HomeMy WebLinkAboutPlanning Comm Reports/1992/02/05 (4)
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 1
1. PUBLIC HEARING:
Rancho San MiQue1. General Deve100ment Plan. Draft
Environmental Imoact Reoort. EIR-90-02
A. BACKGROUND
The document whi ch thi s staff report refers to is a Draft Envi ronmenta 1
Impact Report (DEIR) which addresses the proposed general development
plan for the Rancho San Miguel project.
B. RECOMMENDATION
That the Planning Commission open the public hearing on the Draft
EIR-90-02, take public testimony, and continue the hearing until February
12, 1992, in order to meet the requirements of the Clearinghouse that a
45-day revi ew peri od be allowed whi ch will end on February 6, 1992. (The
continuation of the hearing will permit staff time to incorporate
addi t i ona 1 comments from the C1 eari nghouse that may be recei ved
subsequent to February 5, 1992.)
C. PROJECT DESCRIPTION
The Rancho San Miguel project site consists of approximately 2,590 acres
(divided into two portions) in the southwestern part of San Diego County,
south and east of the Sweetwater Reservoir and adjacent to the
northeastern border of the City of Chu1a Vista. The Rancho San Miguel
project site is predominantly composed of steeply sloping hillsides,
valleys, and Mother Miguel Mountain. The area is dominated by coastal
sage scrub, mixed chaparral, and non-native grasses. The entire Rancho
San Miguel project site is currently unincorporated and within the City
of Chu1 a Vi sta' s adopted sphere of i nf1 uence. The property is bounded
generally by Proctor Valley Road on the west and south, the Otay water
treatment facility and San Miguel Mountain on the east, and the
Sweetwater River and Reservoir on the north and northwest. A caretaker's
house and associated buildings with horse faci1 ities are located in the
western corner of the northern portion of the property. The north and
south portions of the project site are separated by property owned by San
Diego Gas and Electric, which contains the Miguel Substation complex and
associ ated transmi ssi on 1 i nes . Several utili ty easements traverse the
project site. Much of the 2,590 acres of 1 and that make up the project
site have been utilized during the past 80 to 100 years as grazing land.
The majority of the Rancho San Miguel site is undeveloped land. The
1,852-acre northern portion of the property includes Mother Miguel
Mountain and foothills that slope to the north and west toward the
Sweetwater River and Reservoir, and Coon Canyon that drains into the
reservoir. The 738-acre southern portion includes several significant
landforms, Horseshoe Bend and Gobbler's Knob. Wild Man's Canyon, a
narrow canyon, wi nds between the northern and southern port ions of the
development in two fingers, as shown in Figure 2-1. Elevations within
the property range from 200 feet above mean sea level (MSl) to 1,527 feet
above MSl at the top of Mother Miguel Mountain. More than half of the
property consists of slopes in excess of 25 percent.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 2
Vegetat ion onsite is characteri zed by coasta 1 sage scrub, mi xed
chaparral, non-native grassland and riparian scrub. A majority of the
northern portion consists of high quality native vegetation communities,
considered to have high wildlife habitat value.
The Rancho San Miguel GDP is principally regarded as a proposed
single-family detached residential community which will provide a range
of housing products with lot sizes varying from 5,000 square feet to 1
acre. Development wi 11 take place withi n a 1,852-acre northern port i on
and a 738-acre southern portion separated by SDG&E property. The GDP
proposed 1,654 s i ngl e-family residences, and al so integrates the
following proposed components: a 14-acre commercial center; an 11.2-acre
elementary school site; a 20.5-acre community park; a community purpose
facil ity; a 7-acre conference center/retreat and inn; a 6-acre
interpret i ve center; pedestri an and bi cycl e tra il s connect i ng Rancho San
Miguel to the surrounding community and the Chula Vista Greenbelt; and
approximately 1,653 acres of natural open space. It should be noted that
the Chula Vista General Plan land use map designated a substantial
portion of the northern portion of the project site as open space,
cons i st i ng primarily of Mother Miguel Mountain and associ ated steeply
sloping lands surrounding the mountain.
Northern Portion
The 1,852-acre northern portion of the site principally consists of
Mother Miguel Mountain. The GDP proposes 1 imiting most of the
development to the foothills and plateaus on the western side of the
site; the interpretive center, conference center, and inn would be
constructed on steep slopes at a higher elevation (approximately 800 feet
above mean sea level). Individual building envelopes would be graded for
each of the proposed 357 lots; the average lot size would be 1 acre. The
GDP proposes spl it level structures, stemwall foundations, and post and
beam construction to minimize the impact of the homes. The appl icant
would include a brush management program.
The 6- acre interpretive center woul d be constructed on a promi nent knoll
on the northern side of the mountain. It would include trail heads, a
parking lot, informational displays, view points, a small amphitheater,
and perhaps a botanical garden. The 7-acre conference center/retreat and
inn woul d be constructed adjacent to the interpretive center It woul d
include a 20- to 30-room building and approximately 20 small cottages,
for a total of up to 50 guest rooms, and meeting facilities for 200.
The applicant proposes to include wildlife undercrossing areas under
roadways in the northern portion to allow wildlife access to the
Sweetwater Reservoir.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 3
Southern Portion
The majority of the project development would take place in the southern
neighborhood. In addition to the 1,297 residential units proposed for
the southern neighborhood, there are plans for a 14-acre commercial
center, an 11.2-acre elementary school, a 20.5-acre community park, and a
designated community purpose facility.
The commerci a 1 center is proposed to be located at the intersect i on of
Rancho San Miguel Parkway and the proposed State Route 125. The
elementary school would be located on the loop road west of an SDG&E
easement and woul d be central to the development, servi ng the needs of
the 1 argest population segment of the communi ty and surroundi ng area.
The community park would be located adjacent to the elementary school
facil itating a joint use relationship between the elementary school and
the greater community. An open space trail system would be incorporated
into the southern neighborhood, connecting to the northern neighborhood,
and would provide an area for protected pedestrian circulation, hiking,
biking, and equestrian activities.
Circulation
San Miguel Ranch Road is proposed for the southern portion in a general
east/west al ignment from Bonita Road to East H Street. East H Street
wi 11 pass through the southeastern tip of the southern port i on. Access
to the northern portion will be provided via San Miguel Ranch Road.
Residential roads will provide access to the interior areas of the
proposed site.
A new al ignment is proposed for the extension of San Miguel Ranch Road
that is proposed as a bypass (access) road to be located offs ite to the
west and adjacent to the site. The bypass portion of San Miguel Ranch
Road is proposed to el iminate the need to widen San Miguel Road to
provi de site access. County approval woul d be needed to impl ement the
access road, and an Amendment to the County's Circulation Element of the
General Plan would also be required, as this roadway is not shown in the
Genera 1 Plan. However, the access road is cons i stent with the Ci ty of
Chul a Vi sta General Pl an. The transportation sect i on di scusses traffi c
circulation in the area that will occur as a result of buildout of the
General Plan and development of the proposed project.
D. IMPACT ANALYSIS
The environmental analysis performed for the proposed project includes
the following issues: land use, landform/visual quality, biology,
archaeology/history/paleontology, geology/soils, mineral resources,
convers i on of agri cultura 1 1 ands, hydrology, water qua 1 ity,
transportation/access, air quality, noise, community social factors,
fiscal analysis, public services and utilities, parks, recreation and
open space, compliance with threshold standards/policy.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 4
Environmental Analvsis
land Use
Deve 1 opment of the northern port i on of the site is potent i ally
i ncompat i bl e with the Sweetwater Reservoi r due to degradat i on of water
qual ity from urban runoff. Mitigation for this impact includes approval
of storm water management plans that are expected to reduce significant
water quality impacts to below a level of significance.
Portions of the trail system crossing SDG&E easements are not acceptable
to the City Parks and Recreation Department. This represents a
significant impact for the GDP. The modification of the proposed trail
system at SPA 1 eve 1 to locate all trails entirely withi n the project
boundaries will reduce impacts to below a level of significance.
locating residential units adjacent to SDG&E Miguel substation is a
significant impact. The provision of a white paper describing SDG&E's
expansion plans as well as achievement of general visual separation
through 1 andscapi ng, topography vari at ion, etc. and provi s i on of site
grading plans and other information to SDG&E to assist them in developing
future improvements on their site may reduce impacts to below a level of
significance.
Based on the City's consistency analysis development in the southern
portion was found to be inconsistent with the Chula Vista General Plan in
several areas: character of development, compatibility with adjacent
use, lot sizes, encroachment into open space/greenbelt systems, overall
dens ity, preservat i on of s igni fi cant 1 and forms , cl usteri ng and 1 andform
grading.
The impacts are significant and unmitigable with the project as proposed.
landform/Vi sua 1
Gradi ng techni ques for the proposed interpretive center and conference
center on slopes greater than 25% are not discussed in the GDP;
therefore, landform/visual impacts are unknown.
This issue shall be evaluated at the SPA level.
Significant topographic features in the southern portion of the site
(Horseshoe Bend and Gobblers Knob) will be removed by extensive grading.
The landform impacts are considered to be significant and unmitigable
with the project as proposed.
Horseshoe Bend and Gobbl ers Knob are s i gni fi cant vi sual 1 andforms. Both
of these landforms ri se preci pi tously 200-300 feet above the surroundi ng
terrain to the north, west, and south, with side slopes exceeding 25
percent in many areas. Both landforms are visible from the eastern
portion of the Bonita area, and areas to the south along the alignment of
East H Street. Both landforms will be visible from the future al ignment
of SR-125. The two landforms are named on the U.S.G.S. map for the area.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 5
Therefore, development on Gobblers Knob and Horseshoe Bend must be
sensitive to these significant visual landforms. In order to meet the
General Plan criteria for development of such . significant visual
landforms, and therefore not create a significant environmental impact,
the applicant has two clear choices:
(a) Propose development on Horseshoe Bend and Gobblers Knob which is in
conformance with Policies 6.5 (Hillside Development) and 7.7
(Landform Grading) of the Land Use Element; or
(b) Cluster development away from Horseshoe Bend and Gobblers Knob and
preserve these two landforms in their natural state.
The proposed project meets neither of these two choi ces. It proposes
removal of Gobblers Knob and extensive alteration of Horseshoe Bend in
confl ict with the Chula Vista General Plan. Therefore, the impacts to
1 and forms in the southern port ions of the site are cons i dered to be
significant.
The impact of placing homes in close proximity to future expansion area
of SDG&E is significant and unmitigable with the project as proposed.
Visual impacts of putting in large and conspicuous potable water storage
tanks and the degrading of views from a small portion of East H Street
could be mitigated to below a level of significance by evaluating the
visual impact issue of water tanks at the SPA level and implementing
landscaping and development plans to reduce impacts to views to below a
level of significance.
Biology
Significant and unmitigable impacts with the project as proposed are as
foll ows:
Biodiversitv
Disruption of biodiversity of the site.
