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HomeMy WebLinkAbout1980-09-23; City Council; N/A; San Dieguito Circulation Element SA680 SF728I 99 . '1 DATE: SEPTEMBER 23, 1980 TO: CITY COUNCIL FROM: City Manager SAN DIEGUITO CIRCULATION ELEMENT The County proposes to amend the highway circulation plan for the North County area. County Planning Commission will hear the matter September 24, 1980 and the Board of Supervisors on October 15. The key changes which affect Carlsbad are: 1) the deletion of portions of SA680 which connects I-5 to I-15 via Olivenhain Road; 2) the deletion of Melrose Avenue between Rancho Santa Fe Road and SA680; 3) the deletion of SF728 between Escondido and Lomas Santa Fe Road. Discussion The EIR discusses traffic impacts which will be caused by the proposed changes. The data clearly indicates that existing streets will become overloaded if the major through highways are deleted. In the Carlsbad area the main streets which will be overloaded are El Camino Real, La Costa Avenue, Palomar Airport Road, I-5. This issue was discussed at the North County Mayors and Managers meeting on September 18. It was the consensus of those present that North County cities should take a position favoring the retention of SA680 as a through highway between I-5 and I-15; and the retention of SF728 as a through highway between Escondido and Lomas Santa Fe Ftoad. In addition, the Mayors support the upgrading of Highway 76 in Oceanside and the early funding of that route. Also, Carlsbad may wish to oppose the deletion of Melrose Avenue between SA680 and Rancho Santa Fe Road. Recommendation if desired, the City Council may wish to authorize the Mayor to send letter to the Board of Supervisors expressing your position. Attachments Map 2 Proposed Project Map 3 Existing Circulation Element Letter dated 8-22-80 from City Planning Department Letter dated 9-4-80 from San Diego City Manager Letter dated 9-4-80 from Attorney for Ran—o Santa Fe 24*0� FRANK ALESHIRE City Manager FA: ldg CouNu� gc.tto.v 9-a3-Fo CONNc/t r��T�'oR�zko i►-t/�Ya2 r� sENo �.ZrTsc oPPos�n+c 1200 ELM AVENUE TELEPHONE: CARLSBAD, CALIFORNIA 9200 �(�' (714) 74 -Mt' 438-5661 City of Caddab September 24, 1980 , Ms. Kathleen Lethola Secretary, Environmental Review Board County of San Diego 9150 Chesapeake Drive San Diego, CA 92123 SAN DIEGUITO CIRCULATION ELEMENT The City Council has reviewed the draft EIR's prepared by the County Planning and Land Use Department. The proposed changes to the San Dieguito Circulation Element will produce adverse and unacceptable traffic overloads in and around the City of Carlsbad. We believe the ELR has'not adequately addressed these adverse impacts and has not provided mitigating measures which would justify the changes. There are numerous adverse impacts which will be created. Those which most concern the City of Carlsbad are as hollows: 1. El Camino Real (SA650) is not designed to carry the traffic levels projected for the year 2000. 2. Rancho Santa Fe Road is shown as having level of service "D" under the proposed and existing projects. 3. La Costa Avenue MOW W is shown as carrying 14,000 ADT in the year 2000. The current level is 13,,000. The data seems to be incorrect. The proposed project shows La Costa Avenue being downgraded from a major arterial to a collector. This does not appoar to us as being realistic. 4. Melrose Avenue is proposed to be deleted as a ,crime arterial between Rancho Santa Fe Road (SF1412) and SA680. This deletion will cause traffic overload on other roads such as E1 Camino Real.' In addition, we believe the CPO Serias V population, forecast will prove to be undorsta;.ed. 1f so, the traffic volumes are also understated. .j September 24, 1980 Page 2 San Dieguito Circulation Element In view of the adverse impacts revealed in the El'R, we believe "the proposed project should not be approved. Since 1972, Carlsbad has based its planning and land use assumptions on the adopted Circulation Element. The changes now proposed in that element are substantial and will adversely impact existing and future developments within the City of Carlsbad. We would urge that the changes proposed to the 1972 Circulation Element not be made, or that SA680 (Olivenhain extended), SA728 (Lomas Santa Fe extended), SA460 (Melrose), and SA630 (La Costa) not be changed from the 1972 Circulation Element, or that pro- visions be made to require setbacks and dedications for the above 'listed roads as development occurs. We urge the County not to approve the project as proposed. Sincerely, RONALD C. PACKARD Mayor ! RCP:ldg I LEUCADIA 41,9' 28 ENCINITAS 920 CARDIFF MAP 2 PROPOSED PROJECT Year 20DO Average Daily Traffic (ADT) , Volumes in Thousands (000) FREEWAYS ananne PRIME ARTERIALS MAJOR ROADS COLLECTOR ROADS ........... LIGHT COLLECTORS —___ JURISDICTIONAL BOUNDARIES uu a rood toot tow v000 SOLANA BEACH ES7LONO�OU 60 \\ r J j • ofl 1 '� ��i' Dios \ l �' 35 34 sw SrD .■. ■ FSA 680 Prime Arterial ROW "14 ection Only, MaximumiF `•Qector Standards" 1 sc ISM \I �.