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HomeMy WebLinkAboutEIR 93-02; Green Valley; Environmental Impact Report (EIR) (35)- State of California Memorandum .- To: STATE CLEARINGHOUSE M. GOSS From: DEPARTMENT OF TRANSPORTATION District 11 Planning Business, Transportation and Housing Agency Date: November 4, 1993 File: 1 1 -SD-005 42.7144.0 Subject: DElR for the Green Valley MP and MTM-SCH 93041014 . rp Caltrans District 11 comments are as follows: Circulation impacts at Interstate 5 (1-5) interchanges and mainlane segments should be addressed. The Leucadia Boulevard and La Costa Avenue interchanges are of particular interest to our agency. A phasing plan should be developed to insure that proposed interchange and local street improvements are completed prior to development generated traffic creating or intensifying capacity problems on 1-5 or at the existing interchanges. This phasing plan should include coordination with the planned locally funded interchange projects along 1-5. Caltrans supports the concept of "fair share contributions" on part of the developers toward present and future mitigation within the 1-5 corridor. Our contact person for 1-5 in the vicinity of the subject project is Roger Carlin, Project Engineer, Project Development Branch N-3, (61 9) 688- BD/MO:vc BILL DILLON, Chief Planning Studies Branch - IC- November 3,1993 The Los Encinitos Heritage Conservancy (LEHC) appreciates the chance to comment on the Draft EIR for the Carlsbad Partners property. LEHC is concerned with the protection and enhancement of significant natural, agricultural, and cultural resources in the south Carlsbad and Encinitas areas. r LEHC also supports planning which encourages pedestrian and alternative transportation 4- opportunities. The Conservancy believes that people should have an opportunity to enjoy n& % *r\ -6 'r; %\ 4? (2 .I surrounding within their communities. 8 MOV 1 \\% % I Comments to DEIR Traffic & Air Quality (Cumulative Impacts) 5 The Draft EIR (DEIR) indicates that Ecke Ranch and possibly Home Depot traffic proj*Lzoz& were not used since they were not approved at the time the Draft EIR was done, and/or these tw%--- projects are not in compliance with the Encinitas General Plan. This appears to be a serious deficiency. Traffic analysis which incorporates the expected traffic generated from these two projects should be reviewed. The cumulative effect of these projects with the current proposed project will likely cause significant impacts. Traffic generation figures for each major project approved or planned in the Carlsbad and Encinitas areas should be quantified in the EIR (for example, the Home Depot project is expected to generate about 8,000 ADT, and the Ecke Ranch is expected to generate roughly 55,000 to 65,000 depending on the frnal design selected). The DEIR mentioned numerous projects that are approved or proposed in the area, but traffic figures for each were not described. Furthermore, it was unclear which projects were approved and which required amendments to City policies. This should be clearly stated for each project and the traffic assumptions for each project noted. Traffic projections which reflect proposed land uses should be used to calculate cumulative impacts in the area, even if those projects are not yet approved or require amendments to City policies. Some of these projects include, but are not limited to: Home Depot, Shelley, Rice, Rancho Verde, Ecke Ranch, Lego-land, Costco and other developments that could add substantially to the overall traffic in the area. Traffic The DEIR seemed to indicate that Community Commercial development generate more traffic than a regional center per 1000 sq. ft. Please clarifl this assumption. If a large retailer, such as KEA, comes into this site, the customer draw will be a radius of up to one hours drive. How does this affect the total traffic assumed for this site? Some could argue that a regional center will allow close shopping access for those living in south Carlsbad and Encinitas and would reduce air pollution and traffic since people would not need to drive long distances to a regional center. However, it could also be argued that people in south Carlsbad and Encinitas shop Sequently at the regional centers located in north Carlsbad, Clairmont, or Escondido. In other words, if a regional center is close by, will people tend to shop more frequently, and for fewer items each trip, then they would if they had to drive a longer distance. If so, then this type of shopping behavior would likely add to the traffic and air pollution. Cars pollute the most when they are driven for short distances when the engine is cold. Over the course of a year, frequent short trips, vs. a few long trips would likely create more traffic and air pollution. Furthermore, a regional center draws people fiom outside the local area. Therefore, we suffer the traffic and air impacts fiom cars that normally would not be in this area. Any studies which reflect customer shopping patterns as they relate to traffic and air quality impacts of community commercial vs. regional retail centers should be reviewed by the EIR. r - -. *--. Traffic Access Alternatives connection to Leucadia Blvd. (except for year 2010). The EIR should include an analysis for the year 1996, or the year in which this road is expected to be completed. If this alternative is selected, how will access be provided prior to the completion of Leucadia Blvd.? on p. 37 of the appendix (Traffic element) would allow for