The Rancho San Miguel site supports one of the richest and most
di verse assembl ages of uni que and sens it i ve bi 01 ogi ca 1 resources in
Southern Ca 1 iforni a. Of speci a 1 importance is not only the
biodiversity in terms of species numbers, but more importantly, the
sizes of the popul at ions of the sens it i ve resources. The
gnatcatcher, cactus wren, barrel cactus, Palmer's grappling hook and
Otay tarplant all represent regionally significant populations. The
gnatcatcher population represents up to 10% of the County-wide
popul at i on. Thi rteen sens i t i ve plant speci es and twenty sensit i ve
animal species are known to occur on the project site.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 6
Regi ona lly significant popul at ions of coast barrel cactus and San
Diego cactus wren are also present onsite. Individually, many of
the 33 sensitive species found on the site would be considered
significant resources. The high diversity and large population
sizes of these resources compounds the significance of the site for
biological resources.
The northern port i on of the project is contiguous with an exi st i ng
gnatcatcher population occurring throughout the Sweetwater River
Valley to just above Singing Hills Golf Course that likely exceeds
150 pairs. This could represent as much as 10 percent of the U. S.
population of gnatcatchers. The northern portion of the site serves
as a major movement corridor between the Otay Mesa area to the south
and the Sweetwater Reservoir.
This combination of a high diversity of rare plant and animal
species with high population densities, and its proximity within a
much larger regional open space preserve cumulatively make this site
one of the most significant parcels of undeveloped land remaining in
San Di ego County for bi 01 ogi ca 1 resources. Impacts to bi odi vers ity
of the site are significant are unmitigable.
Coastal Saqe Scrub
Loss of 467 acres of Diegan Coastal.
Di egan Coastal Sage Scrub is cons i dered a sens it i ve habitat by the
County of San Di ego, Ca 1 iforni a Department of Fi sh and Game and
United States Fish and Wildlife Service.
The County of San Diego considers the Diegan Coastal Sage Scrub a
sensitive species due to the fact that 70% of the Coastal Sage Scrub
is now gone. Birds and animals that are dependent on the community
are impacted and could eventually be listed.
Otav Tarweed
Impacts to roughly 70 to 80 percent of an estimated total of 200,000
individual Otay Tarweed. (Dense populations are endangered.)
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 7
Coast Barrel Cactus
80% of an estimated 8,000 individuals would be impacted by the
project.
As the Coast Barrel Cactus has a Category 2 listing with the United
States Fish and Wildlife Service. This means the federal government
is currently considering listing this as a threatened or endangered
species in California although it is common elsewhere.
Palmer's Gravvlinq Hook
All of the estimated 11,000 individuals on the site would be
impacted.
The California Native Plant Society has given both Palmer's
Grappl ing Hook and Cal ifornia Adolphia a #2 1 isting. This means
that the California Native Plant Society is aware of the plant's
restriction locally and that the California Fish and Game Department
and the U. S. Forest Service will be observing whether or not
developments plan "around" this species. The individual loss may
not be important but the cumulative loss is a concern.
California Adolvhia
85% of an estimated total of 350 individuals would be impacted by
the project.
Gnatcatchers
The wildlife species of highest sensitivity in the upland habitat is the
Cal ifornia gnatcatcher. The proposed project will significantly impact
this species. The plan would cause direct impacts to 40 (58 percent) of
the existing 69 pairs and would partially impact 8 additional pairs (12
percent). Partial impacts would be expected for pairs which were
observed adjacent to proposed development, and thus the majority of their
territory woul d be lost. Reduct ions to the popul at i on coul d occur from
i ndi rect impacts through increased di sturbance and fragment at i on of the
habitat. Only 21 pairs (30 percent) of California gnatcatchers detected
by ERCE are in the proposed open space not isolated by homes.
Approximately 411 acres (49 percent) of occupied gnatcatcher habitat will
be directly impacted, and 43 acres (5 percent) will be indirectly
impacted, 383 acres (46 percent) be i ng reta i ned in open space.
Approximately 77 acres (54 percent) of potential breeding habitat that
was not occupied during the spring ERCE surveys will be directly
impacted, and 6 acres (3 percent) will be indirectly impacted. A total
of 76 acres (46 percent) of potential breedinq habitat will remain in
open space as biological mitigation.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 8
The Cal ifornia gnatcatcher population on Rancho San Miguel is part of a
larger core popul at i on for the entire speci es. Census data accumul ated
from previ ous offs i te surveys and the Rancho San Mi gue 1 survey i ndi cate
well over 100 pairs of gnatcatchers in the sage scrub habitat along the
Sweetwater River (SEB 1984, WESTEC 1987).
If the gnatcatcher is listed as endangered, it is likely that all
suitable sage scrub habitat for the species would be affected. Section 9
of the Endangered Species Act does not allow for the "taking" of an
endangered species, "take" being defined as any action that would
jeopardize the existence of an individual or any portion of the
environment necessary for its survival. Direct and indirect impacts
which are considered "take" are: elimination of individuals and their
habitat, impacting of habitat by excessive noise or night lighting, and
long-term degradation of habitat by increased fires as a result of an
activity. If the gnatcatcher becomes 1 isted prior to issuance of all
discretionary actions by the city, including grading permits,
construction activities on the site could be stopped until either all
"takes" resulting from the project are eliminated, or a Habitat
Conservat ion Pl an (HCP) for the speci es is developed as di rected under
Section 10(a) of the Act. Development of an HCP may allow for 1 imited
impact to Diegan Coastal Sage Scrub by the development.
Cactus Wren
If the Coastal Cactus Wren is considered a separate subspecies, then the
Cactus Wren is the most seriously threatened species on the site. Only
200 pairs are known to remain in coastal San Diego County (Rea and Weaver
1991). Of the 13 pairs on and near the project site, 7 pairs (54
percent) woul d be el imi nated under the current development pl an. These
impacts are considered significant and unmitigated.
Biological impacts which could be mitigated to below a level of
significance include impact to 3.1 acres of wetland habitat, impacts to
marsh elder, and impact to spiny rush.
Archaeology
Eight important sites will be directly
projects. These can be reduced to below
impl ementat i on of mit i gat i on measures that
recovery.
impacted by the proposed
a level of significance by
focus on reSOurce and data
Based upon the results of the archaeological investigations at the
project, the proposed development of Rancho San Miguel will impact
cultural resources. Many of the resources that will be impacted
represent important archaeol ogi ca 1 sites. The impacts to the important
sites will be significant. The significance of these impacts, whether
direct or indirect, may be mitigated to below a level of significance
through the implementation of measures described above that include
preservation and data recovery.
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 9
Paleontology
Impacts from mass excavation can be reduced
significance by mitigation measures that are
qual ified paleontologist monitoring original
formations.
to below a level of
outlined including a
cutt i ng of sens it i ve
Geol ogy/50il s
Geotechnical constraints
significance by mitigation
geotechnical reports.
can be mitigated to below a level of
measures including preparation of supplemental
Areas requiring no mitigation include: mineral resources, conversion of
agricultural lands, community social factors, and fiscal analysis.
Hydrology
The project would generate substantial increases in surface runoff due to
increases in impervious surfaces and cause significant flooding and
scouring downstream. A detailed drainage report submitted subject to the
approval by the City Engineer at SPA level which would be designed and
implemented by the Sweetwater Authority would reduce impacts to below a
level of significance.
Water Quality
Potential increases in contaminant concentrations in Sweetwater Reservoir
resulting from conversion of undeveloped land to urban uses and the
potent i a 1 for sewage to enter Sweetwater Reservoi r or nearby streams if
the development's sanitary sewer system malfunctioned can be mitigated by
an acceptable runoff protection system being prepared and approved by
Sweetwater Authority and California Department of Health Services as well
as a detailed water quality plan subject to the approval of the City
Engi neer and Envi ronmenta 1 Revi ew Coordi nator bei ng submi tted pri or to
GDP approval.
Traffic
Regional access to the study area is currently provided by Interstate 805
in a north/south direction and by Bonita Road, San Miguel Road, and East
H Street in an east/west di rect i on. Future north/south access will be
provided by State Route 125. The final al ignment of this road will not
be determined until early 1993 (Garcia 1990). Access to the project site
is off East H Street and San Miguel Road. Interim access issues
surroundi ng thi s project must be addressed inSect i ona 1 Planni ng Area
(SPA) level ErR documents to be prepared in the future. The Traffic
Section of the EIR is based on a traffic technical report prepared by JHK
& Associates (1991).
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 10
The majority of the study area roadways are currently under San Diego
County's juri sdi ct ion, and cons i st primarily of two-l ane hi ghways. East
H Street and San Miguel Road and the realigned portion of Proctor Valley
Road through the Salt Creek I subdi vi s ion provide paved publ i c street
access to the southern portion of the site. San Miguel Road provides
paved access to the northern portion. Many of the City's roadways
surrounding the proposed project site are currently under construction
according to buildout configuration recommended in the Chula Vista
General Plan. Both the County and City General Plans anticipate major
improvements to key arterials such as East H Street, Sweetwater Road, and
Otay Lakes Road.
Forecasted traffic volumes were compared to City standards for roadway
ope rat ions in order to evaluate the need for roadway improvements to
mitigate project traffic related impacts.
Future 1 eve 1 s of servi ce for three roadways segments wi 11 be above the
City's standard for traffic operations based on roadway classifications
recommended in the fi na 1 General Pl an Ci rcul at ion El ement. The segment
of East H Street between SR 125 and San Miguel Road is forecasted to
operate at LOS D with 50,800 ADT. This forecasted volume projection
under the proposed project is only 800 vehicles per day over the
threshold LOS C capacity of 50,000 ADT for a six-lane prime. This
represents 1 ess than a 2 percent exceedance of capacity, and does not
warrant redesignation of the road to the next highest functional class,
which would be a Six-Lane Expressway. Thus, no change in the adopted
functional classification for this segment of road as designated by the
General Plan is necessary due to this minor exceedance. A similar
situation exists along Bonita Road from Central to San Miguel Road and
from San Miguel Road to Sweetwater Road. In each of these cases, the
exceedance is minor. The overall conclusion of the JHK analysis is that
implementation of the project will add only minor traffic increases
compared to the 1 and uses proposed by the updated General Pl an.
Therefore, no significant impacts are identified for the minor exceedance
of roadway segment capacities. The remainder of the roadway segments
woul d be under capaci ty at General Pl an buil dout with the project as
proposed.
State Route 125
State Route (SR) 125 is envisioned as a north-south 1 ink between the
international border crossing at Otay Mesa at 1-15 north of Poway. The
portion near the Rancho San Miguel development is one of four toll
revenue transportat i on project demonstrat i on programs ari sing from
Cal ifornia's AB 680 program. The proposed toll road would 1 ie between
the border crossing and SR-54 near Bonita. Cal ifornia Transportation
Ventures, Inc. (CTV), is a company created specifically to develop the
toll portion of SR 125. The corporation consists of a partnership with
Parsons Brinckerhoff Development Group, Inc.; Fluor Daniel, Inc.;
Transroute; and Prudential-Bache Capital Funding. CTV proposes to build,
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 11
transfer to CalTrans, and operate this toll road. The road would
initially be a 4-lane toll highway roughly 76 feet wide, with 2
northbound and 2 southbound lanes. Opening is envisioned for 1996.
Ultimately, the highway would be approximately 178 feet wide, with 4
northbound and 4 southbound 1 anes, pl us a center set of 1 anes for high
occupancy vehicle or light rail transit.
For this impacts discussion, it is assumed the Rancho San Miguel
development is constructed and in place before SR 125 plans are finalized.
