1.;ould he a.'significa.nt in-
crease in erosion and siltation, and would be addressed by Kjdro-
logic "studi,=:ell at the SPA plan level (3.9.3 PrOpOsr2d Nitigation).
The implication is that if th8 "studies" shot.... an increase in
erosion and siltation that a hYdrOlogist can--- AFTER the EIR
is certified--- finct that all of the tributaries should be
chanalized. This would of course eliminate the~a tributariQs
as natural wildlife corridors. .HOll does this information figure
into a preserve system that would be certified BEFORE these
"studies" tske place?
-.-
3) Section 2.3 -1.5 UNIVERSITY COMPONENT
This section, while stating the reasons (briefly and generally)
for this proposed siting, does not describe impacts to a proposed
preserve system and yet this area has some of the highest concen-
tration of priority IG2 sQnsitive plants and animals (various
maps and tables Within the DEIR) on the Ota} Ranch property.
Also mentioned is that the amount of land reserved for this use
totals "apprOXimately" 400 acres. This is a vague qualifQr, open
to Con~idQrable interpretation. Ha3 there been any c~mmitment
from a university relating to the amount of acreage needed to
fulfill their anticipated acreage needs?
2.
~~
4)
Table 1.1-1
PUBLIC SERVICES AND UTILITIES
The mitigation for impact~ to Water Availablilty and Supply
include a r~f~rence to a water-~;~laimatI~;-p~~gram~-Have-Plans
been developed for this program? When .will it go on line? Will
it be able to accommodate the gradual and eventual buildout?
It is important to have this information in order to assess the
significance of thQ mitigation.
These questions represent a small sampling of issues related to
the adequacy of the Dtay Ranch Draft EIR. In order to identify
issues, compare alternatives and assess mitigations it is
necessary that the pUblic be granted an extension of the review
period.
Thank you for your consideration.
Hiehael Beck
~36
(619) 765-1469
ce: George Bailey
Tim Nader
3 .
637
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September 13, 1992
Anthony]. Lettieri
Otay Ranch Project
315 4th Ave., Suite A
Chula Vista, CA 91910
. --.-------.--- '.
"
Dear Mr. Lettieri
I am extremely concerned about the short public review period for
the Otay Ranch Project. This project will affect many of us who live
and work in the South Bay/Chula Vista area. It seems that there is a
real effort to try and "push it through" without allowing reasonable
time for citizens and agencies to comment.
I have been a schoolteacher for the Chula Vista Elementary School
District for 16 years. I cannot understand this effort to give only 30
days to read and understand a 2400 page document, especially when
many of us must use a public library copy. This project will be
important to our community, and AlL of us need to feel that we
were allowed an appropriate amount of time to learn and comment.
At a minimum, 120 days should be given.
Sincerely,
J;::,t..U1'}-:-~il;~
Kim Hamilton, Teacher
Chula Vista Elementary School District
84 East J St.
Chula Vista, CA 91910
cc: Tim Nader, Mayor
City of Chula Vista
275 4th Ave.
Chula Vista, CA 91910
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Sept. 1.3, 1992
Anthony Lettieri
Otay Ranch Project
315 4th Avenue, Suite A
Chula vista, CA 91910
Dear Mr. Lettieri:
We are asking that the review period for the Draft Environmental
Impact Report for otay Ranch be extended. The DEIR is the
largest we have ever seen. The current October 7 deadline for
public comment is insufficient for adequate review. We believe
that a 90-day extension beyond October 7 is much more reasonable.
Sincerely,
~~
Kenneth Weaver,
Conservation Committee
cc: Mayor Tim Nader
Supervisor George Bailey
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September 13, 1992
Dr. Richard Wright
County of San Diego
Planning Commission
5201 Ruffin Rd., Suite B
San Diego, CA 92123-1666
-------',~.
SUBJECT: Written comments and questions for the Commissioners at
the Joint Workshop on Sept. 16, 1992.
Commissioner Wright:
The agenda for the Joint San Diego County / City of Chula Vista
Planning Commission Workshop to be held on Wednesday evening,
September 16, 1992 includes several items of interest to me.
Unfortunately, there is a conflict with our regular Valle de Oro
Community Planning Group meeting and I will be unable to attend
the workshop to make my comments in person. With this note, I
would convey to you some of my concerns hoping that you and
others will be able to address them on the record. I will obtain
a copy of the minutes of the Workshop as soon as one is
available.
Agenda Item III: Public Comment
Several issues have
review of the DEIR
procedural in nature,
a category of rumor
clarification on these
come to my attention during the initial
for the Otay Ranch Project. Some' are
some are informational, and some fall into
control. I would like to receive
matters - for the record.
Issue: "Lead Agency".
Review. of the DEIR informs me for the first time that no part of
the Otay Ranch Project is within either the city limits or the
"sphere of influence" of Chula Vista. The following citations of
the state CEQA Guidelines and portions of the Public Resource
.Code provide for the determination of the "Lead Agency" for the
purpose of preparing the environmental documentation.
Section 15367 of the Guidelines
"Lead A~encJ" means the public
responsibility for carryin~ out
a~encJ which has the principle
or approvin~ a proiect.
page one of six
3-41
Section 15051 of the Guidelines - Criteria for Identifying the
Lead Agency.
(b) If the project is to be carried out by a nongovernmental
person or entity, the Lead Agency shall be the public agency with
he greatest responsibility for supervising or approving the
project as a woe.
(2) Where a city prezones an area, the city will be the
appropriate Lead Agency for any subsequent annexation of the
area and should prepare the appropriate environmental document
at the time of the prezoning. The Local Agency Formation
Commission shall act as a Responsible Agency.
(c) Where-more than one public agency equally meet the criteria
in subsection (b), the agency which will act first on the project
in question shall be the Lead Agency.
(d) Where provisions of subsections (a), (b), and (c) leave two
or more public agencies with substantial claim to be the Lead
Agency, the public agencies may by agreement designate an agency
as the Lead Agency. An agreement may also provide for cooperative
efforts by two or more agencies by contract, joi~~ exercise of
powers, or similar devices.
Section 21067, Public Resources Code
"Lead Agency" means the public agency which
responsibility for carrying out or approving a
have a significant effect upon the environment.
has the principle
project which may
Questions:
Given the above Guidelines and Code sections, by what authority
did the County delegate the responsibility of Lead Agency to the
City of Chula Vista? The MOU dated August 1, 1989 acknowledges
the abnormal arrangement without justifying it. What "studies"
are underway byLAFCO regarding this project ~rea?
Issue: "Tiering" of the EIR and the proposed GPA.
Several Sections of the State CEQA Guidelines address
of "tiered" EIRs:
the matter
Section 15385 of the state Guidelines
\
"TIERING" refers to the coverage of general matters in broader
EIRs (such as on general plans or policy statements) with
subsequent narrower EIRs or ultimately site-specific EIRs
incorporating by reference the general discussions and
concentrating solely on the issues specific to the EIR
subsequently prepared. Tiering is appropriate when the sequence
o.f EIRs is:
page two of six
3L!~
a) From a general plan, policy, or program EIR to a p~ogram,
plan, or policy EIR of lessor scope or to a site-specific EIR.
b) From an EIR on a specific action at an early stage to a
subsequent EIR or a supplement to an EIR at a later stage.
Tiering in such cases is appropriate when it helps the Lead
,Agency to focus on the issues which are ripe for decision and
exclude from consideration issues already decided or no~'yet
ripe.
