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HomeMy WebLinkAboutRCC AGENDA PK 2004/09/13Crossroads II RESIDENTS WORKING TC- KEEP CHiTLA VISTA A GOOD PLACE TU LIVE KEQUEST FOR RECIRCULATION OF DRAFT EIR ESPANADA SPCIFIC PLAN The lead agency should recirculate the "Hvdro[ogyiDrainage/Water Quality', "Traffic, Circulation & Access ", "Population & Housing "and the "Alternatives" sections of the F.cpcrnadn Specific Plan Drafr EIR. CEQA has a provision Tor recirculation of a Drafr EIR if "Significant new information is added involving: • A significant new impact; • A substantial increase in the severity of an impact; • "The addition of a considerable different, feasible mitigation measure or alternative, or • A fundamentally flawed F.IR." Cl1 believes these circumstances are applicable here, as specified in the fi>llowing table. Aaaendix G Issue Omissions Justifyin>? SiQmficant New Recirculation _ Information Substuntiully alter the esis[ing rlruiazuge pattern of the site or carea_. Exeeed._u level of~service stundard esttthlished by the county congestion munagenzent agenrv for designated rnacls of highways Resub in inadequate parking capacity The drafr does nut address whether ~ A firndamentally or not the project would obstruct flawed FIR the flow of water between the townhouse portion of the project and property at 3~8 and 360 Roosevelt St. This issue was raised in response to the NOP. __ The draft does not include or A fundamen[a/Iv address a Congestion Management flawed EIR Program, as required by SANDACi. i The project applicant is requesting 4 fundamentallt~ shared parking for elements of the flawed EIR project and an overall reduction of l0% in required parking. This inforn~ation is not mentioned in the Draft EIR, which contains no data on the number of parking spaces that the project would provide, and no analysis of the adequacy of that narkine. XR2~.Espnada - Recnculation lush Gcati°n Cause an increase in traffic x~hich is substantial in relation to the existing h•q~c load and capacity o% the street system... Displuce substantial numbers q% people _ - -- The drafr fails to evaluate an alternative involving all traffic accessing the project from H St. This is a feasible alternative because a signalized intersection will be provided at Garrett and H Sts. in connection with Gateway phase 2/3. Such an alternative would avoid significant unmitigated traffic impacts to Roosevelt St. The EIR assumes that the city will establish a relocation assistance program for displaced residents. I"his is not true. The fact that no relocation assistance program will be offered represents a substantial increase to the severity of this The addition of u considerably different, feasible mitigation measure or alternative .Substantial increase to the severity of an impact Submitted to Chula Vista Resource Conservation Commission, September 13, 2004 XR2:f?spnaJa - Rcarculation Justification Crossroads II RESIDENTS WORKING TO KEEP CHITI,A VIS'T'A A GOOD PLACE TO LIVE COMMENTS ON ESPANADA SP,E'CIFICPLAN DRAFT EIR Land Use & Planning The BIR identifies 'Y'onfllet with any applicable land use plan...." as a threshold of signiGcance_ Table 4.1-1 clearly shows that the Fspanada Specific Plan conflicts with Chula Vista's adopted General Plan. Yet, language in the Land Use & Planning section of the EIR states: "Under the adopted Chula L'ista General Plan, the proposed Espanada Specific Plan project would result in direct and cumulative unmitigated impacts to traffic, us well as cumulutive unmitigable impacts to visual qualityiue.cthetic.c. " l'he above conclusion is no[ based on land use and planning impacts. The "Traffic, Circulation and Access," and "Visual Quality/Aesthetics" sections of the report already identify significant unmitigated traffic and visual quality/aesthetics impacts. 7~he Land Use and Planning section should acknowledge significant, unmitigated land use impacts based on the EIR's own criteria. "l~he final report should correct this error. 7 raffle, Circulation and Access This section of the report is inadequate in several respects: (1) It fails to address pedestrian circulation-this despite the fact that this issue was specifically called out in responses to the NOP. In urban areas pedestrian access is a critical element of circulation and access. (Z) It fails to address impacts to the local state freeway system-this despite the tact that this issue was called out in a response to the NOP from the Department of Transportation. (3)"The EIR states: "Although required to mitigate the cumulative impact associated with the H Street segment, from Third Avenue to Fourth Avenue, dedication and construction of nn exclusive westbound to northbound