� LANE ISF 1 ) `' 10 HODGES 11 —. -- le bto,' 1 RANCHO62 20 187 sF uoD 15 it 1409 O yn ! f F, ♦ ; _ `( Lan■. sr+u ,•: , I Sty � � ♦♦ DEL MAR INWIA 1200 ELM AVENUE CARLSBAD, CAr_IFORNIA 92008 August 22, 1980 3 San Diego County Department of Planning and Land Use I Environmental Policy Section r 1600 Pacific Highway San Diego CA 92101 Thank you for the opportunity to comment on the Environ- mental Impact Report for CPA 80-CE (80-CP-10 for the addi- tion of State Route 56 to the San Dieguito Circulation E Element). Our comments concerning these documents are i listed below. TELEPHONE: (714) 438.5621 The San Dieguito planning area has its northerly boundary along La Costa Avenue (SA630). Within tr►e vicinity of the planning area are arterial highways which are significant to the City of Carlsbad, includ- ing La Costa Avenue, E1 Camino Real, Palomar Airport Road, Rancho Santa Fe, Olivenhain Road, Highway 101 and Interstate 5. The EIR shows a proposed circulation element that revises the existing element approved in 1972. Table 1 on page 12 of the EIR indicates roads proposed for reclassification by the proposed project. Of particular concern to the City is the reclassifica- tion of La Costa Avenue between I-5 and Highway 101 from a major arterial to a collector. Considering the existing 1979 ADT of 8,100, this would be reasonable if no additional traffic were generated over the next 20 years. With the current development proposed easterly of the area and noting - the additional traffic being assigned to I-5 that may desire to use La Costa Avenue for a beach route, it would definitely appear that this Creclassification is undesirable. y I San Diego County August 22, 1980 Page Two (2) Map 2 indicates that La Costa Avenue (SA630) east of I- 5 will carry 14,000 ADT for design ,year 2000. The 1979 volume map shows this street carrying 13,000 ADT. The 14,000 ADT for 20 years in the future appears unrealis- tic as this is only a 1^00 vehicle per day increase in 20 years. Table 5, page 28, shows th; projected service levels and traffic volumes for the year 2000 under the various alternatives. All alternative circulation elements and the existing element show t1 Camino Real with a very undesirable level of service, the best being level of service D with 44,000 ADT under the existing element. Additionally, Rancho Santa Fe Road is shown as having a level of service D under the proposed and existing elements. My experience with the CPO computer forecast is that it tends to bhow lower volumes than can actually be expected. Should this be the case with respect to the projections for the above arterials, the•City of Carlsbad is going to be suffering *rom intolerable , congestion within the southeast portion of the City. It appears that some relief is necessary for arterials,,) within the eastern area of the City. if you have any questions please feel free to call $tracker (138-5541). City of Carlsbad c4/I CHARLES GRIMM Associate Planner CG:ls concerning the above comments, either myself (438-5591) or Bill i THE CITY OF SAN DIEGO CITY ADMINISTRATION BUILDING • 202 C STREET • SAN DIEGO, CALM: 92101 OFFICE OF THE CITY MANAGER 236.6363 September 4, 1980 Ms. Kathleen Lethola Secretary, Environmental Review Board County of San Diego 9150 Chesapeake Drive San Diego, CA 92123 DRAFT EIR'S FOR THE SAN DIEGUITO CIRCULATION ELEMENT, GPA 80-CE, AND AMENDMENT TO STATE ROUTE 56 TO SHEET 4 OF THE ADOPTED CIRCULATION ELEMENT. The City of San Diego has reviewed the aboved referenced Draft EIRs prepared by the County of San Diego Planning and Land Use Department in July 1980. The proposed projects analyzed in these Draft EIRs would, if implemented, have direct and indirect adverse effects upon The City of San Diego. Our review of these environmental documents indicates that thp,;e effects have not been adequately addressed. There are important significant impacts which are not described in these Draft EIRs and several potential impacts have not been analyzed to determine their significance. In addition, the environmental review performed by the Planning and Land Use Department does not sufficiently reflect the long-term cumulative impacts of development within the study areas and nearby portions of The City of San Diego. Our specific comments concerning these Draft EIRs WEIR hereafter) are listed below. 1. The Average Daily Traffic (ADT) used in both DEIRs are based upon Series V preliminary forecasts for the Year 2000. The City Planning Department and the County Planning and Land Use Department have both expressed dissatisfaction with preliminary Series V forecasts, particularly regarding their accuracy in distributing the regional population, housing and employment totals among the various subareas and communities of the region. City analysis indicates that the preliminary Series V forecasts may be as much as 100 percent low for some suburban communities within the City. The County Planning and Land Use Department, by memorandum dated July 31, 1980, informed the Board of Supervisors of several reservations regarding the preliminary Series V forecasts. In light of these and other concerns the CPO final Series V forecasts are expected to show substantial change frmi the preliminary figures. Adequate analysis of the short-term impacts of the alternative proposals reviewed in these DEIRs requires that they be revised to Page 2 utilize the final Series V forecasts in projecting Year 2000 ADT volumes and determining the magnitude of adverse traffic impacts associated with the transportation systems evaluated. 2. The DEIRs reviewed only the short -,arm traffic impacts of Year 2000 land use and transportation system patterns without regard for the long-term effects of development beyond that horizon year. As was pointed out in the County Planning and Land Use Department memo, referenced above, it is anticipated that regional growth will continue after the Year 2000 horizon year of the Series V forecasts. This will occur through a combination of redevelopment of currently developed areas for more intensive use and new development on remaining vacant lands. The Progress Guide and General Plan for The City of San Diego designates an area of about�7'f, 000 nacres w 6 n e o h Ci ty as "Area for Future Growth." The Guidelines for Future Development define this area as "Future Urbanizing...to be held as an 'urban reserve', and...