Section 21083.3 of the Public Resource Code
(a) If a parcel has been zoned to accommodate a particular
density of residential development or has b~en designated .in a
community plan to accommodate a particular density of residential
development and an environmental impact report was certified for
that zoning or planning action, the application of this division
to the approval of any subdivision map or other project that is
consistent with the zoning or community plan shall be limited to
effects upon the environment which are peculiar to the parcel or
to the project and which were not addressed as significant
effects in the prior environmental impact report. If a
residential development project. is consistent with the general
plan of a local agency and an environmental impact report was'
certified with respect to that general plan, the application o~
this division to the approval of that residential development
_projectshallcbelimited to. effects on the environment. which were .
not addressed as significant effects in the prior environmental '
impact report. Nothing in this section affects any requirement to
analyze potentially significant offsite impacts and cumulative
impacts of the project not discussed in the prior environmental
impact report with respect to the general plan. Section 15152.
Tiering(c) Tiering under this section shall be limited to
situations where the project is consistent with the general plan
and zoning of the city. or county in which the project would be
located.
Discussion:
This section recognizes that the approval of many projects will
move through a series of separate public agency decisions, going
from approval of a general plan, to approval of an intermediate
plan or zoning, and finally to approval of a specific development
proposal. Each of these approvals is subject to the CEQA process.
Question:
I am hearing this week that the 300 page EIR for a proposed
General Plan Amendment will be made available to members of the
public on or about September 22, 1992 for a 30 day review period.
How can this sequence of events be squared ~ith state CEQA
Guidelines regarding a tiered project EIR being appropriate in
cases where the proposed project is consistent with an existing
page three of six
~~~
General
proposed
enormous
Plan? Are we now expected to review and comment on a
GPA EIR at the same time we are wading through the
DEIR on Otay Ranch? Is this feasible? Reasonable?
Issue: Additional alternatives to the project.
I am told there have been informal offerings
alternative to the proposal. This "alternative"
been prepared and "completed" late in the day on
of an additional
is said to have
Sept. 9, 1992.
Question:
Will this be presented
review? What exactly is
members of the Project
period of public review of
to members of the public for formal
this t'alternative" being called by
Team? How will this matter affect the
the DEIR on the proposed project?
Issue: More information available on Wildlife Corridors.
I am told that an updated version of the Wildlife Corridor Study
became available early in September. I have not received it and
formally request that I be sent a copy.
Question:
How does the over 30 day delay in this information getting to
members of the public affect the period for public review of the
environmental documents?
Issue: Clarification of what body will actually make the decision
to extend the period of public review - or not to extend it.
I am .challenging the legitimacy of the City of Chula Vista as
"Lead Agency" on this project. Some have suggested that the Chula
Vista Planning Commission will make the decision regarding
extension of the public review period. If the City of Chula Vista
intends to continue as Lead Agency, can we assume that the Chula
Vista City Council will make the call? At what public meeting? I
am asking for formal notice and an agenda.
Issue: Clarification of lega~ "indemnification".
At the Joint Workshop of the City of Chula Vista and the County
of San Diego where the determination was made for a 60 day
review, a matter of legal responsibility in matters of
environmental documentation arose. The Chula Vista City Attorney
assured the County Board of Supervisors that the City of Chula
Vista was responsible and that Baldwin Co. wo~ld "indemnify" tbe
City. The Supervisors asked for, and seemed to receive, the same
"indemnification" from the Baldwin Co. representatives present.
page four of six
311q
Question:
What is the specific nature
Should Baldwin Co. somehow
some type of bankruptcy,
affected?
and extent of such "indemnification"?
'abandon the project or be forced into
how will such "indemnification" be
Issue: Unpaid bills rumored.
It is rumored that some of the required environmental studies and
fieldwork have been unfunded or payment has been withheld. Is
this true? What specific cases can be made public? Does this
affect the status of the proposal?
Agenda Item IV. B. Public Comment of the DEIR
My comments at this stage
preparing detailed written
will submit them at a later
must be
comments
date.
general in nature. I am
for review and response and
Being forced to assume a 60 day period for review has altered
what could (should) have been a careful' and reasoned review into
a rushed and rather frantic attempt in some cases to cover the
bases. The review period must be extended and not merely 15
days at a time. It is crucial that this enormous and future
determining project receive adequate review by members of the
public and by the responsible decision-making agencies.
Here, I reintroduce my letter dated
determination of adequate period
additional citation of the state
the length of. the usual Summary in
JulV 23. 1992 (attached)
for public review and I add
CEQA Guidelines pertaining
an EIR.
re
an
to
Section 15123. Summary
(c) The summary should normally not exceed 15 pages.
The Summary section in the DEIR for Otay.Ranch runs to 21 pages.
As an additional justification for time extension, I point out
that numerous studies and papers are cited and incorporated by
reference into the body of the DEIR. There must be a fair
opportunity for the public and the decision-makers to review
these supporting materials and to comment on their adequacy and
relevance.
Since the project depends on approval of a General Plan
Amendment, and CEQA Guidelines require the EIR to address the
issue of consistency with the existing General Plan provisions,
how can the public or the decision-makers involved make a fair
assessment of this project until a General Plan Amendment is
page five of six
~Lf(
fully processed,
Amendment should
Baldwin proposal.
. reviewed, an,d
not be viewed
implemented?
as a mere
A General Plan
detail within the
I am requesting that the time eriod for ublic review be
suspen ed uring consideration of the EIR for the General Plan
Amendment. and that the length of public review be reconsidered
when the final decision has been made on that GPA.
I will submit detailed comments on the DEIR at a future date, in
the meanwhile, as an example of its inadequacy, I point to
supporting data and determination of wildlife corridors for the
mountain lion population on the project site. I am told that
proposals for radio tracking and full study were submitted to the
Project Team by resource agencies and that these proposals were
turned down. Is this true? What specific mountain lion studies
have been done? Where can I find the science? Do two recent
sightings of "mountain lion sign" constitute a study? How are
these "corridors" determined in the absence of such science?
In the AppendixA-3, Felis concolor (Mountain Lion} is given no
apparent sta.tus . --1--1--. Is it the position of the Project
Team that Mountain Lions enjoy no protection?
Boiled down, my comments at this
time allowed for full review
sequencing of these proposals.
point are:
and there
there must
must be a
be more
proper
Agenda Item V.
I support the request by the South County Environmental Working
Group for complete documentation in the administrative record of
any and all correspondence between and among all public agencies
and the proponents of this project regarding this project a&d
formation of task forces and teams to work on it.
I continue to follow this project closely and will look to the
administrative record for answers to my questi.ons.
Daniel Tarr
11524 Fuerte
El Cajon, CA
619 588-4863
Farms Rd.
92020
~
~
Sincerely,
cc: State Office of
Diego County Board
members, Otay Ranch
Planning Commission,
Planning and Research, Members of the San
of Supervisors, Chula Vista City Council
Project Team, Chair of the Chula Vista City
South County Environmental Working Group.
page six of six
:;;; 1/ ID
SAN DIEGO AUDUBON SOCIETY
(89' MgnC~JA DC/D. eTC. :Zl2:i . <::.o.~J nISGiQ, CA, 82117 O1Sf 1€a 7(:0
ber 14,1992
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norma Sullivan
5858 Ser;/,I'" St.
San ;]);0<)0, C'a. 92122
thony J. Lettieri
Otay Ranch Project
315 4th Avenue, Suite A
Chula Vista, CA 91910
Subject: Draft EIR, Otay Ranch Project
Dear Mr. Lettieri,
Again we ask for an extension of the public review period for the DEIR for
Otay Ranch. The deadline is now October 7. This simply is not enough time
to review a project so large, complex, and innovative. The document, as you
know, is 2400 pages long, and, now that we have it, we find it is not an easy
document to analyze, what with the many alternatives, appendices, etc.