acceptable intersection conditions with no creek crossings if geometrics 4B on Table 14 are implemented. With a single creek crossing, it appears that impacts would also be similar. Please clarify if this is true. Biologically preferable alternatives should be given priority, especially in light of the fact that negative impacts appear to be only short term impacts. needs to review alternatives which would have two access points to Leucadia Blvd. and no creek crossings and no crossing to La Costa Ave. Would the proximity of these Leucadia Blvd. access points to the Olivenhain Rd. / El Camino Real intersection prohibit this possibility? What geometric configurations would allow this scenario to work properly? If this alternative is infeasible, then a single crossing of Encinitas Creek at Calle Barcelona, along with access to Leucadia Blvd. is preferable to the proposed plan which calls for two road crossings of the Encinitas Creek. The LEHC does not support the extension of street "A" to La Costa Ave if this would impact wetlands close to the lagoon. In addition, it appears that the La Costa connection would impede wildlife movement between the creek and the upland habitats. Please clarify the impacts to wetlands and wildlife movement with road "A" connecting to La Costa Ave. Any bridge crossings of the creek should conform to the Otay Ranch standards for height and width as recommended in the DEIR. If there is only one crossing, the added cost should not be prohibitive. In the event that two road crossings are approved, then the larger bridge span will be all the more critical to maintain some wildlife movement under the roads. alternatives. The deletion of the Levante crossing will protect 0.4 acres of coastal salt marsh habitat. If Levante street crossing is approved, then creation of coastal salt marsh at a minimum of a 2 to 1 ratio should be required as recommended in the DEIR. The DEIR is unclear regarding the location of the restoration of 1.2 acres of coastal salt marsh (page 5-3). The widening of La Costa Ave. should also include a bridge structure to allow movement between the creek and the lagoon. This bridge should follow the Otay Ranch Standards. The traffic analysis did not appear to include an analysis of a single creek crossing and a /c It appears that improvements to Olivenhain Rd. and El Camino Real intersection, as recommended The LEHC supports alternatives which reduce or eliminate impacts to sensitive habitats. The EIR r Alternatives which do not impede the coastal salt marsh should be supported over other Leucadia Blvd. Leucadia Blvd. will likely be the main access for any new commercial center in the Green Valley. The DEIR did not reveal the short term and long term traffic impacts on this roadway. Project related impacts, as well as cumulative impacts, should be reviewed for Leucadia Blvd. This is particularly important in light of the fact that the Ecke Ranch may have a Retail Commercial Center. Customers will need to cross Leucadia Blvd. to get between the two portions of the shopping center. Alternatives which cluster the Regional Shopping Center in one area (e.g. no major road crossing required) should be reviewed. The LEHC Proposal includes this type of design. SA 680 through on the Leucadia Blvd. alignment, rather it was assumed to be realigned to the north. The DEIR noted the uncertainty of this assumption. An analysis of this possibility should be reviewed, especially in light of the fact that if all the Warehouse projects proposed for Green Valley are approved, Leucadia Blvd. and Olivenhain Rd. will suffer significant traffic impacts and a 680 type The DEIR also noted traffic analysis was based on the assumption that SA 680 would not to be put 2 road may be required. Traffic and Current Zoning vs. Proposed Zoning The DEIR indicates that the proposed project will generate 33,400 ADT vs. 27,200 ADT for the current zoning. However, traffic projections of the currently zoned land uses were unclear. The table on page 4.9-6 lists current General Plan land uses as including a Regional Retail Center. The DEIR stated that current land uses allowed Community Commercial (not Regional Retail). The EIR needs to clarify this. Traffic and air quality impacts of the current zoning vs. the proposed zoning should be recalculated to reflect any corrections. The DEIR indicates the change to regional retail is not in conformance with the current General Plan zoning of Community Commercial. Will the expanded range of customer draw create more traffic and air pollution impacts than the current community commercial zoning? Assumptions used to draw conclusions should be explained fully in the final EIR. Commercial. r Table 5 in the appendix for Traffic needs to list daily traffic assumptions for Community General Plan Issues The LEHC supports the designation of lands between El Camino Real and the riparian corridor as open space according to the recommendations of the COSCRMP. The southwest corner of La Costa Ave. and El Camino Real is an important visual resource. Development of the site as commercial would reduce the aesthetic qualities of the site. In addition, car access to the site will not be in conformance with City Street Design standards which require a minimum distance between driveways and major intersections. Since the proposal also does not comply with setback requirements for parking and buildings adjacent to El Camino Real, and the proposed neighborhood commercial does not conform to General Plan. policies that encourage