(to) be released for development as the planned communities are built out...." This area will be developed as a series of "new communities" as the already developing communities of North City reach their development capacities. Original City Planning Department estimates based upon Series IVb forecasts indicated that this "urban reserve" would not be required to accommodate growth until after 1995. However, since adoption of the Series IVb forecasts the County Regional G;°owth Management Plan has resulted in reduced population and housing capacities for many unincorporated communities. The preliminary and final Series V forecasts for jurisdicitons reflect these changes in County policy. The Series V figures indicate that the City is anticipated to have a faster rate of growth than that projected under Series IVb assumptions. In the North City the preliminary Series V 1995 housing forecasts were 24 percent higher than the Series IVb 1995 housing forecasts. These changes in the Regional Growth Forecasts will require the City to reanalyze the timing of development within the Future Urbanizing area and may result in portions of this area being released for development prior to 1995. These accelerated growth rates within the already developing communities of North City indicate that development will almost certainly be occuring within the Future Urbanizing area soon after 2000. Because of the expected timing and intensity of development within the Future Urbanizing area it is inadequate to limit the analysis of traffic impacts in the DEIRs to Year 2000 ADT levels. In order for this area to develop at the expected intensity it will be necessary to provide regional scale transportation facilities. It is necessary that these facilities be anticipated today and that positive steps be taken to define and preserve adequate rights -of -way capable of improvement concurrent with development to provide sufficient inter - and intra-community capacities for ultimate •traffic levels. Both DEIRs show road segments operating at or near design capacity with Page 3 Levels of Service of 'D,' 'E' or 'F' in the Year 2000. Only one road segment is assured of adequate right-of-way protection to provide for future widening; SA 680 from Del Dios Highway to SF 1411. Even this segment is misleading, since no linkage is to be protected from Del Dios Highway east to Rancho Bernardo. Series V forecasts for Year 2000 assume that thousands of acres of developable land in the San Dieguito community will be vacant. When this property is developed new traffic will be generated. If, for example, this area were to develop as single-family detached housing, it is estimated that approximately 90,000 additional trips would be generated. If the Future Urbanizing area of North City were developed at intensities similar to existing communities there would be an additional 280,000 trips. The impact of this long -tern increase in traffic volumes is not considered in the DEIRs because this potential development is not reflected in the Series V Year 2000 forecasts. Failure to provide for long-term development in this area will ensure that future ADT volumes on the local transportation network will exceed design capacities as the Future Urbanizing area of the City is developed to accommodate regional growth. This will cause unacceptable congestion, an increase in traffic safety hazards, contribute to increased fuel use and air pollutant production and reduce accessibility within this subarea of the region. In order for these DEIRs to °adequately address these long -tern environmental effects, it -is necessa-y that projected ADT volumes be generated based upon ultimate development intensities. For those unincorporated areas of the County these figures may be derived from the Regional Growth Management Plan. The City has provided the County Planning and Land Use Department with a copy of the Rancho Carmel Transportation Study (H. Kimmel and Associates, Inc., May 1980,) which provides ultimate ADT projections for the Interstate 15/Poway subarea. This data may be used in revising the DEIR "Amendment of State Route 56 to Sheet 4 of the Adopted Circulation Element" (Hereafter SR 56 DEIR). City staff will be available to assist County efforts to estimate future land use patterns and ADT volumes for the DEIR "San Dieguito Circulation Element, GPA 80-CE" (hereafter San Dieguito DEIR). In order to illustrate the importance of using ultimate ADT projections a comparison of the volumes predicted for the same transportation system proposal is included as Table 1, bel-ow. This table contrasts the ADT projections included in the SR 56 DEIR and those produced as part of the Rancho Carmel Transportation Study (RCTS). The alternative analyzed includes SR 56 from the City -County boundary east to SA 680/SR 125 as a Prime Arterial. y Page 4 TABLE 1 (Thousand ADT) SR 56 DEIR RCTS Alternate 3 Exhibit 6.0 Road Segment 2000 A.D Ultimate SR 56 (City Boundary-Pomerado) 25-30 64 SA 680/SR 125 40-50 44-90 Pomerado (SR 56-SA 680) 20-25 30 Poway Road 20 25-39 Rancho Bernardo/Espoia Road 20 36-40 SR 56 (Pomerado-SA 680/SR 125) Not Analyzed 43 Glen Oak (Pomerado-SA 680/SR 125) 4 Not Analyzed As this comparison shows the ultimate ADT along these streets are substantially higher than the Year 2000 ADT. Although detailed comparisons for the San Dieguito/North City area cannot be made, the magnitude of traffic volume growth from Year 2000 to ultimate build -out is expected to be proportional to that shown for the Interstate 15/Poway area. It is necessary that action be taken now to ensure the ultimate, long-term traffic demand can be accommodated by the transportation system developed within this subarea. These DEIRs, which restrict themselves to the short -tern effects expected by the Year 2000 do npt adequately evaluate the full range of probable effects which would result from adopting the alternative transportation systems. Correction or this serious omission in the environmental analysis of these proj(cts requires that the long-term ADT levels be projected, that a full evaluation of the appropriate road segment classifications be undertaken, levels of service expected under different proposed alternatives be determined and mitigation measures for expected impacts be described. 