Major land use decisions are involved, with a chance to ponder and evaluate
criticill new ideas, for the benefit of us all. The decisions will affect the
quality of life for ALL San Diego County residents, now and forever. Such
decisions simply cannot be analyzed responsibily in 60 days.
Further, we find many, many knowledgeable people.are,eager and willing to
comment on the DEIR. We have many experts within the ranks of our
membership. We are, thus. sharing our copy of the document, which saves
money and trees for us all, but necessitates more time for review.
We ask for at least 90 days beyond October 7.
Thank you for your consideration.
Ctilv.u.z ~(((V~
Norma Sullivan, Conservation Chair
CC: George Bailey, Chairman, Board of Supervisors
Tim Nader, Mayor, City of Chula Vista
15-+1
-----
----_._~--_.-."...._----_.._., ------'-..._-_..-...._.~._._-'
de Treville
Environmental Engineering
4131 Normal Street . San Diego, CA USA 92103-2654
(619) 296-1192
FAX (619) 2ro.o266
September 14, 1992
:P'If2 (c~ r:~ ji"{,; ~'\
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~:Y
Mr. Anthony J. Lettieri
Otay Ranch Project
315 - 4th Avenue, Suite A
Chula Vista, CA 91910
Dear Mr. Lettieri:
Please extend the comment ?eriod of the DEIR for the Otay Ranch
Project by at least 30 more days. The sheer magnitude of the
2400 page draft requires greater scrutiny and more time.
Two iSSUES of .concern are:
1) Water reclamation
2) The coastal sage scrub destruction, and the unique life forms
which live in this habitat.
:;t:;;;;a~
Susan de Trevil1e
Environmental Planner
cc: Tim Nader
George Bailey
S.D. Co. 3d. of Supervisors
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September 14, 1992
..
.',
Board of Supervisors
county Administration Center
1600 Pacific Highway
San Diego, CA 92101
OTAYRANCH PROJECT - REQUEST FOR EXTENSION OF TIME TO REVIEW THE
DRAFT ENVIRONMENTAL IMPACT REPORT BEYOND OCTOBER 7, 1992
I am writing as a concerned citizen of Jamul .and on behalf of the
Chaparral Greens to ask that you help" .to effectuate an extension' of.
time beyond the 60-day review period, that is, beyond October 7th,
for the public to participate and review the draft EIR lest you go
against the quintessential CEQA process of WIDE PUBLIC INVOLVEMENT.
While studying the Guide to CEOA in conjunction with the Otay Ranch
draft EIR I note that our California Supreme Court, in landmark
cases repeatedly emphasizes the importance of public participation.
Although we know that our courts generally defer to the ultimate
political decisions of you, our elected officials, we also
recognize that our Supreme Court says CEQA should be scrupulously
followed so that the public will know the basis on which its
responsible officials either approve or reject environmentally
significant action and will be able to respond accordingly .to
action with which it disagrees. It seems that the EIR process was
designed to protect not only the environment but also informed
self-government. Please do not deny.. your constituents this
opportunity for informed self-government.
Since the EIR process enables the public to determine the
environmental and economic values of their elected officials, this
procedure allows citizens to take appropriate action come election
day should a majority of voters disagree. The 13,000 votes our
nascent Green Party environmentalist candidate 'for Board' of
Supervisors received in the June primary as a result of our grass-
roots campaign tells me that your constituents deserve an "ear"
that developers' contributions 'cannot buy: Please give us your
ear, too... Please listen:.
g LfJ:Y
city ef Chula vista ceuncil Members
OTAY RANCH PROJECT
, ,September,14, 1992
Page 2
. ,. .'. ~;... '-.
',. -
.-. ..
-' . -.-.-. . .
Centrary to. the myth that these ef us requesting 'participation are
"little eldladies who. have nething better to. de..with"theirtime
than attend hearings,!' yeu sheuld knew that we are a multicultUral
gender-and-age--balal'l::::ed greup cf ,"emmuni,tTcTtizens, who. c'are,deeply
abeut eur envirenment and eur gevernment.' ,
','"-
Centrary to. the myth that these ef.. uswhem yeu might pejeratively'.
label . "envirenmentalists" care mere abeut birds than peeple (a
stupid, uninfermed statement!) yeu sheuld knew that we care yery
much abeut the ecenemy. Any theughtful persen knews we need
balance here. We leek to. yeu eur leaders to. help create that
stabili ty. I
I was appa~led to. hear (during an Otay Ranch werkshep) Mr. Jamriska
jekingly tell Mr. Arbuckle that he "weuld, give him a few mere
units" when Arbuckle paid-him a compliment. I was appalled to. hear
(dur'ing the July 30 hearing) Mr. Bilbray interrupt Mayer'Nader, who.
was propesing at least a 90-day review peried for the draft EIR,
remark: '''But.', she's stacked a let, better"- ,( referring' . to.
Councilwoman Herton)~This kind of public sexual harassment when
discussing the size efthe draft EIR is net a jeking matter. Our
erlti,re Eco-system is at stake, here.
Our laws ensure that members ef the public hold a "privileged
pesitien" in the CEQA process. Such status reflects both a belief
that citizens can make .impertant co.ntributio.ns to. envirenmental
pretectienand to. demo.cratic decisio.n-making. PLEASE GIVE US THIS
OPPORTUNITY ,NOH bJ' granting us another 90 days ,fer review.
~
I'd like to. thank the Otay project staff fer their ceeperatien.
They are well aware ef our diligence in reviewing the EIR and eur
need fer an extensien ef time to. complete the review.
{?~'
CAROLYN Z. O'PATRY
Member, Chaparral Greens
P.O. Bex 1009
Jamul, CA 91935
cc: Anthony Lettieri, General Manager
OTAY RANCH JOINT PLANNING PROJECT
~su
SEP-15-92 rUE 17:10
US FWS
FAX NO, 6194319624
p, 02
FISH 1"-''11) WILDLIFE SERVICE
FISH AND WILDLIFE ENHANCEMENT
Southern Cplifornia Field Station
Carlsbad Office
2730 Loker Avenue West
Carlsbad, California 92008
.- -
- II
United St.:'1tes Department of the Interior
Anthony J. Lettieri, AICP
General Manager
otay Ranoh Joint Planning Project
315 Fourth Avenue, suite A
Chula Vista, California 91910
September 14, 1992
Re: Review of the Environmental Impact Report for the Otay Ranch, San Diego
County, California
Dear Mr. Lettieri,
The U.s, Fish and Wildlife Service (Service) is presently reviewing the
Environmental Impact Report (EIR) for the Otay Ranch. We are concerned that
w@ will not be able to adeq~ately review this large document and provide you
with thorough and complete comments on t.opics within our area of technical
expertise and jurisdiction by law prior to the October 7, 1992, deadline.
Bassd on the exceptional length of this document and the complexity of the
SUbject project the Service recommends that the comment periOd deadline be
extended to allow a thorough review of this unusually complex project. The
Service requests that the comment periOd be extended for 90 days. We belieVe
this is reasonable given the size of the EIR, the complexity 0< the project,
and the number of technical appendices.
The project site is biologically extremely important. The proposed :;>roject
will result in significant and unmitigated impacta eo !ederal and State listed
endangered species, federally proposed endangered Dp~cies, :ederal candidate
species for listing aa endangered or threatened, and habitats of concern t~
the Service, including wetlands. As stated by the EIR, significant and
unmitigated impacts will Occur to sensitive uplands and wetlands including
vernal pools, seven state-listed endangered plant species, fiva sensitive
plant speoies, least Bell's vireo, coastal cactus wren, California
gnatcatcher, Quino checkerspot, Riverside fairy shrimp, regional raptor
populations, wildlife corridors and OVer 50 other sensitive species. We
strongly recommend that additional time be allowed to ade~~ately review the
subject document.