Conclusions
If construction of the Rancho San Miguel development as currently
proposed precedes SR 125 alignment selection, the feasible choices for an
alignment of SR 125 past the development most likely would be limited to
Proctor Valley West alignment with an interchange at proposed San Miguel
Ranch Road . Although th is a 1 i gnment may in fact be the one selected,
other a 1 i gnments are st ill bei ng evaluated, and the Proctor Valley West
al ignment may not be the route that is environmentally superior or most
desirable to CalTrans. Since a preferred alignment has not been
established by CalTrans and CTV, and environmental impacts of each of the
alignments have not been determined, further evaluation in this EIR would
not result in resolution of this issue. Therefore, in accordance with
Section 15145 of the CEQA Guidel ines, which states that analyses should
not be pursued in an EIR if the answer remains purely speculative,
discussion of potential impacts of SR 125 on the Rancho San Miguel
development is terminated.
BVDass Road
The bypass road proposed as part of the Rancho San Miguel GDP would
intersect with existing San Miguel Road approximately 4,000 feet west of
the project entrance at the commercial area. The bypass road would run
southeastward, routing traffic off of San Miguel Road and into the
development. The developer envisions that eventually an interchange with
SR 125 would be constructed at this location. The proposed roadway
offers several advantages over the alternative of upgrading existing San
Miguel road to carry project traffic. The proposed bypass road passes
through several 1 arge parcels, and woul d take approximately fi ve
buildings. However, widening San Miguel Road would involve more than 30
parce 1 sand coul d take numerous res i dences. Al so, the proposed bypass
road would bring traffic directly to the main project roadway (San Miguel
Ranch Road) at the commercial area. Existing San Miguel Road would enter
the development north of this location on the access road leading to the
northern portion.
It is not known at this time if the County would prefer to widen the
existing San Miguel Road as planned in the County Circulation Element, or
to implement a bypass road as proposed by the Rancho San Miguel GDP. If
the County chooses the bypass road, speci fi c envi ronmenta 1 impacts will
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 12
be addressed at SPA level. However, one disadvantage of the proposed
bypass road is that the County Ci rcul at i on El ement does not show such a
bypass for San Miguel Road. This is important because the road would
remain the jurisdiction of the County even after the development is
annexed by the City of Chula Vista. This discrepancy with the County
General Plan could be solved by an amendment to the County Circulation
Element. The information contained in this EIR on the GDP and future
documentat i on at more detail ed 1 eve 1 s of p 1 anni ng wi 11 be used by the
County to decide on appropriate actions. If the bypass road would not be
a 11 owed by the County, an altern at i ve to provide access to the project
would be to widen the existing San Miguel Road. This action would be
consistent with the County Circulation Element.
Air Quality
As currently planned, the proposed project would have a significant, and
only partially mitigable, cumulative impact upon air quality in the San
Diego Air Basin. In addition, because the development was not included
in the 1982 SIP, the new emissions would have a significant, unmitigable,
project-specific impact on local air quality.
Noise
Noi se 1 eve 1 sin many areas woul d exceed the 65 dBA standard.
noise walls or wall berms adjacent to major roadways will reduce
to below significance.
Public Services Utilities
Pl aci ng
impacts
Impacts which are unknown at this time and which will be evaluated at the
SPA level include: location of water facilities, adequacy of sewer
infrastructure, location of new fire station, impacts related to placing
homes in close proximity to large areas of natural vegetation and
location of staging areas for the proposed trail system. Publ ic util ity
impacts which can be reduced to below a level of significance by the
proposed mitigation measures include: need for water conservation
measures, provi s i on of three new offi cers and fi ve add it i ona 1 support
staff to the police force emergency medical service response times,
bringing in additional elementary school children, and high school
students, biological impacts of a proposed equestrian trail system,
portions of the trail system which is not acceptable to the Parks and
Recreation Department.
Alternatives
Several of the project alternatives are summarized below.
Horseshoe Bend Alternative
Thi s a lternat i ve preserves Horseshoe Bend, a s i gni fi cant 1 andform and
vi sua 1 feature located in the western half of the project's southern
port i on and reduces the number of units in the southern port i on from
1,297 units to 1,261 units. The purpose of the Horseshoe Bend
City Planning Commission
Agenda Items for Meeting of February 5, 1992
Page 13
alternative is to reduce impacts to biology-landform/visual. Impacts
associated with land use and consistency with the City's General Plan,
landform/visual quality, biology cultural resources/geology soils
hydrology, water quality transportation, air quality, noise and some
public services would remain significant.
BioloQicallv Sensitive Alternative
The biologically sensitive alternative substantially reduces the acreage
developed in the southern portion and el iminates all development on the
northern portion in order to reduce many impacts to the biological
resources assoc i ated with the project site. Approximately 461 acres of
the southern portion would contain 1,600 single family dwelling units.
No development would occur on the northeastern and southeastern portions
of this area preserving approximately 277 acres of sensitive biological
resources. The entire 1,852 acre northern portion would be preserved as
open space.
Impacts to 1 and use, 1 andform/vi sua 1 qual ity, bi 01 ogy, cultural
resources, geology/soils, hydrology, transportation/access, air quality,
noise, public services and utilities, parks, recreation and open space.
ResDonses to Draft EIR
No comments were recei ved from any City departments or State agenci es.
As stated earl ier in the report, the cut-off date for comments from the
Clearinghouse is February 6, 1992. Comments were received from the Buie
Corporation and Chula Vista Elementary School District which are attached.
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LEGEND .
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..-...... DRAINAGE
~ ERCE
FIG lJ R E
Project Site
2-1
February 3, 1992
TO:
Planning Commission Members
FROM:
Barbara Reid, Associate Planner
~{(
SUBJECT: Additional comments regarding Circulated Dra~t EIR-90-02
for Rancho San Miguel General Development Plan
-------------------------------------------------------------------
Please find enclosed 8 additional comments regarding the Rancho San
Miguel EIR as circulated for public review. The attached comments
were received by the Planning Department after your packets were
prepared.
1.
Letter from Endangered Habitats League, dated l/28/92.
Memo from Roger Daoust, dated l/29/92.
Memo from Roger Daoust, dated 11/15/91.
2.
3.
4. Letter from u.S. Department of the Interior, Department of
Fish & wildlife Service dated 1/30/92.
5. Letter from The Buie Corporation, dated l/24/92.
6. Letter from Chula Vista Elementary School District, dated
1/2l/92.
7. Letter from County of San Diego Public Works, dated 1/31/92.
8. Letter from Department of Fish & Game, dated l/29/92.
These correspondences should be considered part of the package for
review of EIR-90-02.
BR:mh
, .
ENDANGERED HABITATS LEAGUE
Dedicated 10 (he protection DC Coastal Sage Scrub and olher threatened eco5)'itcms
F(€C€/V€Q
Dan Silver, Coordinator
1422 N. Sweetzer Ave. #401, Los Angeles, CA 90069
Phone: (213) 654-1456(H); (JIG) 18W llllf\':)
1'.-.:' (111)6J1 n19
A "./ i
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January 28, 1992
Chula Vista Planning Commission
Attn: Barbara Reid
276 Fourth Ave.
Chula Vista, CA 91910
RE: Rancho San Miguel proposed development (EIR 90-02)
Honorable Commissioners:
''\
The Endangered Habitats League is a coalition of over 30 conservation groups
and hundreds of individual members dedicated to constructive land use solutions. As
we seek to integrate development and conservation goals, protection of the California
Gnatcatcher, now proposed for federal endangered species listing, and its vanishing
costal sage scrub habitat, will be a major challenge.
The San Miguel area contains a block of coastal sage scrub whose regional
importance cannot be overstated. There are very few areas like it, and approximately
1 of every 10 gnatcatchers live here. To the many conservationists and developers
'worldngwgeti'1er to a build long term, viable reserve system for southern California,
the presence of 150 gnatcatcher pairs in a relatively intact, undistubed habitat means
that it is sure to constitute a future core reserve area. In turn, the protection of this large
population will subsequently allow much more flexibility for nearby areas in your City
and mean less constraint on other development proposals.
The EIR for this project emphatically concludes that the impacts of the proposed
design is not able to be mitigated. With its direct adverse impacts on 40 of the 69
gnatcatcher pairs the property contains, Rancho San Miguel will cripple the viability of
the regional population and dismantle the future core reserve. We ask you to require
the use of an environmentally preferred alternative design, as found in the Eli=!, which
keeps the northern section free of develpment and is more consistent with your City's
prior open space designations. In this case, a finding of over-riding consideration for
the proposed design would fly in the face of the many, substancial benefits the
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alternative design has for the future of the region as a whole.
We urge the City of Chula Vista to take the lead in responsible conservation
planning and to consult with State and federal widllife agencies regarding project
design. We also believe that adoption of the plan as proposed would be incompatible
with Governor Wilson's new Natural Community Conservation Plan for coastal sage
scrub, in which we urge Chula Vista to participate. To advance the cause of both
nature and future development potential, theSan Miguel project has an obligation to
conform to the needs of the core, regional coastal sage scrub reserve which is in its
midst. We believe that your community will also surely benefit from the many open
space values of this important natural area.
Please adopt the highly feasible environmentally preferred alternative for
Rancho San Miguel. We thank you very much for this opportunity to comment.
With best regards,
.z:)':-~
Dan Silver
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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
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.)
:0
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January 29, 1992
Fi 18 No. YE-052
TO:
VIA: ..
FROM:
Douglas D. Reid, Environmental Review Coordinator
Clifford L. SWanson, Deputy Public Works Director' ~
City Engineer ~
Roger L. Daoust, Senior Civil Engineer~
Harold Rosenberg, City Traffic Enginee~
Review of Draft Environmental Impact Report 90-02,
Rancho San Miguel General Development Plan
SUBJECT:
The Engineering Division has reviewed the sUbject document. and
presents the fOllowing comments:
1. This version of the Draft EIR did not address the following
items presented in our November 15, 1991 memorandum (copy
attached herewith) and are resubmitted for consideration:
Items 4, 5, 9, 17b, and 17c.
2. Change the following statement in Section 3.8 under the
heading "Mitigation":
"Development of the Rancho San Miguel project must comply with
~ applicable regulations established by the United States
Environmental Protection Agency (EPA) as set forth in the
National Pollutant Discharge Elimination System (NPDES) permit
requirements for urban runoff and stormwater dilcharge."
to:
"Development of the Rancho San Miguel project must comply with
~ applicable regulations established by the United States
Envi ronmental Protect ion Agency (EPA) as set forth in the
National Pollutant Discharge Elimination System (NPDES) permit
requirements for urban runoff and atormwater discharge and any
regulations adopted by the City of Chula Vista thereto."
5. Also in Section 3.8, under the heading "Mitigation", add the
following statement:
"The developer ahall . be . requi red to obtain an H.P.D.E.S.
construction permit from the State Water Resources Control
Board and to submit pollutant control and monitoring plans to
the Regional Water Quality Control Board for approval prior to
the issuance of grading permits."
-, ,
Douglas D. Reid
Page 2
January 29, 1992
.
6. In aeneral, the Traffic Engineering Staff is satisfied with
.the traffic analysis presented in the Draft EIR. However,
'~evelopment of Rancho San Miguel is subject to the following
conditions:
a. The EIR must indicate that the proposed location and
configuration of the interchange at San Miguel Ranch Road
and SR-125 is subject to the approval of CALTRANS.