3. The DEIRs are inadequate in their analysis of potentially significant impacts upon The City of San Diego. The SR 56 DEIR did not evaluate the effects upon the transportation systems of adjacent City communities, nor was any attempt made to project ADT upon City streets. The San Dieguito DEIR included insufficient discussion of adverse effects within the City. Although ADT projections were calculated for four road segments within the City, projections for other segments, parallel to roads proposed for deletion or degradation in classification, were not included. Specifically, the San Dieguito DEIR analysis should include ADT projections for SA 700, SA 701, SA 710, SA 730, SA 750, and SR 56, E1 Camino Real south of Del Mar Heights Road between I-5 and I-15. The DEIRs should also have addressed the potential deletion or degradation of Freeway SR 56. As is summarily noted in the introduction to the SZ 56 DEIR, the California Transportation Commission has issued a "Notice of Intention to Consider Rescinding 7 Page 5 Adopted Location of State Route 56 frcm I-5 to SA 680 and from SR 125 to SR 67." However, the DEIRs fail to describe the impacts this recission would have upon traffic conditions in the affected area. Expanding the analysis to include those road segments lying within the City and including an alternative showing SR 56 as either a Prime Arterial or deleted would provide sounder information regarding the impacts of these proposals. 4. The DEIRs state that degradation of Level of Service (LOS) from 'A,' 'B,' 'C,' or 'D' to 'E' or 'F' would be considered a significant traffic impact. Although this arbitrary criterion may be valid, the, City feels that the DEIRs should have further evaluated the effects of accepting LOS 'D' upon traffic safety, energy conservation programs, and air pollution control effcrts. Regional planning programs have indicated that increased congestion and unstable traffic flows are significant contributors to air pollutant production and fuel consumption. The Regional Transportation Improvement Plan, therefore, includes many projects intended to decrease congestion and restore stable traffic flows within the already developed part of the region. The cumulative effects of accepting LOS 'D' within this newly developing area of the region may be significantly adverse on both a local and regional scale. The DEIRs should be revised to include analysis of this issue. S. The San Dieguito DEIR states that the Proposed Project would result in a net reduction of vehicle miles traveled (VMT) and total trips as compared with the existing Circulation Element. The source of this assertion is not documented. The total number of trips should remain constant for all alternatives if the same land use and population assumptions are used thvougout. The VMT will vary depending upon the transportation network provided, and some destinations will be altered as limitations upon mobility are imposed, e.g. congestion, deletion of direct linkages to desired destinations, etc. Review of the data indicate that the total trips and VMT vary less that one percent (1%) among the alternatives evaulated. The conclusion that this variation would have any measureable beneficial effects upon energy consumption or air pollution is not reasonable, especially in light of the increased congestion and unstable traffic flows concommitant with LOS 'D,' and the requirement that persistant drivers make out -of -direction travel a part of their daily lives as they go to their chosen destinations. 6. The DEIRs do not analyze the effect of locating a General Aviation Airport in the North City/San Dieguito area. The San Diego Plan for Air Transportation (SANPAT) adopted in 1976, all Regional Transportation Plans (RTP) prepared subsequent to the adoption of SANPAT, including the draft RTP currently undergoing CPO member agency review, and the draft Airport Systems Plan Update (February 1980) have designated a Mid -County General Aviation Airport site generally west of Rancho Bernardo and referred to variously as 'Pioneer Field' or /© Page 6 'San Bernardo.' This facility is proposed for development as a training strip in 1980-1985, single -runway, full -service airport in 1985-1990, with addition of a second runway scheduled for 1990-1995. The proposed location of the Mid -County General Aviation Airport indicates that SA 680 will be required to provide access to the facility. Additionally, assuming that the regional pattern of development is followed, it may be anticipated that the Mid -County General Aviation Airport will be surrounded by several hundred to several thousand acres of industrial and commercial land uses, as are Montgomery, Gillespie, Palomar and Lindbergh fields currently, and for which the area near Brown Field is planned. These intensive land uses will require major transportation system improvements. As described in point 2 above, these eventual land uses must be considered as part of the DEIR analysis in order to fully understand the potentially significant long -tern effects of abandoning a major portion of the regionally important transportation system in this area. 7. The San Dieguito DEIR indicates that E1 Camino Real (SA 650) will carry 60,000 to 71,000 ADT and Manchester Avenue will carry 62,000 ADT at Year 2000, (Map 2, Proposed Project). It is believed that these road segments will not be able to accommodate these traffic levels. Instead, because of capacity restraints imposed by the proposed road classifications, some traffic will be diverted to other local and collector streets. The DEIR should analyze the effects that the road classification Capacity restraints will have upon alternate routes. 