We appreciate your consideration of this request. If you have any questions
or comments. please contact Nancy Gilbert of this office at (619) 431-9440.
RiChard Zembal
Deputy Field Supervisor
cc, CDFG. La Mesa, CA (Attn: T. Stewart)
County of San Diego, San Diego County, CA (Attn, Chairman Bailey)
City of Chula Vista, Chula Vista, CA (Attn: Honorable Mayor Nader)
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SEF-15-'92 TUE 14:.51 ID:WANKET OFFICE SUPPLY
TEL NO:619 ~43 1751
~947 POL
Sho...,lin.. Study C.'lltrr
September 15,1992
Anthony Lettieri
Otay Ranch Project
315 4th Avenue, suite A
ChulR Vi~ta, CA 91910
Re: DEIR for otay Ranch Project
Dear Mr. Lettieri:
We request an
Many factors
quirelllent.
extension of the public review period to 90 days.
point to the necessity to observe this CEQA re-
consider the creation of a new town -- the core of this 23,000
acre project. Many of these acres are sensitive habitat. Addi-
tional acres are prime prospects for restoration. surround these
acres with fast-growing san Diego county and you have nothing
less than an "unusual situation" (per CEQA Guidelines).
When the public is faced with an Environmental Impact Report of
over 2400 pages (well in excess of the 300 maximum recommended by
CEQA) it's "unusual".
A request for all correspondence between the applicant and all
entities is outstanding.
The mapping is too poor to support making judgements on a pro-
posed preserve. Failing to map a watershed or area containing
sensitive habitat before designing a project is common but not
tolerable. Preserve assessment and its mapping should be done
first.
PUblic
review
largest
input is the heart of CEQA.Please extend the public
period to encourage the best possible project in this
remaining tract in San Diego county.
, President
ce: Tim Nader, Mayor
Geor~e Bailey, Chairman
San Diego ~oaru ~f cupcrvi~orR
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Anthonv J. Lettieri
Otay Ran~n Project
315 4th Ave., Suite A
Chula Vista. CA 9101r~
Dear Mr. Lgttieri
I alII ve~-'y CDr-ICernec .:3.bout the ';llort time f Ot... pub i ic ccmment
on the Otay Ranch PrQJec~. ThlS project will affect many OT
us ~'Jno 1 ive ~...ncl lrlor'K ln tr-Jl2 S':Juth B-3.y/Chul do IJista. a.t-'ea. I~:
sa ems that there is 2 real effort tQ try and I'PUSh it
t:.lr-'c>u.:;;n'l :,.o~i-::'nclu-c a.1 i O~'IJ.ng r-e~...s-on.=..t:li 2 time '~cLr citizens. -s.nc::
agenc!es to comment.
As a resIdent' 0+ the South Bay area. I know that tMis
prOJec~ wi11 D2 Impor~ant to our ch:loren ana comffiuni~y.
ALL of us neeD to feel that we were allowed an appropria~e
3ffiount of tlme ~o iearn, reflec~, 2nd comment.
:5 i ncet-'ei y,
~~
cc: Tim Nader, Mayor
City of Chula Vista
275 4th Ave
Chula Vista~ CA 91910
c=: George Bailey! Chalrm~n
San Diego Ccun~y Bcare Q~ Supervisors
1600 PaciflC Hignway
San Dlego, CA 92101
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Community
Planning
Group
.'
15 September 1992
Subj:
City of Chula Vista Planning Commission
County of San Diego Planning Commission
Draft Environmental Impact Report (DEJR) on the Otay Ranch
General Development Plan and Subregional Plan.
Sweetwater Community Planning Group
To:
From:
The Sweetwater Community Planning Group requests an extension of the DEJR
public review process until after 15 November. After an initial review of the rather
overwhelming documentation and some questions posed to the Joint Project Team
representative at the groups regular meeting of 1 September 1992, the following
motion was passed unanimously with 10 members present and voting:
The DEIR for this project does not deal with the California Gnatcatcher as an
endangered species. The U.S. Rsh and Wildlife Service is due to make a
determination on the bird's status in a few weeks. The California Department
of Fish and Game decision not to list the species was set aside by judicial action
last week.
If either of these agencies act to list the Gnatcatcher the DEIR will not be
adequate and the project will require redesign. Rather than go forward at this
time it would be prudent to continue the work on this until after 15 November
to allow USF&W and CDF&G to deal with the Gnatcatcher problem.
An additional point the Planning Group would like to raise is that of the County
abandoning its responsibility for Lead Agency on this DEIR. This project is com-
pletely outside of the civil jurisdiction of Chula Vista and only minimally within the
Chula Vista Sphere of Influence. The Planning Group would be much more
comfortable if the planning and development standards of the County were being
applied to this project.
dLL~
John Hammond
Chairperson
~st
P.O. Box 460, Bonita, California 91908-0460
IY .oi_____...~ _ ~,_ .~..~. ~._ .._ w. -
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FROM SUPERUISOR G BRILEY
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P. 4
FROM SUPERVISOR G S~ILEY
09.24.1992 1P05
~~4~z-;(,d-: ,.444?-c/ ,4v~' ya;.1./#~ft-/~'/;
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o
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_I
THE CITY OF
((,19) 423-8300
~AX (&19) 429-9770
IMPERIAL
8EACH
825 IMPERIAL BEACH BOULEVARO . IMI'~RJAL BEACH, CALIt'OKNIA 91932
G).~".......
' .,.
~...
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-
September 16, ]992
Anthony J. Lettjeri
Ot~y Kaneh Vroject Planning
315 Fourth AVe., Suite A
Chula Vistn, CA 9]910
I)c.ar Mr. Lallieri:
lam a member of the City Council of Imperial Bcach. As you are well aware, my city is
likely to be immediately affected by Ihe proposed Olay Ranch project. 111erefore, I am very interested
in having Ihe opportUnity to properly review the Program EIR. Unfonunately, 1 will be unablc 10
accomplish this goal in 60 days. I am !1:4Uesting that you extend the comment ~riod for an
additional 60 days.
I am panicularly concerned because the project may have a detriment.1l impact on the entire
region's water, solid waste disposal and circulation infrastructUfC. Funhennore, the l'rognuTl ErR
makes the a.~sumption that the County General Plan will be amended to fit with tile project. If so. it is
Ollly proper thaI the proposed amendmentS 10 the General Plan be reviewed in together with the EIR.
It will ortly he possible to properly analyze the ErR if you extend the public commcnt period.
Sincerely,
/?1 ~ Co ~~__
M..rti C. Goethe
Hayor Pro Tom
City of Imperial Rench
~I
____ _._-_ _~'_ o.__,~~,_o
_. h ~
0_'_'_0_______ _
September 16, 1992
Mr. Anthony J. Lettieri
Otay Ranch Project
315 4th Ave, #A
Chula Vista, Ca. 91910
"
Dear Sir:
I am writing to express concern regarding the length of time allowed
for review of the Draft Environmental Impact Report (DEIR) for Otay
Ranch. Due to the complexity of this proposed project and its impact
upon the residents of the Southbay, I request that the review period
be extended beyond October 7.