, '
b. The EIR must indicate what wi 11 happen to San Miguel
Ranch Road as it enters the County of San Diego (1...,
what standards will it be constructed to, where will it
terminate, etc.).
7. Change the following statement in the first paragraph under
Section 3.15.2 "Sewage: EXisting Conditions":
"The average daily wastewater flow for Chula Vista is
approximately 13 mgd, leaving a surplus capacity of 6.2 mgd
(Chopp 1991). The current wastewater flow is approximately
10.7 mgd due to water conservation efforts (Daoust 1991)."
to:
"The average daily wastewater flows for Chula Vista prior to
1991 were as high 12.7 mgd. However, the average wastewater
flow in 1991 was reduced to 11.2 mgd as a -result of water
conservation efforts."
8. The second paragraph under "Proposed Offsite Facilities" on
page 3.15-17 addresses capacity and capacity rights in the
Frisbie trunk sewer between Corral Canyon Road and Bonita
Road.
According to the Wilson Engineering report, .Proctor Valley
Basin Gravity Sewer Analysis for the Salt Creek I Project" and
Pat Klock of the Spring Valley Sanitation District, the
limiting capacity of the Frisbie trunk sewer is 2.95 mgd (not
3.4 mgd as indicated in the Draft EIR). In addition, the
Spr i ng Va 11 ey San it at ion Di st r i ct acknow1 edges t hat San Mi gue 1
. Partners has the assigned capacity rights from Union 011,
which the Spring Valley Sanitation District feels amounts to
1.3 mgd peak flow. Since the Frisbie trunk sewer capacity is
limited, discussions should take place among the involved
parties regarding the eventual ownership of the 1.3 mgd
capac it y .
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Douglas D. Reid
Page 3
January 29, 1992
In addition, Rancho San Miguel may need to install a metering
~station to measure its flows to the Proctor Valley and Frisbie
~runk sewers. Compensation may need to be provided if Rancho
San Miguel flow exceeds the allocated 1.3 mgd peak flow rate.
KPA/kpa
cc:
~ara Reid, Associate Planner
Elizabeth Chopp, Civil Engineer
Zoubir Ouadah, Civil Engineer
[A:YE-052.03]
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November 15, 1991
File No. YE-oS2
TO:
VIA:
FROM:
_.
Doug Reid, Environmental Review Coordinator
Cifford L Swanson, Deputy Public Works Director/ Cty Engine~
Roger L Dao~t, Senior Cvil Engine~~
Hal Rosenberg, Traffic Engineer f(
Review of Draft Environmental Impact Repon 90-02, Rancho San
Miguel General Development Plan
.
SUBJECT:
The Engineering Division has reviewed the subject document and presents the following
comments:
1. In Table 1-2 under "Hydrology" and "Water Quality", a distinction should be made
as to the specific design review responsibilities of the Cty Engineer, the Cty
Environmental Review Coordinator, and the Sweetwater Authority. Specifically,
review and approval of the proposed runoff protection system for the reservoir (as
it relates to the water quality of the potable water supply in the Sweetwater
Reservoir) is the responsibility of the Sweetwater Authority and the State
Department of Health Services.
2. Section 1.7, "Mitigation Monitoring Framework", indicates that a fu11y detailed
mitigation monitoring plan and program cannot be completed until environmental _
analysis and public review have been completed. This EIR will not be considered
complete until the mitigation monitoring plan and program are reVi~wed and
approved.
3. County Tax Assessor records for the Rancho San Miguel project are not available
to us and, therefore, it was not possible to verify project boundaries and ownership
of the two parcels.
4. Section 3.5, "Geology and Soils~ should indicate whether or not the existing earthen
dams and associated reservoirs represent any potential hazards to tJ!t proposed
development with respect to their stabilities. Geocon Incorporated's May 1986
"Prelimin,,,y Soil and Geological Investigation" reports indicated that these upstream
dams represent a potential hazard for the downstream properties should failure
occur; Geocon recommended that the dams be evaluated for stability and possible
modifications. H no potential hazard exists, then specifically state so in the EIR.
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Doug Reid
Page 2
November IS, 1991
. S. In our August 29, 1991 review of the "PreHminllT)' Soil and Geological Investigation"
by Geocon, we required that the.Em include the soils report, in its entirety, as an
Appendix and that Figures 1 and 8, which were omitted from the furnished report,
be in the Appendix. The statements in the c:urrent version of the Draft EIR that the
....recommendations of the Geocon Incorporated report (1986) must be adhered to
and confirmed at later stages of plllnniT1g.... (page 3.5-18) and that a copy of the
Geocon report is on file with the City of Cbula Vista (page 3.5-15) adequately reflect
our Ahgust 29, 1991 comments and concerns. However. the report on file with the
City lacks Figures 1 and 8; therefore, the applicant must resubmit the soils report,
including the missing figures, so that the City has the complete report on file.
6. Add the following comment in Section 3.8 under the heading "Mitigation":
"Development of the Rancho san Miguel project must comply with.ill applicable
regulations established by the United States Environmental Protection Agency (EP A)
as set forth in the National Pollutant Discharge Elimination System (NPDES) permit
requirements for .urban lunoff and stormwater discharge."
7. Section 3.9 indicates that, in the event the development's sanitary sewer malfunctions
or overflows, the proposed reservoir runoff protection system would carry raw sewage
via open channels (brow ditches and access roads designed to carry flow) to the
South Side Diversion Pond; the raw sewage would ultimately be discharged into the
Sweetwater River at an outfall below the Sweetwater Dam. The City does not allow
the conveyance of raw sewage in open channels due to the potential health nsks to _
the public. In addition, the discharge of raw sewage (up to 250,000 gallons per day
in the event of a major malfunction of the sanitary sewer) to the Sweetwater River
or any other watercourse may violate NPDES and State Water Resources Control
Board regulations. It should be noted that these issues were not adequately
addressed in the "Notice of Preparation" for the Reservoir Runoff Protection System.
8.
On page 3.9-10, under "Alternative 4 - Roadways, Brow Ditches, and Holding Ponds",
the applicant states:
.
"The roadway segments would be constructed of 4-inch thick concrete,.
~
l"'hAnge this statement to the following:
..-
"The roadway segments will be designed in accordance with the Portland Cement
Association's Structural DesiiD of Ri~d Pavements..
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DoUI Reid
Pale 3
November 15, 1991
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9. Figure 3,8.2 should show the entire Reservoir Runoff Protection System, including
the north side facilities, the outfall below the Sweetwater Dam, the low.flow
futerceptor (which will begin upstream of the Sweetwater Reservoir along the south
side of the Sweetwater River), and the pipeline which will convey the diverted runoff
and/or sewage from the South Side Diversion Pond to the North Side Runoff
Protection Facilities. . .
10.' On page 3.9-14, under "Analysis of Significance", it is not clear how the mitigation
measures outlined will mitigate the impacts caused by the discharge of raw sewage
to the downstream portions and tributaries of the Sweetwater River to below a level
of significance.
11. The second.to-last paragraph on page 7.2 indicates that Plate 1 sbows the alignment
of Highway 125 along the southwestern side of the southern portion of Rancho San
Miguel; however, Highway 125 is not shown on Plate 1.
12. In Section 10.8, the Em states:
"As drainage systems are not always constructed at the proper design capacity, a
cumulative risk exists of reservoir contamination provoked by storm drain overflow
during severe rain events (above all at the Sweetwater and Otay Reservoirs)."
It may be necessary to provide sufficient overdesign of the drainage systems in order
to account for the possible construction of these facilities below their 'design
capacities.
.
13. In Section 3.15.2 under "Existing Conditions", the EIR states that the average daily
wastewater flow for Cbula Vista is 13 mgd. However, the current flow is
approximately 10.7 mgd due to water conservation efforts.
7 . _..
14. . On pag~"aer "Impacts: Proposed Offsite Faciliti~~", ihe EIR indicates that
"_.sewe;~urement or a study to accurately estimate existing wastewater
flows in the Frisbie Street sewer must be conducted before project flows can enter
the system." ..,..;":iI' ..
.,
Add the, following after the above statement:
....._~.. -
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~etering of the Frisbie Street trunk sewer shall be performed by the developer."
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Doug Reid
Page 4
NOYember 15, 1991
15. In genera], there are several sewer capacity issues besides the City's overall capacity
and the Proctor Valley line's capacity that must be considered. These are: (a) the
Frisbie trunk line; (b) the Otay Water District line; and, (c) the Spring Valley trunk
line. Items (b) and (c) must be addressed in more detail.
More specifically, the EIR must address capacity of, and discharge to, the Spring
Valley sewerage system both in terms of the Frisbie trunk line owned by the Spring
Valley Sanitation District and the Otay Water District line, which connects to the
- Frisbie trunk sewer. Flow from the development will be conveyed through the Otay
line. However, the Otay Water District currently has a reserve capacity in this line
. for the emergency discharge of flows from the Otay Water Reclamation Plant The
developer will most likely be required to enter into an agreement with the Otay
Water District to provide additional capacity to the Otay Water Reclamation Plant
16. Wastewater flows indicated in the "Prelimin,,'}' Sewer Concept Plan Study for
Rancho San Miguel" (Appendix I) differ from those presented in Section 3.15 of the
subject EIR; this _ difference should be explained.
17. In ieneral, the Traffic Engineering Staff agrees with the Draft "Rancho San Miguel
Traffic Analysis" prepared by JHK &. Associates, which is presented in Appendix E.
However, the following issues from Section 3.10 and Appendix E must be addressed
in any subsequent version of the EIR:.
a.
On page 3.10-21 under .Other Future Issues., the EJR indicates that ....the
City of Chula Vista is currently pursuing a consultant study to determine .
whether it would be advisable to build an interim roadway facility in the [SR
125J corridor prior to completion of the SR 125 freeway..Jt is recommended
that this issue be reevaluated at the SPA level of analysis when more
information is available. The construction of the project should be contingent
on either construction of some interim freeway level roadway facility in the
SR 125 corridor or provision of alternate routes of travel for project traffic..
7'
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The EIR must recognize that development of this project cannot proceed until
the City's consultant study on the feasibility of building an inte~ facility in
the SR 125 corridor is completed and there is a determination of itso~~m~ __
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b. Bonita Road between I-80S and Otay Lakes Road is a four-lane _major
roadway, not a 6-lane prime arterial as indicated in the report.
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Doua Reid
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Paae 5
November 15, 1991
.
C. The trip generation rate for "Park" in Table 4.1 Is shown as S trips per acre.
A trip generation rate of S trips per acre Is appropriate if referring to an
undeveloped park. However, it Is OUI understanding, based upon information
provided in Section 3.16 of the Draft EIR, that the park will be developed;
the trip generation rate for a developed park Is 20 trips per acre.
