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Home My WebLink AboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (45)September 28, 1993 Mr. Christer Westman Associate Planner Planning Department City of Carlsbad 2075 Las Palmas Drive CarlsbaJ, CA 82OC3-1576 PBD Tbchndogks Planning 1100 Town & Country Road Suite 300 Transportation Orange, CA 92668 Environmental PO. Box 5367 Economics Orange, CA 92613-5367 Landscape Architecture Engineering FAX 7141953-6989 7141835-4447 An Employee-Owned Company Re: Comments on Draft Program Environmental Impact Report for the Green Valley Master Plan and Master Tentative Map Dear Christer: We have reviewed the draft EIR noted above and wish to make the following comments on several areas of the analysis and conclusions. These are the combined comments from the applicant, Carlsbad Partners, Ltd., and their consultant team. /I Land Use - Paae 1-2 of Executive Summarv and Paae 4.1-7 The discussion of Carlsbad's Open Space and Conservation Resource Management Plan (COSCRMP) an incomplete presentation of the plan's provisions as it relates to Planning Area 4. In addition to the material presented in the EIR analysis the COSCRMP states that: "Although the ultimate use for the property at this major intersection may be commercial, this would not preclude the establishment of a secondary staging area." If the plan intended to include this existing developed area as part of the "additional strips of land between El Camino Real and the riparian corridor" this would not have been discussed as a commercial site. In addition, there is no reasoning in the COSCRMP or in any other applicable plan or policy, how an existing building, two paved parking areas and a graded pad would be an integral part of a natural open space system. The only reasonable conclusion from an analysis of the COSCRMP is that this area was not to be included as part of these "strips" to be designated as open space. The "strips of land" do exist in several places on the property south along El Camino Real. They are included in the project open space area. Land Use - Paae 1-2 of Executive Summary II The Land Use section in 4.1 adequately describes the relationship between land use assumptions (General Plan), public facility adequacy and specific development proposals; however, this information is not carried through in the Executive Summary. Those individuals reading only the Executive Summary may not be afforded an adequate understanding of the Mr. Christer Westman ' City of Carlsbad r September 28, 1993 Page 2 relationship by the brief description under Item 1, Potential Impacts. The Executive Summary should offer a summary of important facts found in the body of the report. One of these is that the holding capacity of,the land based on adequacy of public facilities is an important test which is paramount in the General Plan - Growth Management relationship. Both environmental constraints and public facility adequacy are considered very early in the planning process through the Growth Management Program. The inference in Potential Impact, Item 1, is that the proposed land use is "not in conformance" with the existing General Plan designations due to intensification of use. This is not the case as demonstrated in Section 4.1 and through the Local Facilities Management Plan for Zone 23. The Item 1 statement in the Executive Summary should be expanded to make this clear. Land Use - Circulation ComDatibilitv Issues - Paae 4.1 - 15 and 16 The proposed site plan for Planning Area 4, which has been subject to further refinements not included in the draft EIR analysis, does respond to all significant issues related to compatibility with circulation at the La Costa/El Camino Real intersection. A copy of the refined site plan is included as Attachment 1. The proposed site plan is not at all comparable to the existing service station use on the northeast corner of the same intersection as suggested on Page 4.1-1 6. Two of the three access points are already existing to serve the existing commercial use and all three are much further removed from the intersection than the access points into the existing service station. Right-in and right-out movements are well established methods to solve access to properties near intersections and along major streets. This is particularly true where the amount of traffic requiring access is low. The original master plan proposal, plus the subsequent refinements that have becn suggested by the applicant, establish a workable circulation system for this site. f" The potentially significant biological impact described in Item 3 of the Executive Summary and the discussion of wildlife corridors in Section 4.4 does not include consideration of the existing crossing at La Costa Avenue as it relates to the overall wildlife corridor issue. These existing box culverts constrict any wildlife movement along this corridor to a primary destination - Batiquitos Lagoon. The corridor in Green Valley is maintained by the bridge system discussed in more detail in a following comment. A complete discussion of the corridor issue should include information about the offsite situations including the lack of a crossing at La Costa Avenbe designed similar to the Green Valley proposal. -tion 4.4 The project has proposed a bridge system at Calle Barcelona and Levante Street that is a 36- foot clear span approximately 11 feet high. The applicant's biological analysis has concluded that such a system in the Encinitas Creek riparian coxidor would reduce the impact to below a level of significance. The EIR analysis does not directly address the adequacy of this bridge system for Encinitas Creek. 7 h Mr. Christer Westman City of Carlsbad r September 28, 1993 Page 3 The EIR appears to conclude that the proposed bridge does, in fact, reduce the impact to below a level of significatxe. The four required mitigation measures do not include any change to the bridge design. Therefore, implementing the required mitigation measures in conjunction with the various project proposed environmental protection features will provide the necessary mitigation. This should be clarified. The preferred mitigation options include a description of bridge design that is a width of bridge to the width of undercrossing ratio of 2:l (i.e., a 100-foot wide roadway crossing would need an opening under the bridge of 50 feet wide). This standard is from another study in another part of San Diego County; there is no information how this is relevant to the Green Valley sii:jatioc. As noted 350~5, S-,G a::a:Ysis shdd address whether :he proposed bridge system for Green Valley over Encinitas Creek at the locations proposed reduces the impact to the wildlife corridor to below a level of significance. In summary, it is our understanding that the required mitigation measures identified in the EIR must be implemented to reduce the impacts to below a level of significance. Although impacts would be further reduced if the preferred measures are implemented, no significant, unmitigated impacts would result if the preferred measures are not implemented. Thus, no Statement of Overriding Consideration will be needed if the preferred measures are not implemented. DeDollutant Basins - Paae 4.8-5 The description of the basins should be limited only to the performance standards that need to be met. The portions of the description related to specific basin designs is not appropriate. There may be a variety of basin designs that can meet the standards and the EIR should not limit the approach used. -f-- Detention Basins - Paae 4.8-6. Item 7 The requirement for constriiction of Basin C prior to or concurrent with development of Green Valley should be modified. Further studies at final design and/or changes to the Green Valley pians ar final design may edequately demonstrate how Green Valiey could proceed without Basin C in place. Basin C is offsite and a situation could arise where it would not be possible for it to be built concurrent with Green Valley. This flexibility should be included within a revised Item 7 statement. Circulation - Sect ion 4.9 The circulation section leaves an impression that the "General Plan Land Uses", analyzed primarily for the Alternative Section of the EIR, is the level of traffic generation that has been planned by the City for the property at buildout. This is incorrect. The General Plan Land Use alternative is derived simuly by converting the land area proposed by the applicant for development to a mix of land uses described in the General Plan and projecting traffic from that level of development. The traffic generation projected for the property at buildout and for which area roadways have been planned is 39,000 ADT. This is shown in Table 22 of the WPA report of September 25, 1992. r h Mr. Christer Westman City of Carlsbad r- September 28, 1993 Page 4 The proposed development of Green Valley, which produces total traffic generation of 33,400 ADT, is approximately 15 percent below that planned and reduces total peak hour trips by 60 percent over that planned. This information should be included in the discussion to provide a correct perspective to the traffic issue. Please call if there are any questions regarding our comments. Very truly yours, President GBW:be