As a 15 year resident of Chula Vista, and as a new homeowner in
Eastlake Greens, I am particularly concerned that the quality of life
in our city be protected. I appreciate your consideration of my
request.
ex:: Tim Nader, Mayor
City of Chula Vista
275 4th Avenue
Chula Vista, Ca. 91910
~6,3-
FRI ENDS. OF BATI gUITDS
LAGOON,
p . 0 ' :s 0 x Z 7 3 6. ~ E' U C.A D, I A '. C A, L I FOR N I A 9.2 0 2 4
.' ..r
~eptember 17, 1992
"
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II~v 'SEP 2'1 ;' iilll!f
IU~ I~ ' '
i ,,' I'
Mr:, Anthony Lettieri
Otay Ranch Project
'315 4th Avenue, Suite A
'Chula, Vista, CA 91910
RE: Drafi EIR for OtayRanch Proj~ct
Dear Mr. L~~tieri:
lve.
for
respectfully request
the above project.
"
an extension of the public
review period
The Environmental Impact Report of 4000 pages (including the,
appendices) is more than ,10 times the number' of pagesrecommended
by CEQA (300 pages). ',The project covers 2300 acres, and will be
a city_' ,unto, itself" when completed. ,Rare" threatened and
endangered, species inhabit these 'acres, some of w'hich are'covered
with plant ,and wildlife, communities.on the edge of extinction.
San, Diego ,County' will be greatly ,altered b'y,this project. It is
unique' andtinusual in every aspect, and, qualifies in everi way
for an extension beyond the usual 45 - 90 days. The intent of
CEQA is that public officials and public citizens be provided
adequate time to review, and digest the proposal, t.O imagine.. the '
project, visit the site, and consider the imp4lll!'!'ll.....,;rii'this.(:as~,~.-
even ninety days imposes'a hardship. We ask for 180 days.
Review
mapping,
project
regional.
program,
regional
of this project has also been hampered b~ inadequate
and by the proponen~'s failure to spell out how the
coordinates with the MSCP and other attempts at planning
preserves. If the county is serious about' its MSCP
this project must include,and be' included in the
perspective.
A good project cannot be rushed. We ask you to
public review period to 180 days and allow this
unusual project the time it takes to make it
good project, but a best possible project.
extend the
exceptionally
not just a
ue:iJ
Dolo", "'~
Conservation Chair
cc: Tim Nader
George Bailey
~fc?:J
Or -''--.7'''IJ~~1
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.
September 19,1992
1702 Yale St.
Chula
, Vista,
C2"-
91913
Mayor Tim Nader
City of Chula Vista
276 4th Avensue
Chula Vista, CA 91910
Dear Mr. Mayor,
I would like you to know that there is a great deal of concern in
the coc;rntmity with regards to the planning for the otay Ranch project. If
the review period for the Environmental Impact Report is limited to the
existing period, there is a high probability for litigation. I would
suggest that if the revievl period takes 90 days or \'lhat ever additional
time is necessary to thoroughly study the report, it \.;Quld be time well
spent to mollify the public's apprehensions.
Sincerely,
Robert E. Tugenberg
cc: Tony Lettieri
~lo if
..~\....'--~.-"''''--_. ,~. ~-~~.~. ..-."."# .'.~""'-"~~.,. -----_._~-_.--
,
CROSSROADS
RESIDENTS WORKING TO KEEP CHULA VISTA A NICE PLACE TO LIVE
Cuol Freno
President
"
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Bill Robens
Vice.President
.~)i
,
ScP 2"
Will Hyde
Treasurer
September. 20, 1992
.~ \ \1
Alan Campbell
MAyor Tim Nader
Members of the Chula Vista City Council
276 Fourth Avenue
Chula Vista CA 91910
Memhe~
Lowell BIanJ:fort
WilllillT1 Cannon
Subject: Otay Ranch Environmental Impact Report
JO'U'\ie Fu!a.sz.
Our members have been reviewing this sub j ect documenLarid bel ieve
that due to the scope and magnitude of the Otay Ranch project, we
and other members of this community cannot complete our comments
during the presencly allowed review period. A development of this
size will affect all aspects of our environment and life in the
South Bay and reauires a great deal of scrutiny.
George Cillow
Jc:rry Griffith
Tom Pasqua
FrJl'l.k SCOt[
We therefore ask that you and the Board of Supervisors extend the
review period at least an additional sixty days.
. Peter Warry
Cuy Wright
Since the City is renuesting additional consulting staff assistance
it would seem the public could have a longer interval to review all
of this most important information.
Thank you.
C~~
Ca ro 1 Freno
cc:
Tony Lettieri, General Manager
Otay Ranch Joint Planning Committee
~
P. O. Box 470 . Chula Vi",_ CA. 91012 . phone 411.3773
~roC::
P.02
22 '3~+ LQ92.
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County/Chula Vista Planning Commission
publ ic Hearing/\'7orkshop - September 16, 1992
DRAFT
36
\lorking Group, meet to discuss what is needed and I'/ork out
any complications: The motion failed by the following vote:
AYES:
Commissioners Brown, Kastelic, Leichtfuss and
\^1right
NOES:
Commissioners Ferraro and Kreitzer
ABSENT:
None
VI. PLANNING COmUSSIONS cormENTs TO BOARD OF SUPERVISORS/CITY
COUNCIL REGARDnlG PUBLIC REVIEl'1 PERIOD
Hr. Lettieri referenced the letters received from groups and
individuals requesting an extension of the public review
period of the Draft EIR. On July 30 the Board of Super-
visors recommended to the City Council that the public
review be initiated for a 50-day period and the right for
reconsideration on September 24 reserved. Council supported
that resolution with clear knowledge that the decision I'las
the City of Chula Vista's. The Planning Commission had re-
questQc this item be on today's Agenda with full knowledge
that the Board of Supervisors and City Council were going to
reconsider the item on the 24th. The item was placed on the
Agenda to afford the opportunity for the individual Commis-
sions to input to the Board and the Council their experience
in reviewing the DEIR and whether GO days is appropriate.
The local CEQA Guidelines will rest with the Chula Vista
Planning Commission, but both Planning Commissions are being
given the opportunity to address the issue. Options include
giving/not giving input or designating a representative to
ma]~e a presentation at the neeting of September 24.
Commissioner Carson asked if the Board of Supervisors and
City Council had the DEIR or any of the documentation in
front of them so they could see the volume of the material
and ho\'! technical it was I'lhen they !':lade their decision?
She was ans\'!ered that they had been told of its size but did
not receive copies until the next day.
Commissioner Decker asked \Vhy since the City is the Lead
Agency and the Planning Commission could summarily e::tend
the public reViel'l period, I'las the issue referred to the
Board of Supervisors and City Council? He was ansl'lered that
the public reviel'l period issue had not been addressed at
that time, staff had needed direction from the legislative
body on ho\'! long the notice of public hearing should be
posted since 3,500 notices had to be mailed. There \Vas a
disagree!':lent regarding whether the time span should be the
3)bX
Joint CountyjChula Vista Planning Commission
Public Hearing~lorkshop - September 16, 1992
37
statutory 45 days' or be extended to 60 or more. It was felt
to be too important a decision to be made at staff level.
Commissioner Decker spoJee in support of a time extension
based on the many issues involved that required time to
study and learn. He said he derived benefit from listening
to the members of the public particularly those who were
I'/ell-qualified in the field they discussed as they produced
insights not available in just reading the documents.
Commissioner Ferraro remarked that he knew of no project
larger than the Otay Ranch in the State of California.
Because of policy implications, the comple::ity of the DEIR,
the response and interest of the public he was of the
opinion that he would be better informed and make a better
decision if he had an e::tended period of time. He suggested
that the time be extended to 150 days.
Commissioner Wright interjected as a point of order that the
issue should not be discussed by the Commissioners until
after public testimony had been received.
The Chair asked for comments from the public.