neighborhood commercial sites to serve a local residential neighborhood primarily via foot traffic, the LEHC feels that the use of this site for convenience commercial is inappropriate. COSCRMP has, as a second priority, the use of the red barn site as a trail staging area. An alternative which designates this site as a trail headlnature visitor center should be reviewed. Although similar access problems would exist, hours of operation would likely be far less than a convenience commercial store. In addition, visitors would generally come on weekends (e.g. not peak hour commute times). F Aesthetics The LEHC encourages the preservation of significant open spaces within the Batiquitos Lagoon viewshed. The north Green Valley is one of the most significant viewsheds near the lagoon. Development of this site for a Regional Retail Center and Multi-Family homes will permanently alter the character of this site. The creek vegetation will provide some visual protection; however, the site will lose its semi-rural qualities. The LEHC asks that the EIR review alternatives which would greatly reduce the amount of development proposed for this site (including, but not limited to, the LEHC Proposal). Re- establishment of several habitat connections between the bluffs and the creek would add significantly to the value of the upland and wetland habitats. Alternatives which incorporate these connections should be reviewed. The Batiquitos Lagoon, the Encinitas Creek, and the uplands of Green Valley are all rated "Very High" on the MHCP Habitat Evaluation Model Maps. As such, this area could be selected as a core area for preservation. Wildlife agencies should be consulted as to the probability of this occurring. Funds to purchase and revegetate otherwise developable sites may be available in the near future (CALPAW, etc.). F 3 c -. Biology consulted to determine the reason for their reappearance. Has the termination of the agricultural operations had any effect? If agricultural operations are resumed, what amount of buffering would prevent disruption of sensitive species? It is interesting that Least Bell's Vireo have been sited recently in the creek. Biologists should be ,- Biological Impacts As noted in the DEIR, spring surveys need to be completed in order to be able to adequately determine impacts and mitigation measures. The survey should note the date and time of day and which species were observed. A sensitive species map, with locations noted, should be included, When the surveys are completed, the LEHC will then be able to make comments on the adequacy of the mitigation proposed for the Diegan sage scrub impacts and the impacts to the bluff habitat due to adjacent development. This upland habitat is known to contain numerous rare and endangered species, some of which occur only in the immediate area. Although the proposal will disrupt only a small portion of Diegan Sage Scrub, the LEHC is concerned with the disturbance to this habitat caused by highly intensive land uses. The DEIR was unclear regarding the buffer setback from the bluffs. Please clarify this. Noise area by the year 2010 with or without the project. The EIR needs to clarify whether or not this assumption is based upon the site being developed according to the current General Plan. policies. If the site were left undeveloped, would this noise impact still exist in the year 2010? Furthermore, was this analysis based upon projects such as Encinitas Ranch being developed as proposed? Also, the EIR notes that certain road segments will experience noticeable increase in noise levels. These roadway segments should be called out. Noise contours due to El Camino Real and the proposed development should be mapped to facilitate an understanding of the impacts (both existing and cumulative). The EIR should note what are the noise sensitivity levels for sensitive species. Is the width of the corridor sufficient for the long term? The widening of El Camino Real could include earth berms which direct noise up and away from the creek area which is below the roadway. Any encroachments into the wetlands from the construction of a berm should be minimized or eliminated where possible. Any lost wetland should be replaced at appropriate ratios. Long term benefits and impacts of such a berm should be reviewed by the EIR. The DEIR notes that noise levels are expected to be over 60 CNEL for over 95% of the riparian Corridor Width The DEIR notes that the riparian corridor is planned to have a width of 400-600'. Dudek & Associates recently submitted a paper to the City of Encinitas which noted that corridors need to be 500' to 1OOO' in width. For flatter topography, a wider corridor is desirable if sensitive species are expected to utilize the corridor. habitats caused by close proximity to major roadways, human use areas, or urban zones. The impacted area can range from 100' to 300' depending on the type of adjacent land use (e.g. low density residential vs. airport, etc.) Currently, the Encinitas Creek is impacted by edge effects only on the east side (El Camino Real). The agricultural land offers quiet buffering on the west, even though there is little habitat value associated with the fallow agricultural land. However, with the conversion of this agricultural land to highly intensive urban uses, is the 400-600' width adequate to ensure the continued presence of sensitive species such as the Least Bell's Vireo? The EIR should provide evidence that such a narrow 4 Also noted in MHCP studies is the problem of edge