8. The San Dieguito DEIR is also considered inadequate due to its failure to sufficiently analyze all reasonable alternative projects. Specifically, The City of San Diego believes that the alternative represented by Figure 1 (attached) should be subjected to full review prior to final Environmental Review Board action. The alternative shown on Figure 1 would essentially duplicate the Proposed Project with two changes. SA 680 would extend as a direct, unbroken alignment from I-5 to I-15, with sufficient right-of-way reserved for eventual development as a Prime Arterial. Interim development within the protected right-of-way would provide access via Collector or Major Road improvements, as necessitated by traffic levels. SF 728 would extend from the Via de la Valle/I-5 interchange to Del Dios Highway in an unbroken direct alignment with the same Prime Arterial right-of-way protection and interim improvement conditions as SA 680. This alternative proposal would preserve sufficient right-of-way to permit accommodation of anticipated future traffic volumes which will be generated by development within the Sap, Dieguito/North City area. Although the 1972 Circulation Element is vreferred, this alternative should be acceptable. 9. The SR 56 DEIR analyzed two alternatives which would provide direct uninterrupted alignments from I-15 to SA 680/SR 125 for the Prime Arterial SR 56. Subject to the comments p�o`vided in this latter, The City of San Diego would find either of these proposals acceptable. Page 7 In conclusion, we would like to request that in future a copy of the Notice of Preparation and Draft Environmental Impact Report regarding all proposed amendments to the County General Plan, Community Plans, and all major private and public projects lying within that area encompass*d by the General Plan Map of the Progress Guide and General Plan for The City of San Diego (enclosed) be prow di-ed-to—tV Mcyvmiirager and Pfam'5-159 D-ir—ecEo—ro-rThe City of San Diego. The area described within the General Plan Map lyipq n• ide the boundaries of The City of San Diego is considered Within the Metropolitan Area of The City of San Diego, and planning ano uevelopment activities taking place within those areas may have direct and/or indirect effects upon our planning activities. In the near future we expect to undertake a Sphere of Influence study to define which of these areas will be ultimately annexed to The City of San Diego. Upon completion of this study, the General Plan Map will be appropriately amended and your office will be notified of the refined boundaries of areas bearing relation to our planning activities. Until that time, we will appreciate your efforts to assist us in an orderly and expeditious evaluation of proposals within the F-Atropolitan Area. In closing, we wish to thank you for this opportunity to review these draft environmental reports. Should there be any questions regarding our comments or should you require any further assistance in revising these documents to assure their adequacy and sufficiency, please contact us. Sincerely, RAY T. BLAIR, JR. City Manager TO:h Attachments JAC VAN CLEAVE anning Director cc: C. Graves, Chief Administrative Officer, San Diego County R. Massman, Director, Transportation Department, San Diego County R. Huff, Executive Director, Comprehensive Planning Organization c /a ALTERNATIVE TRANSPORTATIO SYSTEM FREEWAYS �����• PRIME ARTERIAI ..�� MAJOR ROADS COLLECTOR ROr -••-----•-• LIGHT COLLECT JURISOICTIONAI BOUNDARIES RAY, CARY, AMES & FRYE CORDON CRAY(1077.1907) ATTORNEYS AT LAW W. P CARY(1082.19-3) 925 13 STRECT, SUITE 2100 WALTCR AMCS0093•1000) FRANK A. FRTC(1904.1970) SAN DIEGO, CALIFORNIA 92101 TELCP-c:JC !71d3 236-1661 t CLCCOPIF.R(71n3 2]6-10+8 WUO TWK 910 375.1273 September 4, 1980 County of San Diego Environmental Review Board 9150 Chesapeake Drive San Diego, CA 92123 ATTN: Ms. Kathy Lehtola; Secretary Re: Draft EIR - San Dieguito Circulation Element (GPA 80-CE) Members of the Board: LA JOLLA OFFICC 1200 •ROSPCCT STRCCT.Su1TC L7S LA JOLLA. CAU FORRIA 92017 (i1 A��5�•0101 IM ►CRIAL COYRn orme — SOUTH C10-714 STIICCT POST OFFICC 60A 2-16 CL CCNTRO.CALIFORRIA 922M (71-3353-61.0 The Rancho Santa Fe Association opposes certification of the Draft ETR for the San Dieguito Circulation Element Amendments. The Draft EIR: (1) fails to identify and ade- quately discuss all significant adverse traffic impacts of the Proposed Project; (2) fails to assess reasonable alternative road plans; (3) fails to propose feasible mitigation measures for traffic congestion; and (4) is based on a traffic analysis which is inadequate and incorrect. A. The Draft EIR Fails To Identify All Significant Short -Term Adverse Effects Of The Proposed Project. 