Mark Monti10. 1875 Honev SprinGs Road. Jamul. CA 91935.
iIr. Ilontijo said he lias speaking as the Chair of the Jamul-
Delzura Community Planning Group. His Group's support of an
extension of time is based on the impact the project would
have on the East County since several thousand acres of the
development are in the Jamul-Delzuro sub-regional planning
area. Hr. 1I0ntijo outlined the responsibilities of the
elected representatives of this Planning Group as lIell as
the method by which they reviewed the DEIR. The Jamul-
Delzura Community Planning Group, after a good-faith effort
to study the DEIR during the allotted time, voted unani-
mously to recommend a minimum 120-day review period. They
requested cooperation of the Commission in presenting the
recommendation or, if necessary, in the exercise of its
statutory ability to e::tend the time period.
John Hammond. 3012 ,;nderson St.. Bonita. CA 91902, Chair of
the SI'/eetwater Community Planning Group. Hr. Hammond said
he had submitted a letter tonight raising t,,/O issues, one
relative to the gnatcatcher and some questions on jurisdic-
tion and requesting an extension of time. lIr. Hammond said
the size of the DEIR is incredible and it is very difficult
to focus on those issues of concern to his Group. In the
Bonita and Sweewater Valley area they are very concerned
Ilith the impacts of SR-125 and the outflml froQ the project.
~9
Joint County/Chula Vista Planning Commission 38
Public Hearing/Uorlcsilop - September 16, 1992
nore time is needed to revieH just the circulation and air
quality impacts. The Group has requested extension to
t10vember 15 at the minimum but would support a longer
extension of time for public reviel'l.
In response to a question by Commissioner Leichtfuss, Hr.
Lettieri explained that CEQA Guidelines mandate that the
Commission make the determination to extend the public
reviel-I period, hOHever, the Board of Supervisors and the
City Council at their July meeting had said they Hanted to
relook at the issue. The October 7 meetina would be an
appropriate time to determine whether or n6t an extension is
needed from that date. Hhat l'les ~lanted today I'las an opinion
from either or both of the Commissions regerding the ade-
suecy of the length of revieH time.
rlSUC (Ferrara/nright) 6-0 for the County Planning Commission
to recommend to the Board of Supervisors that the public
revieH period be extended an additional 60 days making for a
total of 120 days.
rlSUC (Decker/Carson) 5-0, Fuller and Ray out, for the Chula
vista Planning Commission to recommend to the City Council
that the public revieH period be extended an additional 60
days making for a total of 120 days.
Commissioner Carson said that in case this was not extended
on the 24th, she would like to make a motion at this time to
have the publ ic rev ieu per iod e::t ended an addi tional 60
days. If the Commission feels strongly enough to make a
recommendation for e:;tension, it should feel strongly enough
to take action.
L1r. Lettieri e:-:pressed his concern the.t \'lhen this hearing
and the October 7 hearing were advertised, the notice sent
to over 3,000 people had said that the October 7 hearing
would determine closing the public revieu period.
The Commissioner acknm-lledged the problem, said she l'Iould
not make a motion tonight but assured the audience that on
October 7 she I-Iould move to extend the revievl period another
60 days if it hed not been done.
Mr. Lettieri spoke to the Commissions' indication that it
Hould be helpful to have other presentations; such as, the
Regional Biology Studies Hhich are in the report. To make
them more meaningful he suggested that there might be a
formal presentation of the biologist from the regional
perspective no'c only the Resource :lanage::1ent Plan. He
J-)[)
Joint CountyjChula Vista Planning Commission
Public HearingAlorkshop - September 16, 1992
39
suggested that for the October 7 hearing it might be pos-
sible to discuss the water issue and have a representative
from the California Water Authority present as well as Ogden
Environmental on the EIR. He said he would '~ork "ith the
Chairs of both Commissions to put together that final
program to assist the Commission in understanding the
background information.
Commissioner Carson requested that all who had given public
testimony at tonight's meeting be sent a copy of the final
Agenda. Or. Lettieri agreed and asked anyone vlho had not
filled out a slip with their name and address to do so.
Suggestions from the Commissioners included the Transporta-
tion Phasing Plan, the sewer issue and corollary sewers, the
~'1ildlife Corridor Study and a broad look at the fiscal sco;.:e
of the project. fIr. Lettieri said staff would come up I'lith
a formal program of environmental issues and see if they
could be scheduled appropriately. He would bring the Agenda
program to the Commission on October 7.
Presently the Service Revenue Plan is scheduled on October 9
which is also the first public hearing at which the Commis-
sions were going to get into the substance of the project
and the staff recommendations. Depending on Council's
action on September 24 or the Commissions' on October 7, the
schedule may be revised.
The Draft ,':ilalite Corridor study is in the Commission's
packet in the technical appendi:. A presentation was made
on the Hildlife Corridor Study, the Draft Phase I Study.
The Draft Phase II Study ,.,as submitted to staff last week
and will undoubtedly be complete within a month. The
Commissioner said she "ould 1 ike to have the technical
appendices of that report.
VII. ADJOURNHENT at 8:38 p.m. to the Joint San Diego CountyjCity
of Chula Vista Planning Commission Public Hear-
ingjl'7orkshop f.leeting on ,'lednesday, Octobe r 7,
1992, at 5:00 p.m. in the City of Chula Vista
Council Chambers
;;:e=C'-/ Cif
Ruth 11. Smith
Secretary
iJ-71
~(f?
~~~~
"'-........-:....~
-:....- -~
CllY OF
(HUlA VISTA
OFFICE OF THE CITY COUNCil
MEMO
DATE: October 6, 1992
TO: commissioner Carson
FROM: David Malcolm
RE: Otay Ranch
----------------------------------------------------------------
----------------------------------------------------------------
First let me thank you for taking your time to discuss the Otay
Ranch project. It's unfortunate that the council has not kept the
commission better informed during this process. If I may repeat
myself "It is not the council's intention to take over any EIR
review". I hope our joint meeting will be short and the public
review period will close prior to October 19, 1992.
/
I have enclosed the agreement between the County of San Diego and
the City of Chula vista. I have also enclosed a copy of the
indemnity agreement which expires on october 19, 1992.
Should you have any questions please do not hesitate to call. Also
the city Attorney Bruce Boogaard will be glad to answer any
questions at 691-5037.
67-+
276 FOURTH AVENUE/CHUlA VISTA, CALIFORNIA 91910/(619) 691-5044
MEMORANDUM OF UNDERSTANDING
BEnJEEN THE
CITY OF CHULA VISTA MID
THE COUNTY OF SAN DIEGO
TO ESTABLISH A JOINT PLANtnNG PROJECT TEAr1
FOR THE PROCESSItJG OF THE OTAY RANCH PROJECT
August 1, 1989
INTRODUCTION
The Baldwin Company is preparing a development plan fOf the Otay Ranch which
is located within the unincorporated area of the County of San Diego. Two
jurisdictions with potential final land use authority include "the City of
Chula Vista and San Diego County. Both jurisdictions have chosen to be
actively involved with the preparation of the necessary plans and documents
and with the final approval of the entitlements listed below. Both
jurisdictions have adopted similar Statements of Intent.
The purpose of thi s Memorandum of Understandi ng is to permi t and encourage
both jurisdictions to share personnel, costs and ideas with a goal of jointly
foroi ng and crea ti ng necessary documents, plans and enti tl ements for the
project acceptable to both jurisdictions and consistent with the Statements of
Intention. While both jurisdictions intend to retain their independent
governmental authority to review the project, both jurisdictions have
vol untarily entered into thi s t~emorandum of Understandi ng and have agreed to
cooperate to form a joint planning approach in an attempt to develop a single
set of entitlements acceptable to both jurisdictions. It is agreed that such
an approach is advantageous because:
1. The size of the project (34 sq. miles).
2. Although the entire Otay Ranch property is within the
unincorporated area of the County of San Diego, the City of
Chul a Vi sta' s General Pl an shows 42% of the Ranch property as
within the City's planning area. This same 42% of the Otay
Ranch. has been desi gnated a speci al study area by LAFCO. The
entire area will be the SUbject of a Sphere of Influence Study.