KPA/kpa
. '
, .
cc: Barbara Reid, Associate Planner'
Elizabeth Chopp, Civil Engineer
Zoubir Ouadah, Civil Engineer
j
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[A:YE-OS2.02]
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!r::ti ~ '92 17:02 FWS--Lf'r~ 714-643'-4118
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FISH ANP. WILDLIFE SERVICE
PISH J\HI) WILDt-In: ENHAIICEKJ:NT
.OU~HIRN ~rroRRtA PIlton ITATtON
t.ag~na .iouel Offioe
Pederal Building, 24000 Avila acad
~Ig~nl .iOUel, California '2656
United States Department of the Interior
January 3D, 1t~2
~. Jtobert A. Leiter,
Director of 'llnnin;
City of Chula'Viltl
216 Fo~rth Aven~e
Ch~la Viltl, CIlitornia 12010
ae. Dratt Environmentll rmpact Report on the Rancho Ian Xi;~el General
Davalopment .lan (IIR.'0-02), City of Chula Vi.ta, Ian Diago County,
CaUtornia
Dear Mr. Leiter.
The Fi.h and Wildlife lervice (Iervioe) ha. reviewed the Dratt Environmental
Impact "port (Report) for the Rancho Iln Miguel aeneral Devalopment Plan
within the .phere of intluenoe ot the City ot Chula Vi.ta, 'an Diego COunty,
Calitornia. A. reque.ted, the lervice i. providing the City of Chula Vi.ta
with technioal a..i.tanoe. The tollowing oomment. and reoommendation on the
biological impact. of the projeot are ba..d on our knowledge ot .en.iti.e and
declining habitat type. and .pecie. in Ian Diego county. The 'ervice would
like to emphl.i.e our inorea.in; concern with the oumulative impactl of
pro~ect., auch al thi. pro~act, on biological re.ourca. in 'In Diego COunty.
Tha Rancho Ian Xigual Oaneral Development Plan con.i.t. of the development of
I 2,590 Icr. parcel into 1,654 .ingle-tamily re.idance., a 14 acre commercial
center, an 11.2 aore elementary eohool .ita, a 20.5 acre community park, a
comm~nity purpo.a tacility, a 1 acre conterence center/retraat and inn, a 6
aore interpretive center, pede.trian and bicycl. trail. and 1,653 aore. of
natural opln 'plOI.
The project, a. de.igned, will re.ult in the direot lOll Ind degradation of
.ailtin; wildlife habitat inoluding tha 10.. and degradation ot 515 aora. of
Diegan ooa.tal .age .orub, 415 aore. of Don-native gra..land and 5.5 acre. ot
dry .ar.h/riplrian .crub habitat. ligniticant, adyer.e project-iRduced
~aot. will occur to biological re.ource. of concarn to the 'er~e,
partioularly the California gnatcltch.r (PolioDtila oaliforniaa), the cactu.
wren (Camolcrhvnchu. brunn.lc.~illum) and ~h. otay ~arplant (H.mizonia
D~av.nai.). The propo.ed project wa. tound to have .ignitioant unmitigable
impact. to biological r..ouroe.. Xinimal mitigation meaaure. &r. di.cu..ed in
the "port.
-
JAM :3e'. '92 17:1212 FWS-LNF 714-643-4118
,
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~. IIobert A. ~U:er
2
Thl 'erv1oe ha. ~e'pon.1b11it1e' unde~ the ellan Water Act and the Bndangered
lpeoie. Aot of 1973, a. _ndee!. Our _ndate. ~equire that we "",ovide
comment a on any pUb1io notioe i..ued for a redera1 permit or lioenee affeoting
the .adon' I waten, in partiou1ar,' AnIr Corp. of I"gineen (Corp.) permU.
JU"'luant to Ilotion .0. of thl e11an Wate~ Act end laotion 10 of the aiTar and
Harbor Aot of 1899. The goal of the Clean Water Aot 1. to maintain and
raltora the chemical, phy~1oal and biologioal intagrity of thl nation'l watlr.
~y eltablilh1ng .trong protlction againlt d1lohargel into .pac1al aqultic
litl', which include wetland.. The Ilrvice i. rl.pon.ib1e for thl
adm1n1.tration and enforcement of thl Indangered Ipec1l' Act, including
lilting and "'ecovery of endangl"'ad lpecil', 10(a) permit ilauanOI and
oonlultation with rldlra1 agenoia. for aotion. which may afflct federally
1i.ted Indang.rld lpaoill.
GENERAL COHKBN'1'1
'he Ilrvioe ha. the 1a;a1 ~1.pon.ibi1ity for the welfarl of ell mi;",atory
bLrd., anadromou. fi.h, and endangerld animal. and plant. ooourring in thl
Un1tld Itate.. prl..ntly, Iln Diego county ha",bor. thirt.en flderally li.tld
endang.rld .paoil' and .ix prcpo..d Indang.red .paoil'. Thl l.rv101 ha. bien
petitionld to li.t 27 mora .pacie.. On. hundrld and thirtY-li;ht oandidatl
lpeoie. for lilting a. Indangerld or thrlltlnld ocour within Ian Dil;o county.
'h.al high numblr. azl 1ndioativl of thl dlcl1ning trand of plant and animal
.peoie. in Ian Diego County. Without planning for thl.1 re.ouroe. in a
oGmp"'lhln.ivl mannl"', it i. rla.onabll to expeot tha.e trendl to oontinul..
G1vln thil lituation, the lervioe Itrongly urge. the City of chu1a Vi.ta to
plln for the long-term protection of their biological re.ourcl.. ~o oontinue
to develop aria. in the pre.ent manniI' 1. to cauae the endan;e~nt and
po..ib1e extinction of numarou. lpecie.. Allowing lpaoil' to dloline to
11..11 that warrant rldlral lilting a. Indangerld will oomp11cata p1ann1ng for
future projectl. Protact1on of remaining habitat arlal of luffioient 11.1 and
~ality can help prll.rve Ixi.ting population..
levlra1 candidat. .pecie. for lilting a. .ndangered will be adver.ely affected
by 10.. and degradation of habit.t ~.ultin9 frem the lubjlOt projlct. Thl
primary ;oal of identifying radaral oandidate lpaoiel i. to notify aOlnoie. of
~h. documented dealine of aertain 'Pec1e. and ~o alert the'e agenaiel to the
po..ih1e 1nclu.ion of the.e lpecie. to endan;.red or threatened .tatu.. The
candidate .pe01el li.t provide. an "early alert" whioh oan allow for the
cen.ideration of the.e .peoie. in planning and protection effort.. We ur;1
the Citr of Chula Vi.ta to give grlat weight to thl proteotion of AAnd1datl
~
plant and an1lllal .peci... _
Tha aeport .tata., and tha s.rvica concur. that the p~ojeot .ite .upport. one
of thl richelt and mo.t diver.e "Iamblagea of un1~e ~ .an.1tiTe ~iolO;1oal
~.eurce. in ,outhern California. The lite i. potlntial1y the .in;11 laroalt
conaentration of California gnatoatchlr in Southern california. Appreva1 of
the preferred project would re.ult in ma..i.. .dvere. tmpa=t. to the
pre'lrvation of the California gn.toatchlr, the Otay tarplant .nd othar
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ll'ti :30 '92 17: 03 FWS-L/'F" 714-643-4118
P.4
~. aobel't A. t.itel'
3
'In.i~ivI .peoil.. DI.Ilopment of the highly aen.i~iVl ftOrthel'n pol'~ion of
tha projact aita would I'a.ult in ccap1a~ion of 317 unita out of thl pl'cpoaed
1,1'4 tDtal dwelling unita. ~ha diffll'lncI b.tweln the liologica11y Prlflrl'ld
Alternati.. and the pl'cpoa.d pl'ojeot ia approximatlly .4 dwelling unit.. POI'
.4 additional houain; unit., the continued e.i.tlnoe of tha California
vnatcatoher would ~I plaold in jlopardy. ~ia .ction would neola.it.te that
the 'Irviol ...... thl nlld to lm.adiatlly "'I'gency li.t thl callfol'nia
gn.to.tcher, the c.ctua wran, .nd tha otay t.rplant. Additionally, 1t will
certainly daatl'oy tha likalihood of tbl 1U00... of . viAbll ..tuzal COmmunity
COn'lrvation .rogram for ooaatal .agl acrub in aouthel'n 'an Diego County. Thl
de.truCltion of 70 pel'cant of the on-.ite California gnatoatchel' territoriaa
will eliminate planning fllxibility fol' othar projeot. throughout aouthel'ft
California dUI to tha ino~a..d jlopardy of extLrpating the apeoil' inoul'~d
by thia prcjact. Wa cannot ovarly atre.. the biological import.nce of thl
projlct litl and th. n'ld to prl..1'VI thi. looation.
.paCIFIC COMKINT.
3.3 .ioloalcal ...oure... paa. !.2-1
The 'aZ'Yio. concur. with the "pol't that the projlct aite lupport. ona of thl
I'lohe.t and mo.t dival'.a a..amblagl. of unique and I.n.itiv. ~iolo;ical
~'OUI'CI' in 'Outh.rn California. The proj.ot .itl oon.llt. of 7 .egltation
type.. Thl Vlgltation type. on-.itl inoluda Di.gan ooaatal .agl lorub (1,'22
10~'), louthll'n mixld chaparral (109 aorl.), ohami.1 chaparral (23 ao~.),
dry fr'lhwater .arlh/riparian lorub and riparian .crub (13.1 acrl.),
Califol'nia native gl'l..land (11 101'1'), and non-native gra..land (106 ICl'e.).
All of th... habl~at. II" eon.idlrld 'Ineiti.1 .xoept non-native vra..1and,
and chami.e and louthel'n .ixed chap.rral. Additionally, thl 'I'ojlot lite
'I'ovid.. important large aammal movement oorridorl and i. .tr~t.gioally
locat.d a. an important link in the .aint.nano. of ~iodiver.ity from the
.weltwater ....Z'Yolr and .iVII', .a.t to thl Jamul Xountain. and louth aoro..
the int.rnational bo~der.
leveral Iln.itivI lpeoi.. including 63-100 ,air. of California onatoatchel', 12
pail' of oactue wr.n, 13 ..n.itiv. plant .peci.. and 21 Iln.ltiYe ant.al
lpacil' inoluding the ol'an;l-throatld Whiptail (enmm!do~hcru. hvcarvthru.),
the horned li..rd (~hPVfto.ema eoron.~um bl&iftvil1ai), and ~h. golden .agl.
(Aaui1a chrv.a.tc.) have been ob..rvld on-.it.. onl hundl'ld and ~wo I,aoi..
of ~ird. WIl'l ob.lrvld on-.ite inoluding 13 raptor aplcil', ~nl hi~~rio
ne.ting lit. tOI' thl ;oldln .agll, and on. f.dll'ally li.t.d .ndangli\d
lpeci..,th. per.;r1Ae falcon (Perearlnul falec), Fift.en ._Mm-l lpeoi..
including ~hl mountain lion (lIl1I oonoolor), four amphibian lpeoil' and 12
r.ptile Ipeoi.. Wlr. ob'lrved on-.it.. Thirty-.LK r.cooni~.d .en.iti.e and
dlolining .paci.. inoluding 6 plant apeoil' and 10 anLmal lpeci.. which are
f.deral oandidata. fol' lilting II .ndan;erad and thr.aten.d oocur on-.itl. Of
thl .paoi.. ob.lrvld on-.ite, 7 lpecie. have beln newly liltld .. Cate;ory 2
OandLd&~.. for liltift; e. .ndan;'I'.d 01' threatenld).
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;AN 3IiI '92 17:04 FWS-LNI- ~ ?14-643-4118
P.5
.