1. The Proposed Project will not accommodate traffic needs generated by population growth in excess of the prelimi- nary forecasts relied upon in the Draft EIR. These forecasts (CPO preliminary Series V) have been criticized by the City of San Diego for underestimating population growth and inaccurate- ly dist=ibuting it throughout the San Diego region. Any under- estimation of population growth prior to the year 2000 will be significant because many plan area roads will be operating at capacity (and beyond capacity) by that date under the Proposed Project (Draft EIR p. ii). According to the City of San Diego, the adoption of the County Regional Growth Management Plan has restricted the population and housing capacity of many unin- corporated areas of the County, and adjustments to the Series V /Y GI ♦Y. CAnY. Amcs 6 FRYE County of San :.,iego September 4, 1980 Page 2 forecasts must be made to redistribute anticipated population growth. The City anticipates that areas now designated for future urbanization will be needed to accommodate development prior to the year 2000 or sooner thereafter than originally expected. Regional transportation facilities to accommodate this anticipated growth should be protected. 2. In addition to underestimated population fore- casts, the methodology used to generate and distribute daily vehicular trips (ADT) tends to understate future congestion (discussed below in part C). The cumulative effect of using unreliable population figures, underestimating future conges- tion, and tolerating capacity road conditions is likely to be significant even before the year 2000 (and certainly there- after). Tables 5 (p. 28)and 6 (p. 31) indicate that this congestion will affect Circulation Element roads, local roads, and regional roads. These impacts should be recognized as significant and mitigated to the maximum extent feasible by providing additional road capacity and by protecting corridors for future expansion. 3. The Draft EIR characterizes the level of service of individual roads in order to determine whether predicted future traffic amounts to a significant impact. Each service level covers a range of traffic volume, but the Draft EIR does not identify the capacities for different road classifica- tions -- e.g., what volume can a prime arterial, a major road, a collector road, or a light collector accommodate? Level -of - service classifications obscure substantial variations among alternative road plans which receive the same designation. For example, the traffic on extremely congested routes is worse under the Proposed Project in most cases although "it'is clas- sified at E or F level under all alternatives (see table, p. ii) . The service level suggests that there are no plan, to - plan significant impacts, wKen i"n'fact the alternative road networks provide partial mitigation. The Draft EIR identifies a number of roads which will be operating at D level under the Proposed Project (p.ii) but concludes that this level of congestion is not significant. This level represents capacity conditions and should be identified as a significant impact, especially in view of the underestimated traffic data and the failure to assess traffic roeds after, the year 2000. 4. The Draft EIR acknowledges that a number of plan area roads are important access routes to the coast identified in the Local Coastal Program Access Component. The Draft EIR concludes that none of these routes would be impacted with the C'RAY CARY. AMCL 6. FRYC County of San Diego September 4, 1980 Page 3 adoption of any of the alternatives proposed in the Draft EIR (p. 23). This conclusion is not supported by Table 5, which shows significant differences in ADT projected for these roads when the alternatives are compared: Existing Proposed Road Segment ADT Project Alt. 1 Alt. 2 Alt. 3 " La Cosa Avenue 10 [C] 14 [B] 9 [B] 7 [C] 12 (SA-630) Encinitas Blvd. 20 [C] 16 [B] 9 (C) 14 [C] 16 (SF-1410) Manchester 13 [F] 62 [F] 58 [F] 59 [F] 62 Avenue Lomas Santa Fe 15 [C] 15 [C] 12 [C] 10 [C] 12 Drive (SF-1409) Via de la Valle 11 [C] 20 [C] 18 [C] 20 [C] 20 (W. of I-5) Via de la Valle 11 [C] 24 [C] 30 [C] 18 [C] 28 (E . of 1-5) Pacific Coast 17 [D] 28 [C] 24 [D] 29 [D] 30 Highway (SA-101) Interstate 5 83 [D]118 [D]115 [D]118 [D]115 (Plan Area) Interstate 5 100 [E]199 [E]189 [E]205 [E]196 (S . of Plan Area) , La Camino Real 17 [Fj 60 [D] 44 [F] 69 [F] 65 (SF-1411) This table and the table identifying routes with potentially significant congestion (p. ii) show significant increases over existing traffic and significant congestion on coastal access roads under the Proposed Project. These impacts can be and should be mitigated by adopting an alternative which reduces ADT on coastal access routes, in order to implement the impor- tant Coastal Act policy of preserving maximum physical access „ to the shoreline. /(P .G11AY, CAF2Y. AM C i a FRYC County of San Diego September 4, 1980 Page 5 10. The Draft EIR fails to include significant devel- opments which are projected prior to the year 2000, such as the proposed Mid -County General Aviation Airport east of Rancho Bernardo. As pointed out by the City of San Diego, SA-680 will be required to provide access to that facility, and development of the airport will result in dramatic changes in land uses in the surrounding area. The Draft EIR should acknowledge the existing planning for this facility, and the corridors for pos- sible future development should be preserved. B. The Draft EIR Fails To Identif And Discuss The Lonq- Term, Cumulat i VA Tmr� 4 .. _ ec Under the Proposed Project, a significant number of plan area roads will be operating at capacity (D level of ser- vice) or congested (E or F) levels by the year 2000. In addi- tion to the fact that