3. Such a large area will generate an inordinate number of complex
social, economic, environmental and other concerns.
4. This requires the application of available governmental
resources.
5. A central clearinghouse is needed for the convenience of
interested citizens, organizations and various groups.
~)3
Therefore, the joint planning approach, reflected in this Memorandum of
Understandi ng, has been developed to r.1eet the above concerns. It is the
intent of both jurisdictions, through thi s ~1emorandum of Understanding, to
work together, diligently, to achieve concurrence on specific plans and
actions to be taken concerning the future development of the project.
The City Council and the Board of Supervi sors have agreed that thi s
cooperati ve approach waul d best serve the ci ti zens, organi zati ons and the
various groups who ~ay have interest in or concerns about this project.
THE JOINT PLANNING APPROACH
A. Authorized Work - This includes all work leading to the adoption of
General Plan Amendments (GPA's) a General Development P]an, Master
Development Agreement(s), Tiered EIR and all necessary environmental
documentati on, Sphere of Infl uence Study, Servi ce/Revenue Pl an, and an
Annexation Plan. Thi, work will be governed by a comprehensive work
program acceptable to both jurisdictions and consistent with the
respecti ve Statements of Intenti on. The work program shall be prepared
within 45 days following approval of the Memorandum of Understanding. All
of the above entitl ements are to be consi dered and acted upon by both
jurisdictions prior to the processing of subdivisions.
The scope of work developed for the above listed entitlements .shall
compri se the total assi gnment of the Joi nt Pl anni ng Project Team and the
Inter juri sdi cti ona 1 Ta sk Force. Thi s ~~emorandum of Understandi ng shall
remain in effect for the time necessary to complete the above-listed scope
of work or until such time in the future as it is deemed appropriate that
this Memorandum of Understanding shall no longer have effect. This
Memorandum of Understanding is limited to the above-listed authorized work
and no other work shall be undertaken pursuant to thi s ~~emorandum of
Understanding unless authorized by both jurisdictions.
Approach - The City and the County will each process a separate GPA.
However, the GPAs will be based upon one development proposal and joint
staff work.
The County GPA i ncl udes consi derati on of a shi ft of the Urban Limit Li ne
to extend' the Current Urban Development Area (CUDA) Regional Category.
This property may be placed in the Specific Plan Area (SPA 21) Plan
designation. The SPA 21 may include specific text in the Subregional Plan
setti ng forth the development pa rameters for the' requi red Speci fi c Pl an.
This text mag require that development conform to the development plan and
phasing plan approved by both the Chula Vista City Council and the Board
of Supervisors. The City and County are expected to process future land
use approvals consistent with a joint plan and consistent with the
respective Statements of Intention.
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B. Lead Agency - The City of Chula Vista is hereby designated as the lead
agency for processing the authorized work described in "A" above. Ch~lla
Vista shall be responsible for coordinating all of this work with the
County and with the Interjurisdictional Task Force.
Although the County of San Oi ego bel i eves tha t under norma 1 ci rcumstances
the County would be the lead agency for the environmental review of this
project pursuant toCEQA, the County agrees that, in order to most
efficiently process this joint project, the City of Chula Vista shall be
the lead agency for the environmental review process.
Since part of the planning will include a prezoning of the property,
California Adllinistrative Code 5 l505(b)(2) allows a city to act as lead
agency. Lead agency responsibility for the EIR shall by agre!!ment be the
City of Chula Vista, u~der Section 15051 (d) of the CEQA Guidelines. The
County shall provide staff resources for full review of all environmental
documenta ti on produced by the Joi nt Pl anni ng Project Team's consultant
prior to EIR certification by the City of Chula Vista and with County
input.
City will fully consult with County, as a responsible agency, in the
preparation of all environmental documents. Prior to certification by the
City of Chula Vista, the San Diego County Planning Corrrnission and the
Board of Supervisors shall be afforded an opportunity to review, comment,
and hold public hearings on the ErR. Any resulting EIR revisions,
mitigation measures, and overriding findings by the Board of Supervisors
shall be incorporated into the final ErR by the City of Chula Vista.
C. Staff and Consultant Resources County and City will provide the
necessary staff resources and jointly retain consultants as necessary to
carry out the authorized work described in "A" and "B" above. The
attached organization chart illustrates the staff and consultant resources
currently expected to be committed to this project.
All consulting contracts shall be with the City of Chula Vista and in
accordance with its procedures for letting contracts. Prior approval
shall be obtained through the County's Chief Administrative Office.
The cost of providing staff and consultant resources shall be recovered
from depos its made by the app 1 i cant.
D. Service/Revenue Plan - A service/revenue plan shall be prepared which will
outline municipal and regional service and infrastructure
responsi bil iti es, and how they are to be fi nanced, i ncl udi ng capital
outlay, maintenance and operational costs. This plan may include service
agreements with all affected agencies, as well as revenue sharing
agreements as deemed appropriate. This plan may also include separate
agreements on fees and exactions, the potential for alternative methods of
financing such as Mello Roos districts, assessment districts and/or other
means of financing short and long term facil ities and service costs.
Specifics of this plan will be set forth in the scope of work.
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The f~aster Property Tax Agreement adopted by both the Board of Supervi sors
and the Chul a Vi sta City Council shall not apply to thi s pl an unl ess
specifically agreed to by both governmental bodies.
E. Sphere of Influence and Annexation Agreement - A sphere of infl uence
agreement and an annexation agreement shall be based on the
servi ce/revenue pl an and 1 and use pl an. The sphere agreement and the
annexation agreement shall be processed concurrent with the GPA and shall
be included in the scope of work described in "A" above. Decisions on
said agreements are expected to be executed prior to LAFCO action on the
Sphere of Infl uence. The Sphere of Infl uence must be adopted by LAFCO
prior to implementation of formal annexation plans. (This necessary LAFCO
action is outside the 9-14 month time line in the Statements of Intention
and requires an additional 60-90 days.)
F.
Confl i ct Pesol uti on - The recommendati ons of the 'Interjuri sdi cti onal
Force shall be considered during the processing of the General
Amendment.
Task
Plan
The work program for this project shall include consideration of a Dispute
Reso 1 uti on proces s for reso 1 vi ng any City/County di sagreements and any
disagreements with the Baldwin Company. While the exact nature of the
proces s will be determi ned as pa rt of the work program, it is expected
that the Dispute Resolution process will provide for appropriate levels of
sta ff, consultant and/or I nterj uri sdi cti ana 1 Ta sk Force revi ew. Thi s wi 11
provide for a more independent review by the consultants, staff and/or
Interjurisdictional Task Force and place disagreements in a more complete
context for the policy makers.
Failure to reach consensus between the two jurisdictions may be cause for
independent review and decision by the affected jurisdictions.
G. Notice - Reasonable notice shall be given to the other party when either
the Board of Supervisors or the Chula Vista City Council places an item on
their respective agendas pertaining to the Otay Ranch project.
H. Defi niti ons
General Development Plan - a description of the development proposed
within a particular planned community consisting of, at minimum, a map and
written statements setting forth, in general, ~he location and arrangement
of all proposed uses and improvements to be included in the development
and the policies and regulations governing it.