1Ir. IObert A. Leitlr
4
IftfonaHon within the .ub~ect: docwant .hould !Ie IIpdat:ed to ~epnl!l.nt: the
prl..nt atatu. of thl C&lUo~nia ,natca1:cher. ~I .1:&1:u. ~eview 18 c_pleu
and thi, .pecie. ha. been prcpo.ed .. . rederally li.tld endangered l~cLI..
I'he "&'Vic. ba. up to one yeu f_ "pt:Mber 17, 1111 ~o ..ke a final
dltl,.1nat10n on thl. I~cie.. I'he 'e&'Viol il pre.en1:1y 101icit1n; comment:.
(untilllarch 16, 1"2) ~egU'd1n, info&'lllaUon on thl CalUornia Vnat:catcher tc
.n.ure 1:he accuracy of our prcpo.ed rule.
%ftmAe~.1 Pa~. !a!-2'.
I'be project a. prcpoled will .i;nifioantly impaet: thl C&liforftia 9ftateatehlr.
Direct: impact:. t:o 40 (S8 percent) of the Ixilting " pairl and putial 1mpaatl
1:0 I addi1:1ona1 pair. (12 percent) would occur. .rc~ect inducld tmp&ct. will
occur to 411 acr.. of habitat occupied by 1:he California ,na1:catcber and 77
acre. of pot.ntially occupied habitat. Additlonal impact. to remaining bird.
are expect.d to occur due to ed,e affect. of thl dlvelopment and fire buffer..
I'he .ite i. potentially the .ingll lar,..t concentration of California
,nataatcherl in .outhlrn California and i. a ~egionally .i;nificant populatlon
of California ;natcatcher..
I'he propo.ed pro~ect will impaat 7 of the 8-13 cactu. wren territorL..
occurring on-.ite. I'he ooa.tal lub-population of the oactu. wren i. bighly
1:hrea1:ened by babi1:at de.truction. The lervice i. prl.lntly reviewing a
~tition r.qul.tin; that: thi. .pecie. be ...r,ency lieted. The 10.. of 7 pair
of cactu. wren territori.. in thl. area i. of ,raat concern to the ..rvic..
Th. prcpo.ed project will impact 70-10 percent of a den.. population of
150,000 indlvidual tarplant.. I'he aepc~ .tate. thlt 1:h. pro~ect: lit. ..y
IUppc~ the larQl.t known population of otay 1:arplant in .In Die,o County.
li,nificant impact. to eo perc.nt of the .an Dilgo 00&11: barrel cactuI
population (1,300 individual.) will Occur. I'he entire population of 11,000
individual. of the Pal_r' IJI'appl1n, hook will be ..et:roy.d. lignificant
impact. 1:0 1:hr.. oth.r ..nlitiv. plant apecie. will occur due 1:0 the propo.ed
pro~.ct:.
The infomation within tbl "po~ ragardin; ~h. Indang.red apeala. Act i. net:
accurat.. ..rviae relpon.ibili1:iel to andang.red epeeie. ara ~r.uan1: to the
Indangered 'peci.. Act of 1173 aa am.nded. 'ection"' of the Act: nlquire.
rederal a,.nci.. to oon.ult with the '.rviae .bould 1t be det.rmined that
their action. may affect a li.ted .ndanger.d or thr..tened lpecie'~'ect:ion ,
of the Ac1: additionally prohibit. the -1:ak." (..g., harm, h.r.e~ pur.u.,
injure, kill) of federally li.ted fi.h and wildlll. .pecie.. "Harm" i. further
defLAed a. an act whiah ..y ~..ult ~ aignifiaant habitat eodifiaa1:10n or
degradation "where 1t actually kill. or ~~ur.. wildlife by aignifieantly
impairing ....n1:ial b.havior pa1:tern. inaluding b~din" f.eding or
.h.lt.ring (50 CrR 17.3). ";ake' can only b. ~rml1:1:.d pur.uant to the
pertinent langua,. and provi.ionl ln ..ction 7 and .eation 10(a). The take
provL.Lone would apply upon the .ff.ctiv. da1:e of lilting in the rLnal Rul.
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..J1'V-I30 '92 17:05 FWS-LNFO .14-643-4118
P.6
Mr. Rabert A. Leit.r
I
and publi.hed in the .adaral ..ai.t.r, r.gardl... of the Ita;. in the i..uano.
of City.:-COllnty 01' atatl d.,..lopllen1; penlit..
AIr JlZ'I'Irioue1y .tat.d the C.lifornia. 9ftatc.tcller 1& . propo..d .pitoi.. and the
'uvio. hu !!Mn petitioned to liet the aactu. wnn a. Indal\9.red. Given the
119ftif1oant, unmitiVabll impaot whioh would n'lIlt fram thl appraval of thl
prope..d pro~.ot, the a.rv10e will immediat.ly ...... the nlld to ....rg.noy
lilt" th... two .peoil' and po..ibly the ot.y tarpl.nt pur.uant to ..otion
4(b)(7) of the .ndan;.r.d apaoi.. Act. ~h. prope..d projlot w11l n..d to be
......ad .. to wh.th.r it PO'" . lign1f10ant ri.k to the Wlll~bling of any
.peoi.. of fi.h and wildlife or pl.nt.. luch. rlgulation will t&k8 .ff.ct
immediat.ly, including prov1.ion. prohib1tlnq take, upon the pub1ic.t10n of
~he regulation in ~he ..d.ral a.cl.~.~.
Th. etatut.. and guid.line. of the Ca11forni. .nvironment.l Qu.lity Act
r.quire. among oth.r thing. that the oont.nt. of .nvironment.l Imp.ot ~rt.
1nolud. net only the lignif10ant dir.ot Invironment.l oon..quenoe. of the
project but .1.0 that the indirect impaot of the prope.ed projeot bl
.ddr....d. Th. Report in'lIffioi.ntly .ddr..... ie.lle. r.lat1ng to indinot
.ff.ot. of thl projlot, ino1uding thl biologio.l imp.ote rellllting from thl
Idge Iff.ot. of the dev.lopment, lewer f.oiliti.., off~.it. road., w.tlr
.torag., and fir. buff.r..
Xi~io.ticn M..aur... Pao. 3.3-'.1.
lignificant .dv.r'l imp.ct. to thl C.liforni. vnatc.tchlr will ooour .. .
rl.1l1t of thl lubj.ot proj.ot. Ho aLniml..tion or mitig.tion ..a.llrl. fOr the
california 9ft.tc.tcher, caotu. wr.n, otay tarplant, Go..t barrIl a.otll',
,.lmer'. vrapp11ng hook, C.liforni. .dolphia, wildlife oorr1dor., and oo..t.l
..g. .o~ '1'1 propo..d to off.lt the imp.ot. for the 'lIbjlOt projlct. Th.
neld for . major redl.lvn i. mentionld but net included in thl Report.
Kit1g.t1on plane ahollld be .pec1fic .nd .hould off.lt proj.ot-r.latld 1mpact.,
inolud1nv aumul.tive impaot. of liVnif1alnt d1rect and ind1r.ct h.bitat
10..... Th. Rlport .hollld di.oll" .paoific ....ur.. whioh avoid or min1mi'1
impact. to import.nt b1010Vical &'I.ourc... KIp. Ihould be incllldld in thl
aeport .how1ng t.hl p~opo..d areu that wollld nead to be pr..erved t.o reduce
1mpact. to . b.low a level of .ivn1fioanoe I' d..cribld tn Tabll 3.3-1. It.
.ppeare that t.hl Rlport hu corr.ctly detlrmlnld t.h&1: the impact. of the
project c.nnot be reduold t.o a l.vel below .1gniUolnt but ba. incorrectly
dltlrminld th.t thlrlfor. no n.ed t.o furthlr di8cu" ma..ura. t.o m~1.1 or
off..t the impact i. n.o....ry. WI blllev. thi. ~. contrarr t.o t~alifQrni.
&nvl~ftDlntal Qu.lit.y Act.
%nformat10n CD mit1;at10n for 1mpaot.. to watland. i. yaque and ill-dlfinld.
~etail.d information on watl.nd miti;atlon plan. Ihould be tncllld.d in the
aeport. Kitigation condition. which rely on future .ct.lon. by other &genci..
to r.quir. mitig.tion i. in.ppropri.te .nd inadequ.t... Languaq. like .Ivery
.ffort to minimi.e th... imp.ct.- i. un.nforce.b1. and provide. t.h. ~iewer
with 11ttle to no informatlon. Additlon.lly, a 1.1 miti;.tion r.tio for the
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)AN 30 '92 17:06 FW5-LK ~14-643-4118
P.7
Mr. Robert A. Leit.r
15
10.. of .carc. wetland habitat 1. inad.quat.. Rar.ly 1. ~.v.g.tation of
habitat -.ucc...ful- and greater than a 111 ~.tio .hould be employed for thi.
rea.on.
In g.neral, the '.rvic. ~eoammend. that project-induc.d impact. tc watland. be
aYOidad or minimi&.d wh.n.v.r po..ibl. thrQugh proj.ct d..1gn. It 1. the
'.rvice'. regional policy to view anr wetland dliradation o~ 10.... a.
un.cc.ptabl. change. to an important nation.l r..ource. Unavoidabl. project
impact. to high valu. biologic.l r..ouroe. .uch a. wetland. .hould be
mitigated .uch than no n.t 10.. of acr'lga or value of wetllnd. occur..
Prope.al. for non-water dependent .tructure., f.ciliti.. or activ1ti.. (.uch
a. hou.ing) ar. g.n.r.lly view.d a. an unacceptable u.. of public water..
Acc.ptability of each prope..l will d.pend upon ..lection of th. lea.t
damaging alternative or con.truction ..thod, and incorporation of app~opriate
aitigation ....ur.. for unavoidabl. impact.. A. pr...ntly propo..d, the
'.rvic. would recommend denial of any r.deral permit pur.uant to ..ction 404
of the Cl.an Wat.r Act for the .ubj.ct proj.ct.
'ection 15021 of the california Rnvironmantal Quality Act .tatute. and
Ouidelin.. .tate. that CEQA ..tabli.h.1 a duty for public aglncie. to avoid or
minimi.. environmental damag. wh.r. fea.ibl.. M.jor oon.ideration to pr.v.nt
.nvirollllllntal damag. 1. r.quired. A public agency .bould not .pprov. a
proj.ct .. propoI.d if th.r. are f.a.ibl. altern.tiv. or mitigation ....ur..
availabl. that would .ub.tlntillly l....n any .ignificant .ff.ct. th.t the
p~oj.ct would have on the .nvironment. Th. ..rvioe believ.. that the
r.quirlllllnt. of ..cUon 15091 (a) oannot tie adequat.ly ..t given the
availability of the 8iologically ..n.itiv. Alt.rnativ..
'.ction 15041 of the California Bnvironmental gu.lity Act .tatute. and
Guid.lin.. Illow. I Le.d Ag.ncy to require change. in any activity 1nvolved 1n
the project 1n ord.r to l....n or avoid .ignific.nt .ffect. on th.
environment. Hor.ov.r, eection 15042 allow. a publio ei.ncy may di..pprov. I
proj.ct if n.c....ry in ord.r to avoid one or acr. eignif1cant .ff.cte on the
.nvironment that would occur 1f the project w.r. approved a. propoe.d. Th.