right turn lane from H Stree[ trr Fourth Avenue would not be feasible because the applicant does not own the land parcel situated at the northeast corner q/ Fourth Avenue and H Street that would require construction of the lone dedication. If at the time of project approval, the applicant does own the Lund parcel, dedication and construction of art exclusive westbound to northbound right turn lane from H Street to Fourth a'R2:Fspanada f!R Comments .4verrue would he feasible. However, future lured ownerships and acquisitions are not known at lhi.c time. " This statement makes no sense. Without acquisition of this parcel (Area C in the Conceptual Development Plan), the project could not proceed. The final EIR should clarify this point. (4) Despite several responses to The N9P, and the fact that pazking is not allowed on H Street or Fourth Avenue, and on only one side of Roosevelt Street, incredibly the EIR does not address parking impacts except to say, "The proposed Espanada Specific Plan project would provide udeq:uue on-site marking facilities in accordance with 'Title 19 n/the City of Chula vista Municipal Code. "'This is a wrong and completely inadequate way of addressing parking. Perhaps authors of the Draft EIR did not read the Draft Specific Plan, which states: "Proximity to Transit..4 10% reduction in all parking requirements within the Urban Residential rConzmercial Zone (Areas.4 c~ C) may be granted by the Redevelopment Director for anv development located within 1.000 feet of an existing or proposed transit station (identifred in the General Plan)." Granting a 10% reduction in parking requirements on the basis that the project is 1,000 feet from a transit station that will not be in existence for at least ten years (per telephone conference with Mark Stephens, City Planning and Building Department) is totally unacceptable- This critical issue must be analyzed in the final EIR! In addition, the report should include the following table: PARKIN(, DATA Required Der Code Provided by Protect Resident iul ? Retail Restaurant If the numbers in [he eohunns do not match, the EIR should analyze the effects of the deficiencies. (5) Page 4-Z of the Draft states: "The Ciry orChula Vista has developed significance thresholds for certain environmental issue areas as part of the City's Growth Management Policy. These significance thresholds provide the basis XR2.Fspanada EIR Commcn~s Jnr distinguishing hefiveen impacts w{rich are determined to be signiJicunt and those which are less than signiJiearat. This F.IR uses the Citv's Thresholds oJ.Significance. except in cases where none have heen developed. " Despite this statement, the Traffic, Circulation, and Access section uses the 2000 Highway Capacity Manual instead of the city's growth management thresholds to determine levels of significance. This section of the EIR must be rewwritten to deternine significance of traffic impacts based on the correct standard. Public Services and Utilities (1) Schools: Again, the E1R is internally inconsistent in that it uses the CEQA guidelines instead of the city's growth and management thresholds. The final EIR must re-analyze the impact on schools using the correct significance threshold. Further, Crossroads II disagrees with the conclusion in the Drafr EIR that because the developer must pay impact fees for school services, this is sufficient to mitigate impacts to schools to below a level of significance. These impact fees cover less than half of the cost to finance needed facilities (which is why the Mello-Koos assessment is levied in new commm~ities in eastern Chula Vista). This is even more of an issue with this project because all three servicing schools (Vista Square Elementary, Chula Vista Middle, and Chula Vista High) would be over design capacity with implementation of the project. 'fhe final EIR should acknowledge significant, unmitigated impacts nn affected schools, and the City Council should be required to adopt overriding considerations for schools should they decide to adopt the specific plan. (2) Energy: The document neglects to address the impact of the proposed project on energy supply and services. This critical assessment is missing despite recent history of local brown- outs. and despite the fact that one of the responses to the NOP specifically asked that the EIR address a green building. 