Master Development Agreement/Public Benefit Agreement - An agreement that
is "layered" and developed as the key elements of the work program are
approved by the governing jurisdiction(s). The initial stage of the
Master Development Agreement will include issues related to the General
Plan and the General Development Plan. Subsequent stages of this
agreement will include issues related to adopted (or to be adopted)
implementation measures such as Specific Plans and Tentative Maps.
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Upon comp 1 eti on of the Mas ter Oeve 1 opment Agreement proces s, the pub 1 i c
benefits and entitlements of the development shall include a co"'plete
range of issues including regional and site specific.
1. Ar.lendments - Th is agreement
Board of Supervisors.
;j ,Ii}
/(;Juo",X!7.<.' '
Gregory R Cr;r, r1ayor
City of Chula Vista
may be amended by the Ci ty Counci 1 and the
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L
I Susan Golding, Chairman
San Oi ego County
Board of Supervisors
~
VH/mad
\IPC 6366P
Attachments: Organizational chart for the Joint Planning Task Force
Appro>ed 1Qd/ or 8IltlIorizecI by tl>e Board
of Supeniaon of lIIe Covllly 01 SalIIliiau
August I, 1989 (35)
a-a+ /l ~
Cieri of !to.! Boern M S"oeni",,,
DISTRIBUTION:
CERTIFIED COPIES OF THE AGREEMENT SENT TO:
CITY CLERK, CITY OF CHULA VISTA
P. O. Box 1087, CHULA VISTA, CA 920LO
MR. VERN HAZEN
OTAY RANCH PROJECT MANAGER
315 FOURTH AVENUE, SUITE "A"
CHU LA V I ST A, CA 92011
Ms. CLAUDIA TRIOSI
SENIOR VICE PRESIDENT
THE BALDWIN COMPANY
11975 EL CAMINO REAL, SUITE 200
SAN DIEGO, CA 92130
DEPUTY CAO (A6) ATTN: LARI SHEEHAN
MA I LED: 8-11 -89MA T
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OTR'-rI RRnCH
"'OINT PLANNING '..OJICT
COUNTY Of u.N DIECO . CITY Of CHUl.h VIsrA
I~ ,i
'lJv
I
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~,
Gordon Ho"Ward .
County Realonal
Planner
Richard Zumwalt .-
Asst Planner
County
. ,
I : _ r.,
CITY OF CHULA VISTA
CITY COUNCIL
COUNTY OF SAN DIEGO
BOARD OF SUPERVISORS
TECH ADVISORY
COMMITTEE
(CITY)
DEPT HEADS/
REPS
Em Consult.a.n:t
Dames lie Moore
Ralph Kin~ery
Project Mgr
Terry Clapham
ProJeot Dlr
John Burke
De Dir P.W.
Gary W. Cane
Prinoipal C.E.
Steve Thoma5 ...
City
Sr Civil Eng
I T..,,..-,r!'l (lffi,....,...
Interjurisdictional Task Force
Executive Staff. Committee
VERNON HAZEN.
CENERAL MANAGER.
JOINT .PLANNING
PROJECT TEAM
(OVER FOR LIST OF NAMES)
Lar! Sbeehan, County Deputy CAD
John Goss, City Manager and
selected staff members
TECH ADVISORY
COMMITTEE
(COUNTY)
DEPT HEADS!
REPS
Marin" Brand - CQ
Env Mgt Spco III
PlannlngjEng
Consultant - RBF
John Sullard .
City/County EIR Unit3
Doug Hoid .
Clly ltnv Coord
Trame En.II
CO:Z:lInllt~t - JHK
Dan U..nnn
CITY/COUNTY
JOINT PLANNING
PROJECT TEAM
Hal Rosenberg
City Trc.ffiQ EDg P /T
Sally Shaler-Finch
CO A.:lI:!IOC Trans Plnr P/T
Secretary /
Office Manager
Linda Boed .
Duane Ba.zzel *
City
Senior Planner
Manuel ldollincdD, Dir
Shauna Stokes. Pr AQalyst.
City Parks Plannlna: PIT
R. B. Claire
County Parle: Planner PIT
")1 <:; mlTP'T'1l "'VFN1TF:, S11I1'E A, ('HTTT,]I. HTC:'T'1I rll. Q1nl0 -- (Filq) 42)-7157
INDEMNITY REGARDING PROCESSING OF ENVIRONMENTAL IMPACT REPORT
FOR OTAY RANCH
The undersigned, Baldwin vista Associates Ltd., a California
Limited Partnership ("Baldwin"), with reference to the following:
R E C I TAL S
WHEREAS, Baldwin is the owner or agent of a 22,700 acre
parcel of land located wi thin the County of San Diego ("county")
territorial limits and has submitted to the county an application
for a General Plan Amendment and to the City for a General
Development Plan, along with other entitlement requests, to
facilitate development approvals for the project known as "Otay
Ranch" which Baldwin proposes for said land; and
WHEREAS, a draft Environmental Impact Report ("EIR") has
been prepared for said applications pursuant to the California
Environmental Quality Act ("CEQA") and the State CEQA Guidelines
("Guidelines") and is required by said laws to be submitted to a
public review period; and
WHEREAS, the Guidelines provide that the public review
period for this type of project shall be at least 45 days and
should not be longer than 90 days except in unusual situations; and
WHEREAS, Baldwin believes that a
than 80 days is entirely
of this particular project
bound to the City of Chula
public review period of
appropriate given the
and by this documents
vista ("City") and the
not greater
circumstances
agrees to be
county,
NOW, THEREFORE, Baldwin does hereby irrevocably offer to
the city and County, to defend, indemnify and hold harmless the
county and City, and each of them, and their respective officers,
employees, and agents from and against any litigation which is
commenced against them which alleges or complains that the public
review period ending prior to October 19, 1992 for said
Environmental Impact Report is inadequate or not in compliance with
CEQA or the Guidelines. This is a unilateral offer to indemnify
which offer is to be accepted by closing the public review period
on or before October 19, 1992, and not by any other act of the City
or County. Upon closing such public review period on or before
October 19, 1992, this offer shall be deemed to be accepted by the
city and County and this offer of indemnity shall become, at that
point, a binding and irrevocable contract.
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The one and only condition of such binding contract is
that City, County and Baldwin shall each have the right to approve
of counsel to represent them in such defense and each shall have
the right to approve the tactics with which any litigation should
be conducted and each of them agree that their approval shall not
be unreasonably withheld.
This offer of indemnity shall remain irrevocable until
October 20, 1992, and if not accepted by that date, shall be deemed
to have terminated of and by its own accord; otherwise, it shall
not be revocable, or be revoked by Baldwin.
Dated: September 24, 1992
BALDWIN VISTA ASSOCIATES, L.P.,
a California Limited Partnership
By: Baldwin Builders, Inc.,
a California corporation,
General Partner
By:
Gregory T. Smith, President
F:\homc\attomey\otayindm
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NOTICE OF A SPECIAL JOINT MEETING OF THE CITY COUNCIL OF THE CITY
OF CHULA VISTA AND THE CHULA VISTA PLANNING COMMISSION
NOTICE IS HEREBY GIVEN that the City Council of the city of
Chula vista will meet on October 12, 1992 at the Chula vista
Council Chambers, 276 4th Avenue, Chula Vista, CA at 6:00 p.m.
SAID PURPOSE OF THE MEETING is a public hearing to consider
the Draft Program Environmental Impact Report for the Otay Ranch
General Plan Amendments and General Development Plan/Subregional
Plan.
DATED: October 8, 1992
Beverly A. Authelet, City Clerk
'" declare under penalty of perjury that I am
employed by the City of Chula Vista in the
Office of the City Clerk and that I posted
this AgcncjafNotice on the Bulletin Board at
the Public S rvi as Building an at City Hall
DATED, 0 '%, :2 SIGNED