'.rv1c. r.commend. th.t the city of Chull Vi.tl dieapprov. the proj.ct ba..d
on the .ignif1cant edver.. impact to biologic.l re.ouro...
eam~l!anc. Wi~h ~h. Thr..held.I.~and.rd. .plicy. Pan. '_1~
Con.picuou.ly ab..nt from ~h. city of Cbula Vietl" Thr..hold. and .tendard.
1e a Itandard for biolo;ical r..ourc.. Or habitlt prot.ction thr'lhold. W.
ha.e enclo..d our comment. to the City of Chula Vi.ta on the Draft Growth
. -
x.nagemant Program end Imple=entation Ordinance dated ..bruary 12,~91. In
th1. l.tter the larvice recommend.d that the City add wildlife habitat/natural
cpan .pao. a. e twelfth ~hr..hold .tandard for oon.1deration in the Growth
x.nagUllnt Program. UntU tbere 1. recognition by the local ~ur1.dictional
ai.nci.. of the need for a oompr.h.n.iv. plan for the prot.ction of euftLe1ent
ar.a. of wildlif. habitat, land u.e deci.ion. will contLnue ~o re.ult in the
irr.placeable 10.. of biological re.ouroee, haphaEard and in.ffectiv.
.J~ 30 '92 17:06 FWS-Ll'F"~ 714-643-4118
.
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P.8
~. Robert A. 1.e1ter
7
biolooioal mitigation and the oontinued .ndan;w~nt of native plant and
antad epecie..
Al~.rfta~!v..t'P&8. 1-1.
Given the documented high bl01091aal value of the projeot: e.\.t:e ba.ed on the
pre..nc. of propoeed faderally lieted endangered epecie., candidate lpaci..,
It ate lilted endangered lpaciel, wildlife oorridor .aluel, #egional
eignifioano., and th. location adjaoent to other hlgh velu. biological
Ir.Guroe. (I_twater ...."olr and Jliv.r, Ian KllJU.l Mountain), the I."io.
et20ngly recommend. th. Mo Projeot Alternativ. or th. liologioally I.n.itiva
Alternative. The liologioally lenlitiva Alternative would Itill ..eoe..itate
the ....d to dev.lop and impl..nt mitigation ...uura. for impact. to the .tate
li.ted otay ta~lant. Th. ..ryiae i. willing to work with th. City to
minimi.e Lapact. to thil Stat. lilted plant: .peai... Th. .iolooioally
.an.itiva Alternative contain. 1,100 .in;l.-f-=ily dwellin; unit. a. oppo.ed
to 1,154 unit. in the propo.ed project. ror '4 additional unit. the prape..d
project would allow mallive habitat de.tructlon, further imperil the
California gnatcataher, th. cactu. wren and the otay tarplant.
The 'ervioe i. allo etrongly oppo.ed to the Hore..boa 'end Alternative and the
Coon Canyon Alternative du. to the .i;nifioant ady.r.. implct. which would
etill oocur in both the north.rn and eouthern parc.ll. Th. '.rYioe reoomm.nd.
a;ain.t the louth only D.velopment Alternative ba.ed on tba li;nifioant
~ot. to the California gnatcatcher, the oactu_ wren, Ian Di.go barrel
oaotul, Palmer'e grappling hook and California adolphia. The Servioe il
unable to provide conclu.ive reoommendation. regardlng the .tat. Route 121 WI
or W5 alignment until we haye compl.te information regarding the full affeat
of Itate Jlout. 125, both on and off-alte.
~
The 'Irvice i. conc.rned re;ar4ing tbe 4i.cu..ion in the ~.port of the
~ativa Analy_il an4 th. Bnvircnmantally Superior Alternativa. The
implioation. Of the dieou..ion appeare to di.count the importanc. Of
min1m1.ation of eignifiaant biological impact_ whioh would oaaur with the
liolooically Preferred Alternative.
Unavo!dabl. .ian1fLo.n~ Rnvironmental ImDao~.t Pac. '-1.
The Report identifie. the .primary unavoidable an4 unmitigable impact"
r..ulting from the propo.ed project .. the 10.. of important biologlaal
relourO.I. Thi_ oonolu_ion aubltantiatel the olear bane fit of the
BiolO9ically Prefarred Alternativa. ~
eumul,~!.. r~.~~.1 10-1.
Th. 'ervice aoncurl with the Report that the _ubject pro,ect ~ conjunction
wlth projeat. propo.ed for the .urroundin; area have a eignificant, advera.,
oumulati.. impact to biological re.ouroe.. The larvioe i. particularly
ooncern.d with the number and magnitude of project. preceding through the
.
~.. .
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;JAN 3e '92 17:07 FWS-LK '14-643-4118
P.9
Hr. bbert A. Leiter
8
env11'011Mntal ~.v1..., proe... withollt adeflllate r"01Iroe planning. The
~iologioal zw.OIIroe. of ~he .waetwater/.an KLguel/otay area are of hiOh value.
'1'ba pre,ent undevelopad ~atu. of thi. area allow. for re.ollroe planning on a
relatively laro& eoale. Pew area. ramain in oo..tal ..n Diego where thi.
pat.nti.l .xi.t.. '1'ba project ait. i. atrateoically 10c.t.d and L. a oritioal
partion of a 1'1'0' cor. poPul.tion of the C.lifornia gnatoatcher. la..d on
it. location, hal:>itat ..alue. and pre.ence of highly aen.Ui.e epecie. the
pr...rvation of the aita in a natllr.l open .pace configuration whioh will
pre.erve exi.tinO habitat value. o.er t~ i. ....nti.l. The de.ign, ai.e,
and configuration of n.tural open .pace to be pr...rvad L. oritioal to th.
long te~ integrity of the habitat and con.eqvently the con.ervation of the
wildlife .peci.. dependent upon it.
.ummarv
In aummary, the propo.ed projeot. will ha.. .ionificant, unmitigated adver..
1=pact. to biological re.ouroe.. '1'ha '.rvio. r.commend. that eith.r the NO
'roj.ct Alternativ. or the liologioally 'r.f.rr.d Alt.rnativ. be ..l.ct.d.
The ..rvio. i. Itrongly oppo.ed to thl approval of the lubj.ct proj.ot. w.
~.oommand th.t the city of Chula Vi.ta d.olin. to olrtify the Report and deny
th. approval of the projeot. w. ba.. 011"1' zwo_.ndaUon of d.nial on the
.e.er., unmitigat.d 1=p.ct, of the propo..d project on ....nti.l habitat and
ari1:10al population. of hiOhly ..nliti.. Ipecie., including the propo..d
.ndanger.d C.lifornia onatoatch.r. No minimi..tion of impact I within the
prcpo.ed proj.ct il attemptld nor il any llIb.tantive mitigation propoled to
l...an th. ....rity of the impact. '1'ha .ubj.ct projeat will r.lult in the
molt Ilvlre, biologically damaging impact to the California gnato.tch.r and
the otay tatpl.nt that ~he Service i. aware of. .1 aannot oVlramphali.e the
biological ~rtanc. of the project lit.. Th. ..rvio. remaine will in; to
work with the City of Chula Vi.ta and the project applicant to .n'lIr.
prot.ction of biologioal 1"'0111'0" throllgh .voidanc., minimi..tion of impactl
and mitigation.
If fOu have any fIII..tion. zwgardin; tha.. comment., pl.... oontact Wancy
Gilba~t of thi. offioe .t (7141 641-4270.
-
ainc.nly,
.~rp~
Office .upervi.or
~
,
-~
.
.JAN 30 '92 17:08 FWS-LNFO 714-643-4118
Mr. IIob.rt A. Le1tel'
-~
ca, COrG, loon; a.acb, CA
CPR, San 111.90, CIA (Attn. T. 8tewart)
City of Ch~la Vilta, Ch~la Viata, CIA ( Attn, a. "id)
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TheBuieCorporation
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SAN DIEGO CAL.,FOr:r....,..; 92127- 1696
(61g~ 487-3050
January 24, 1992
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PLANNING
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Mr. Robert A. Leiter
Director of Planning
276 Fourth Avenue
Chula Vista, CA 91910
RE: Rancho San Miguel DEIR (90-02) - COMMENTS
Dear Mr. Leiter:
We are the owners of approximately 259 acres located west of the
subject property, San Miguel Ranch, and we wish to comment on the
San Miguel Ranch Draft Environmental Impact Report (ErR-90-02).
We understand that the ErR will be considered for public comment by
the Chula vista Planning Commission on February 5, 1992. According
to Barbara Reid of the Chula vista Planning Department, the period
of time for public comment to the draft ErR will close on February
5, 1992. The following represent our comments to date, however, we
reserve the right to make additional comments prior to the
deadline.
While we generally approve of the San Miguel Ranch project, and its
ultimate development, we have some basic concerns over the
treatment of Route 125 in the EIR. Therefore, our initial comments
are focused on the Route 125 issues with respect to the project as
proposed.
ALTERNATXVE ALIGNMENTS OF 125
The EIR does NOT adequately address the possible alignments being
considered by CalTrans for Route 125. We believe the discussion
relating to alternative routes is deficient because it does not
adequately address information which is readily available to the
project.
Specifically, we object to the statement in the ErR concerning the
alignment which was chosen by the San Miguel proponent for
development of their project. The EIR refers to this alignment
(the "W-4") as being the alignment which is "consistent" with the
Chula Vista General Plan. Our recollection of the General Plan
process is that no alignment was specifically identified during the
General Plan process in order to insure that the City of Chula
vista was not placing itself in the position of making a decision
prior to action by CalTrans.
We have objected to the "W-4" alignment in the past because of its
significant impact upon our property and will continue to do so in
the future. Furthermore, to the extent that the "lines" drawn on
the General Plan Map represent a preferred alignment for Route 125,
we believe that the proposed alignment is inconsistent with the
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General Plan because it substantially impacts our property whereas
the "alignment" on the General Plan Map skirts the eastern edge of
our property with minimal impact. We believe that the EIR should
give equal weight to each of the potential alignments.
SAN MIGUEL ROAD INTERSECTION
The discussion in the EIR concerning the location of the
intersection of San Miguel Road and Route 125 is particularly
important. While the EIR recognizes that the location of the
intersection proposed by the San Miguel project is inconsistent
with CalTrans' current proposal with respect to the .W-4.
alignment, it does not address the apparent inconsistency with
respect to the Chula Vista General Plan. In addition, it does not
discuss the impact the intersection, as proposed, has on adjacent
landowner's properties. We object to the location of the
intersection because it would have substantial impact upon our
property as well as others' located to the west of the subject
project.
NOISE ANALYSIS
We believe the noise analysis associated with Route 125 does not
adequately consider potential impacts of the various alignments on
the adjoining properties. To the extent the San Miguel project
defines a location of Route 125, we believe such an analysis must
be oontemplated by the EIR, and adequate mitigation measures should
be defined prior to the determination of the final alignment.
CONCLUSIONS
It is our conclusion that project proponent's assumed alignment of
Route 125 is in many ways inconsistent with the Chula Vista General
Plan. Any approval for the San Miguel Ranch project should
encompass all alternative routes for 125 with consistent detail as
to alignment, land use and circulation. Finally, the assumed
alignment generates many impacts on adjacent landowners which have
not been properly addressed.