effects. Edge effects are impacts to sensitive - corridor is adequate for sensitive species. Are there other sites that have highly urban land uses located next to a 400-600' wide riparian corridor where sensitive species have continued to use the habitat? Buffers The LEHC is concerned that the buffers may not offer long term protection of sensitive resources. The DEIR recommends the planting of cacti. This may be effective in the upland areas; however, this may not be effective adjacent to the creek due to excess water. The EIR needs to review alternatives which offer better protection of the wetland areas. This is particularly important since a public trail system is planned in the buffer zone along the creek. The COSCRMP lists, as a second priority, the expansion of open spaces as a buffer along the riparian corridor. Designs which provide a buffer greater than 50' should be reviewed. r Location of Multi-Family units The Land Use element policies set guidelines to limit higher density residential developments to those areas where they are compatible with adjacent land uses. The LEHC questions the appropriateness of Multi-Family dwellings so close to highly sensitive habitats. Children and adults will likely find ways to utilize the natural habitats for recreational purposes. Domestic plants and animals also pose major problems to native species. Long term monitoring of buffers is usually not practical. Once the residential areas is built, it is unlikely that the City will be notified about people using the natural areas for hiking or other recreation. Alternative designs which allow a better siting of the multi-family development should be reviewed. If the location is not changed, then the multi-family residential development should be designed to impede human intrusion into the natural areas. In addition, appropriate fees should be required in order to provide funding to pay for long term monitoring of the natural areas Exotic Animal Species Domestic animals pose a major threat to native species. Due to the close proximity of the developments to sensitive native habitats, the multi-family residential area should be covered by restrictions to prohibit cats. Dogs should be required to be kept on leashes. Exotic Plant Species should be limited to non-invasive species. The EIR should present a list of plants that would be prohibited. The LEHC is concerned that exotic plant species could impact native habitat. Landscape plants citing The LEHC is concerned that sensitive species which utilize the riparian and upland habitats will be negatively affected by increased night lighting. The EIR should review information on the sensitively of certain species to night lighting. Is there any evidence to suggest that the mitigation offered (low intensity lighting, shielding, etc.) is sufficient mitigation for sensitive species (Least Bell's Vireo, etc.). Geological The DEIR noted that ground water studies in 1985 showed water elevations at depths of 38' and 65'. Groundwater elevations at the corner of northeast corner of La Costa and El Camino Real were recently found to be 6' below ground level. The LEHC is concerned that the high ground water table may be subject to pollution impacts from the proposed development. Testing of ground water, at several locations on the site should be done in order to determine a base line for pollutants. Water ,- 5 quality at each test point should be tested separately, particularly if the water table is not continuous. Furthermore, several locations should be tested for ground water elevation. Water elevations taken in the spring and summer would provide useful information on the possibility of ground water contamination from the proposed development. The 1985 surveys may have been done in the dry season. The DEIR did not say whether 1985 was a drought year. This should be clarified. The EIR needs to provide objective data on the current ground water elevations and its quality. When this data is available, new opportunities and constraints may become apparent. At this time, there is not sufficient data to comment. revegetation or agriculture. /c If the water quality is found to be fair to good, this may open opportunities for its use in Hydrology The DEIR notes that the 100' year floodplain will be lowered by .5' in certain areas along the creek and raised in other areas (at least until Detention Basin 'IC" is built). The EIR needs to note whether the change in flood elevations and water movement on the site will result in an overall decrease or increase in wetlands habitat. A detention basin may allow for some ground water recharging, but it can also reduce the overall acreage of shallow water wetlands. The LEHC supports alternatives which do not reduce the overall acreage of wetlands. If it is found that there will be an overall decrease in wetland acreage, then appropriate mitigation should be required. Are these water tables created by seepage from above (e.g. rain seeping through the soil). Or is the water from a source outside the disturbed agricultural area? The EIR needs to analyze how these water tables affect the creek and lagoon wetlands. Does this water seep into the creek or lagoon? If so, how much water does this contribute to the wetland systems (both in the wet Season and the dry season). The DEIR notes that 30% of the site will be covered with impermeable surfaces. How will this affect these water tables and the wetlands that may depend upon them. The DEIR notes that there are several ground water tables on the