'T'his analysis should be provided in the Final EIR. Population and IIousing We have learned from Steve Power that the F.IR is incorrect when it states (pages 3-6 and 4.1 1-~) that the city will provide relocation assistance to displaced residents. Obviously, this grievous and misleading error must be corrected in the Final EIR. Further, Crossroads II disagrees with the EIR conclusion that no impact would result from the displacement by the project of 148 people. Any time people are displaced there is an environmental impact. This section of the EIR should be revised to indicate a significant population and housing impact because of the displacement issue, and the City council should be required to adopt overriding considerations should they decide to approve the specific plan. 3 X R 2. Fspanada E l R l ortimcnn Alternatives Despite the horrific, unmitigateable, significant traffic impacts the FIR acknowledges will occw on Roosevelt Street, a quiet residential street, the Draft EIR does not analyze a project alternative that would have all traffic access to the project site from H Street. Again, the need for evaluation of such an alternative was addressed in response to the NOP, but simply ignored. The final report must contain such an analysis. Comments submitted to Chula Visa Resource Conservation Commission, Sept. 13, 2004 ~R2'Espanada EIR Comments Cross~-v~ds II RESIDENTS WORHING TO KEEP CHULA VISTA A GOOD PLACE TO LNE Position Parser Espanada Specific Plan September 13, 2004 Summary: As currently proposed the project creates uomitigatable, significant environmental impacts. Yet, the project is being processed for action before any requirements for off-setting amenities have been agreed-upon. These requirements will be established by the Lirban Core specific Plan (UCSP). Therefore, action on the project should be postponed until completion of the UCSP. Failing that, the reduced density alternative identified in the Draft EIR that avoids signifcant environmental impacts should be approved. A. CII believes the application for this project has been submitted prematurely. Commitments have been made to existing residents of the "urban core" that their quality of life will not be degraded by redevelopment, and that the negative impacts of redevelopment would be offset by amenities such as wider sidewalks, public urban. plazas, pocket parks, etc. It is our understanding that rules for providing these amenities are to he established by the UCSP. "The Draft EIR acknowledges that the Espanada project will generate significant, unmitigateable trafFe and visual impacts. (Although not acknowledged as such, we contend that the EIR analysis also proves that the project will have signiticant unmitigated impacts on schools and land use: Schools, because the project would add more students to schools that are already operating beyond their design capacity; and land use because it reyuires an amendment to the city's General Plan) The project will generate these negative impacts before UCSP requirements for compensating amenities have been identified. Therefore, we think the city should urge the applicant to temporarily withdraw his application until completion of UCSP, at which time it can he re- submitted and evaluated in light of the provisions of that plan. B. Ifthe applicant refuses to temporarily withdraw his application, then we believe the city should deny the project as proposed and instead adopt "BIR Alternative Three Reduced Density Project." The F,IR concludes that adoption of this alternative would meet most of the project objectives. Ilowever, the reduced-density alternative would lower traffic impacts to below the environmentally significant level. 'T'his alternative would also allow the condo towers to be built as mid-rise buildings instead of high-rise, which also reduces visual impacts to a level less than significant In this event, the applicant should be reyuired to I) fully meet the city`s parking standards; 2) relocate the existing Gateway monument sign in the middle of the sidewalk on H St. to a location outside of the public right-of-way; 3) design and construct "green" buildings; 4) provide a relocation assistance program for the 140+ residents that will be displaced by the project. XR2. Fspanazia Portion °npe~ CROSSROADS II GENERAL MEETING THURSDAY, SEPTEMBER 23 6:00 PM CIVIC CENTER LIBRARY Fourth Ave. and F St. GUEST SPEAKER: DANA SMITH, COMMUNITY DEVELOPMENT DEPARTMENT Dana, and members of her staff, will speak on the "Redevelopment of Northwest Chula Vista." and will also be available to answer questions and hear your comments. Many of you have been asking important questions about traffic, overcrowded schools, the lack of park space and the displacement of people now living in the redevelopment areas - in other words about the quality of life for residents already here. THE FOCUS OF THIS MEETING WILI, BE ON THE I-IiJMAN IMPACTS OF REDEVELOPMENT. Please come! See the dramatic changes being considered. Talk with Crossroads II Steering Committee. Ask questions. Express your opinion