We appreciate the opportunity to comment on the San Miguel Ranch
Draft Environmental Impact Report and look forward to a progressive
solution to the issues raised herein.
~
Sincerely,
THE BUIE CORPORATION
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D. Andrew Brown
cc: Messrs:
George Krempl
Barbara Reid
Charles Gill esq.
Douglas Buie
Jim Resney
BOARD OF EDUCATION
JOSEPH D. CUMMINGS. Ph.D.
LARRY CUNNINGHAM
SHARON GILES
PATRICK A. JUDD
GREG R. SANDOVAL
SUPERINTENDENT
XlHN F. VUGRIN. Ph.D.
CHULA VIL...'A ELEMENTARY SCHOl,..... DISTRICT
84 EAST "J" STREET. CHULA VISTA, CALIFORNIA 91910 . 619425-9600
EACH CHILD IS AN INDIVIDUAL OF GREAT WORTH
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January 21, 1992
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Mr. Doug Reid
Environmental Review Section
City of Chula vista
276 Fourth Avenue
Chula Vista, CA 91910
RE: General Development Plan, Draft EIR - Rancho San
Miguel
Dear Mr. Reid:
Thank you for the
General Development
Miguel project.
opportunity to review and comment on the
Plan and Draft EIR for the Rancho San
The need for a new elementary school to serve students from
this project is identified in the DEIR, and a school site
designated on the Land Use Plan. The District has not had
the opportunity to review this site and make certain State
and District criteria are met. This should be done prior to
approval of the General Development PlanjDEIR.
Though a school site has been identified, the mechanism for
funding this school site and the needed facilities is
unclear. The DEIR correctly states that developer fees are
not adequate to fully mitigate school impacts and lists
possible alternate measures, including participation in a
Mello-Roos Community Facilities District, as recommended by
the District. Also discussed is the Leroy F. Greene Lease
Purchase Program. It is stated that "Obtainment of state
funds for new facility construction is the primary measure
by which district "impacts" can be mitigated." This is
incorrect. As presently structured, the State Program is
not a viable financing mechanism for the District. There
currently exists a significant backlog of approved school
projects, and funding falls far short. Further, the
uncertainties surrounding future bond issues are
substantial.
January 2l, 1992
Mr. Doug Reid
Page 2
RE: General Development Plan, Draft EIR/Rancho San Miguel
In order to assure elementary facilities will be available
to serve children from this project, participation in a
Mello-Roos Community Facilities District or alternative
financing mechanism is necessary. The City's Growth Program
sets forth the timing for agreements between the developer
and school district and this program schedule should be
followed.
If you have any questions, please contact me.
Sincerely,
Kate Shurson
Director of Planning & Facilities
KS:dp
cc: Tom Silva
Tom Meade
Carl Kadie
4:rsanmig-
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GRANVILLE M. BOWMAN
DIRECTOR
(619) 694-2212
(LOCATION CODE 7riOl
QInuttttJ nf ~tttt ~icgn
DEPARTMENT OF PUBLIC WORKS
COUNTY ENGINEER
COUNTY AIRPORTS
COUNTY ROAD COMMISSIONER
TRANSPORTATION OPERATIONS
COUNTY SURVEYOR
FLOOD CONTROL
LIQUID WA.STE
SOLID WASTE
RECEIVED
JAN 31 7992
F:LAf-LNI/'{G
5555 OVERLAND AVE. SAN DIEGO. CALIFORNIA 92123-1295
January 31, 1992
Ms. Barbara Reid
City of Chula Vista
276 Fourth Avenue
Chula Vista, CA 92110
Dear Ms. Reid
Subject: Rancho San Miguel General Development Plan Draft EIR
Thank you for requesting our comments on this General Development
Plan. We have the following comments:
Traffic/Circulation
The Draft EIR document is not considered complete and in
compliance with CEQA in its present form because the traffic
analysis is inadequate. Listed below are the required components
of an acceptable traffic analysis for this project. When the
items listed below are covered in the traffic analysis and the
Draft EIR, then these documents should be sent out for additional
public review. Please incorporate the following items in the
Draft EIR and traffic analysis:
1. Please address the County Circulation Element correctly. For
example, Proctor Valley Road (SA 1l50.1) is shown as a 6-lane
Prime Arterial ultimately, whereas the County Circulation
Element shows a 4-lane Major Road. In addition, San Miguel
Road, from Bonita Road to SR 125, is shown as a 4-lane
Collector, whereas the County Circulation Element shows a 2-
lane Light Collector. Blacksmith Road, a County 4-lane
Collector, is not shown at all. If any changes to the County
Circulation Element are proposed such as upgrading of road
classifications, additions, deletions, etc., then a County
General Plan Amendment is required.
2. Please address the County Circulation Element Bicycle Network
and identify bicycle lanes where appropriate.
3. Include a discussion of measures required by CALTRANS for
state highway impacts associated with this project.
n...:...~.I _ D_._1_.I n___
Ms. Reid
Page 2
January 31, 1992
4. Incorporate the County Standards for Level of Service in lieu
of the Chula vista standards since this project is within the
unincorporated area of the County.
5. Provide Intersection Capacity utilization (ICU) calculations
for onsite intersections and offsite intersections.
6. The access to the northern portion of this project is not
clearly identified. This unclarity leads to further
confusion on when, where, and how other portions of this
project are to access the existing County Circulation Element
system of roads. Please clarify.
7. The traffic generated by the northern 357 units is shown as
10 trips per unit. Please revise to 12 trips per unit to
reflect the County's acceptable rate for rural estate
development. The elementary school trip rate is shown as 40
trips per acre. Please revise to 60 trips per acre.
8. The traffic analysis should identify that access rights shall
be relinquished into all County Circulation Element roads, as
well as, SR 125.
9. The traffic phasing analysis is inadequate. Please revise as
follows:
a. With each phase, show what occurs to the offsite existing
roads with and without the interim SR l25 and ultimate SR
125. This phased traffic analysis shall include area
roads from the project to 1-805 and SR 54. Provide the
associated tables and map exhibits displaying existing
traffic, project traffic, existing plus project traffic,
buildout traffic, and percent traffic splits. Buildout
year is approximately 2010 for this project.
b. The phased traffic analysis should determine whether
the project should be limited to a certain number of
units until the interim SR 125 or other County
Circulation Element roads are available to accommodate
project traffic.
lO. The revised Draft EIR and traffic analysis should identify
traffic impacts onsite and offsite.
11. The revised Draft EIR and traffic analysis should
incorporate appropriate traffic mitigation measures for the
traffic impacts identified as offsite and onsite.
Ms. Reid
Page 3
January 31, 1992
Flood Control
The subject document adequately addresses the hydrologic impacts
of the project.
Transit
If the city of Chula Vista plans to expand its transit operations
in the unincorporated areas of the County as a result of this
project, then the Draft EIR should address the financial impact
this would have on the County.
Solid Waste
Please evaluate recycling requirements for the project. The
attached, "Mandatory Recycling Ordinance Summary" identifies
recyclable materials and provides an implementation schedule for
the South County Region. Also, please consider an integrated
waste management program to include curbside recycling,
neighborhood recycling/buyback centers, a materials recovery
facility (MRF), a composting facility, and a household hazardous
waste collection facility.
If you have any questions, please call Dirk smith at (6l9) 495-
5679.
Very truly yours,
/rJcUJ1~ ~
~SHARON JASEK REID, Deputy Director
Department of Public Works
SJR:DDS
Attachment
cc:
Bill Hoeben
Larry watt
Rick Anthony
Dwight smith
(0336)
(3580)
(0383)
(0384)
'JAN 31 '92 16:52
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SI...n Of ~"'LI'OIINI"'-THE USOUR~f$ ......ENCY
'fTE WILSON. 00.._
-\ OEPARTMENT OF FISH AND GAME
330 Golden Shore, suite SO
Long Beach, CA 90802
(310) 590-5113
.
January 29, 1992
MB. Barbara Reid
city of Chula Vista
Plannin~ Department
276 Fourth Avenue
Chula Vista, CA 91910
Dear MIl. Reid:
A Department biologist familiar with the project area has
reviewed the Draft Program Environmental Impact Report (PEIR) for
the Rancho Miguel Project caCH 90010155). We do not concur with
the project as proposed due to its unmitigable adverse impacts
to sensitive bioloqical reBourceB. Instead, we recommend that the
BiologicallY Sensitive Alternative 5.4 be mOdified and selected
for the following reasons:
1. The proposed project will eliminate 3.1 acres of wetland
habitat, 467 acres of Dieqan coaBtal sage scrub habitat,
cause direct impacts to 40 out of the 69 pairs of California
gnat catchers known to exiBt on-site, and indirect impacts to
another 8 pairs of qnatcatcherB. Also, the project would
cause adverse impacts to 5 pairs.of cactus wrens, 70-S0
percent of the remaining 200,000 individuals of the state
endangered Otay tarplant: San Diego horned lizard and
orange-throated whiptail (both Candidate 2 species for
fe~eral listing) I reBult in permanent loss of foraging
habitat for raptors aB well as impacts to numerous other
wildlife and plant specieB.
2. The Department recommends that the project be redesigned by
placing the northern portion of the site in permanent open
space to protect the most Bensitive biological resources.
The Biologically Sensitive Alternative 5.4, it implemented,
would result in the northern portion left undeveloped, would
eliminate wetland impacts, and would reduce acreage developed
in the southern portion. However, signifioant impacts to
wildlife and endangered and Bensitive plants would still
remain largely unmitigated. We, therefore, recommend the
redeBign of this Alternative be done in such a manner that it
would reduce or altogether avoi~ impacts to the qnatcatchers,
otay tarplant, coaBt barrel oactus, Palmer's qrappling hook,
and California adolphia.
3. A Memorandum of Understanding CMOU) with the Department 'will
be necessary for any take of the State-listed Otay tarplant.
'JRN 31 '92 16:53
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Ms. Barbara Reid
January 29, 1992
Page Two
A mitigation plan should b. ..tabli.he~ to provide for the
.alvage, transplantation, and monitoring of the otay tarplant
and other impacted .en.itive plant .pecie..
,
4. Although the document for this pro~ect is a 'EIR and a
General Development 'lan, the Department would like to be
involved in future planning for the entire area with respect
to infrastructure, roads, water storage facilities, pump
stations, trail system, and fire marlagement, buffers proposed
for this development.
In conclusion, the Department opposes certification of the
'EIR that would result in unmitigable adverae impacts to
biological reSOuroea. Pro~ect redesign is necessary 4ue to the
high density of sensitive plant and animal species contained
within the project area and their regional and statewide
significance. Department personnel are available to assist the
City and the pro~ect proponent in devising measures to avoid
and/or reduce impacts to a level of non-aignificance. To set up
date, time, and place of meeting, please contact Mr. Randy Botta,
Wildlife Biologist at (619) 674-4407.
Thank you for the opportunity to provide comments on this
project. We request that the lead agency provide us with a copy
of their response to our comment. and/or the final environmental
document, immediately upon approval and prior to filing the Notice
of Determination. If you have any questions, contact Kriahan Lal,
Environmental Specialist at the above addrea. or telephone at
(213) 590-4844.
Sincerely,
&tm~~
Fred worthley
Regional Manager
Region 5
cc: state Clearinghouse
ISD