pre-2000 traffic needs are probably underestimated in the Draft EIR, the Proposed Project does not accommodate the foreseeable long-term traffic impacts which will result shortly after the year 2000. The County clearly expects growth to occur after the year 2000, but no mitigation for these long-term cumulative im acts is proposed in the Draft EIR. The Propose Project ai s to protect rights -of -way which could accommodate future road expansion and which are protected under the existing Circulation Element. It is not necessary to build out long-term road capacity prior to the time it is need- ed, but responsible planning requires that the potential for expansion be protected by reserving corridors for major roads. The City of San Diego has prepared and provided to the County a traffic analysis of a portion of the plan area (tire I-15/Poway subarea) which projects post-2000 traffic;, A com- parison of this study with the Draft EIR indicates that very substantial traffic increases will result on these roads after the year 2000, if not before. This comparison identifies a long-term adverse traffic impact associated with relying on year-2000 traffic projections without preserving the potential for growth after that date. C. The Traffic Analysis Relied Upon To Assess Future Con - ion Contains Errors And Deficiencies. At the Association's request, a traffic engineer has reviewed the procedure used to predict and distribute vehicular trips (ADT) on plan area roads. His review indicates that the traffic analysis is defective and inaccurately reported in the �7 GRAY CA14Y A-LG s Fare .. County of San Diego September 4, 1980 Page 4 5. SF-728 terminates at E1 Camino Real under the Proposed Project. The Draft EIR acknowledges that the City of San Diego does not accept this intersection (within City lim- its) as a "permanent solution" (p. 9). The City has stated that it supports a connection of SF-728 with Via de la Valle, as depicted in Alternatives 1 (1972 Circulation Element) and 3 (SF-728 North). How can the County of San Diego rely on this termination point for SF-728, which the Draft EIR concedes will require the City's cooperation, when the City opposes it? Is the Draft EIR acknowledging that the Proposed Project provides only a temporary solution? Is the County of San Diego forcing the City to accommodate the high traffic volume generated by this termination by constructing improvements at Via de la Valle and Del Mar Heights Road? 6. A substantial intersection must be constructed to accommodate the significant traffic predicted for the connec- tion between SF-728 and E1 Camino Real. The Draft EIR does not discuss the environmental effects of requiring such an inter- se ction in this environmentally sensitive area. 7. There is no mention in the Draft EIR of the pro- posals currently being considered for SR-56. The Draft EIR for the SR-56 project predicts heavy traffic demands on SA-680 be- tween I-15 and Pomerado Road (40-50,000 ADT, service level C or D) and on SR-125 which connects with SA-680 (50,000 ADT, ser- vice level D) (p. 18). The SR-56 Draft EIR also acknowledges explosive growth in the North County area and the need to ac- commodate regional traffic. Has staff considered the impacts of the alternative SR-56 proposals on the San Dieguito Circu- lation Element and vice versa? What effect will the gap in SA-680 have on SR-125? 8. The Draft EIR for the SR-56 project states that roads operating at capacity 'or congested levels (with slow - moving, stop -and -go traffic flew) can have significant impacts on air quality and energy consumption (pp. 15, 16, 20). Why are these impacts not identified in the Draft EIR for the San Dieguito Circulation Element? 9. The Association believes that the constricted road network provided under Proposed Project may have signif- icant adverse impacts on: the ability to provide adequate public transportation corridors; mutual aid agreements among North County cities for police and fire services; the evacu- ation plan for San Onofre and other natural disasters. These impacts should be evaluated and addressed in the Draft EIR. V ' -Afj Y. A-tZ & F-R,C County of San Diego September 4, 1980 Page 7 critical roads has been understated. For example, sstarlightanalysis collectorewProposeoject speed SA-680pwas reprein the com- hour, rather than a with with a operating p ed Of 25 milesPerhour. This reduced olletPeed of 35 miles per an underrepresentation of the volume of traffic attracted to capacity an speed for SA-680 resulted in this road. A similar error was m ade which was assigned a speed of 40and for Palomar Airport Road, than 50. These and other errors indicatelles rather future the traffic Projections relied upon in the Draft EIR to determine er rfut re road capacity are unreliable. D. The Draft EIR Fails To Pro ose Feasible tqiti ation Mea___SUres. pose increasedAroadscasacatabove, the Draft EIR fails to pro - traffic congestion under the as a means of mitigating Predicted tection as a means of mitigating longroposed termProject,or g g predicted imp c sa tt 9 long-term, cumulacOEIL raffic 2• No mitigation is the significant regional impacts Proposed in the Draft EIR for 2-15 which will be Operating Proposed Project on and F south of SR-_ (Tatie96at service level E north of SA-680 all mitigate this significant �effect�and, ther a ore 1 considered as mitigating s therefore, shoulddbe g 9 measures. E. The Draft EIR Fails tern.,ativTo Assess Reasonable Pro'ect A1- _es, The Draft EIR assesses several alternative fbad net- works, but it does not assess all reasonable alternatives. Because the Board of Supervisors feasiblecannotadooptca road plan significantly different from the alternatives as- sessed in the EIR, the staffs selection of alternatives actu- ally revise9controls assess theultimate trafficcimpacts " The Draft EIR should be in order to present a realistic choiceoOfaalternativesdditional ato the Board of Supervisors, Plans Bfeatures that sue existing alternatives include objec- tionableby comparison, the ProposedeProst jectnappearsrmoretreasonableand, than it actually is. The Association and the City of staff analyze an additional alternative wSan Diego request that hich uses the Proposed GRAY. C.ARY, AmcS 4 FRYC County of San Diego September 4, 1980 Page 6 Draft EIR. As a result, the Draft EIR does not include reli- able information on the volume of future traffic or the road capacity required to accommodate it. 1. The Draft EIR reports (for the Proposed Project) V8,000 ADT along S-8 through the Rancho Santa Fe area and 15,000 along the improved portion of Lomas Santa Fe (a continuation of S-8 between E1 Camino Real and I-5 (Map 2, P. 10; Table 5, p. 28). However, the computer printouts actually show 15,000 ADT on S-8 east of the intersection with El Camino Real With 8,000 ADT, S-8 (a two-lane light col- lector road) is operating at capacity at D service level; 15,000 ADT clearly exceeds the capacity of this local road. This significant effect is not reported in the Draft EIR, nor is mitigation proposed. 2. Staff has not explained how it derived the traffic estimates reported in the Draft EIR for local roads S-6 and S-8, and they appear to be quite low. For example, the traffic volume for S-6 under the Proposed Project in the year 2000 is predicted to be 1,000 less than the volume existing today (Table 5, p. 18). 3. The computer analyzed traffic for selected and specific locations, but the Draft EIR reports ADT for an entire road or highway, The Draft EIR should state where the traffic volumes are expected and the total number of route miles operating at low or congested levels. 4. According to County staff, Map 6 (Alterna- tive 2, SF-728 New Interchange) incorrectly depicts the road network analyzed by the computer. The ADT figures'on-this map apparently were based on a more direct connection to Escondido without the sharp jog between SF-728 and Del Dios Highway. The Draft EIR map should accurately 'reflect the road network actu- ally analyzed so that the alternatives can be validly compared, S. A segment of SA-680 west of El Camino Real was omitted from the computer analysis. The failure to include a direct connection to I-5 results in an underestimation of future SA-680 traffic attracted to this route. 6, The County staff has computed future traffic by assuming, among other things, different speeds for different roads. These speeds have been selectively adjusted and are not uniformly applied, with the result that the traffic on certain ,)0 GRAY, iAf4y. Amt:s 6 rpyr County of San Diego September 4, 1986 Page 8 Project as a base but incorporates these features: (1) a con- tinuous regional route for SA-680 with a direct connection to I-5 and I-15 (like the Proposed Project but without the gap); (2) a continuous regional route for SF-728 connecting to I-5 along Via de la Valle on the west and to Del Dios Highway on the east; and (3) prime arterial corridor protection for SA-680 and SF-728, although they could be built to lesser standards. This proposed alternative will facilitate local and regional traffic and will mitigate short-term and long-term traffic con- gestion. It will avoid the adverse effects associated with a new interchange at I-5 (as in Draft EIR Alternative 2) and the adverse impacts of eliminating SA-680 (as in Draft EIR Alterna- tive 3). The adverse impacts associated with the easterly river crossings (one for SA-680, one for SF-728, as in Daft EIR Alternative 1) can be avoided by designing one intersection north of the San Dieguito River. This proposed alternative is a reasonable and feasible means of mitigating potential traffic congestion, and it should be analyzed in the EIR and presented to the decisionmaker. F. Action By The ERB Is Requested. In light of the above cormnents, the Association re- quests the Environmental Review Board to take the following action: 1. Recommend that staff analyze the traffic and other environmental impacts of the additional alternative pro- posed by the City of San Diego and the Association and incorpo- rate this information in the Final EIR forwarded to the Board of Supervisors. 2. Recommend that staff clarify and expand the Draft EIR discussion of traffic impacts in order to correct the problems identified above arid accurately assess all significant impacts. 3. Identify significant adverse traffic impacts of the Proposed Project (compared to the Draft EIR alterna- tives) which affect Circulation Element roads, local roads, and regional roads. f 4. Identify a continuous route for SA-680 be- tween I-5 and I-15 and continuous route for SF-728 between Via de la Valle and Del Dios Highway as means of mitigating signif- icant adverse traffic impact on local roads and regional roads. C=R/Y C..nY.AMVr, G FgyC Y County of San Diego September 4, 1980 Page 9 S. Identify significant long-term, cumulative adverse traffic effects of the Proposed Project. 6. as a means tif Mitigating significantnadverserridor trafficreservaeffectsion short-term,of long-term, and cumulative effects. Respectfully submitted, GRAY, CARY, AMES & FRYE By: 6-e4' Iq.01 ELLEN B. SPELLMAN Attorneys for Rancho Santa Fe Association EBS:dd cc: County of San Diego Dept. of Planning and Land Use Environmental Policy Section 1600 Pacific Highway San Diego, CA 92101 a �,