site, some of these are perched. r' Soil Toxicity should include this information along with mitigation recommendations. The LEHC is concerned that failure to do these tests could result in greater impacts to the wetlands. For example, much of the fill dirt is proposed to be used as fill dirt near the floodplains and wetlands. If this soil has toxicity problems it would be inappropriate to use this as fill near wetland and floodplain areas. The DEIR noted that much of the soil in the development area is compressible. Various mitigation options were briefly discussed. One option might be removal of compressible soils. If this soil is toxic, how would this affect relocation of the compressible soils? Soil toxicity tests should be done on the agricultural portions of the property. The Final EIR Cultural Resources GV-4 is the only known archeological site in the Batiquitos area that reflects late Pre-historic occupation (Kumeyaay). All other known sites are from the La Jollan complex. Mitigation offered is excavation prior to grading over 10-20%. The DEIR suggested that a higher percentage would be desirable. LEHC would support a more thorough study of this site due to its apparent significance. Grading The LEHC encourages protection of natural landforms. The current proposal calls for cripwalls and manufactured slopes that exceed 30' in height. The Hillside Development and Design Standards limit cut or fill slopes to 30'. Alternative designs which conform to these city policies cripwalls should be reviewed in the EIR. r 6 MHCP As per the Fish and Game letter (April 20, 1993), the EIR needs to review the current regional conservation programs that are relevant to the project. This includes the effect that the project may have on the completion and implementation of such efforts. For example, the south Carlsbadi north Encinitas area is a hub of rare and endangered species. The probability that this might be selected as a core area for preservation should be reviewed. The MHCP mapped agricultural land and other disturbed, but vacant, lands, in part, because these lands provide opportunities to reconnect habitats into larger units (e.g. revegetate disturbed portions to provide connections between existing habitats). - Agriculture Agricultural open space does provide a quiet buffer to natural habitats. In addition, agricultural land can be converted to natural habitat at a fbture date. Furthermore, agricultural land within urban boundaries allows food to be shipped to local markets with minimal traffic and air pollution impacts. People do not shop at Regional stores everyday. However, people do eat everyday. The benefits of protecting agricultural land on this site should be thoroughly reviewed in the EIR. notes that the majority of pollution found in the nation's surface water bodies is a result of runoff from urban areas (non point sources). Proper agricultural practices can minimize impacts on wetlands and other native habitats. Improved farming techniques include minimal or no disking which reduces erosion impacts. Marsh systems can provide filtering of unwanted nutrients. The possibility for recreating marshes along the western side of the creek should be reviewed. This would also provide a buffer to human encroachment into the creek. (This may be an option even if agricultural land is not preserved on this site.) The Department of Conservation letter (May 10, 1993) requested that the DEIR contain information on the potential agricultural value of the site, the impacts of farmland conversion, and possible mitigation actions. They also asked that information include types and relative yields of crops, the impacts on current and fbture agricultural operations and the cumulative and growth inducing impacts of the plan, etc. The Department of Conservation also requested that mitigation measures and alternatives to lessen farmland conversion be reviewed. Some mechanisms to be reviewed include clustering of development to allow more agricultural protection, buffers to separate farmland from urban uses, and utilizing planning tools such as transfer of development right, conservation easements, farmland trusts, etc. The Department of Food and Agriculture also requested information on crop history and yields. Furthermore, impacts to adjacent agricultural preserves was to be analyzed. This information needs to be reviewed in the EIR. The DER simply indicates that the Ecke Ranch is planned for a regional commercial center. However, this may or may not be approved. Alternatives which protect agricultural lands should be reviewed (including the LEHC Proposal). The DEIR appears to be deficient in its analysis of the agricultural value of this site. The DEIR indicates that the site is not prime agricultural land. However, there is no information on the possibility of continued agricultural use of the site. The Carlsbad Partners property has been fallow for several years; however, the Ecke Ranch to the south is currently being farmed. If soil types are similar on these two properties, then this would provide information on the potential economic viability of the Carlsbad Partners property. agricultural uses questionable. However, the land to the south (Ecke Ranch) has not yet been approved for development. The Ecke Ranch is currently in the Williamson Act protection. The portion of the Ecke Ranch, south of the project site, is being farmed successfblly with a variety of vegetable crops. About 1/3rd of these crops are organically farmed. In addition, the farmer is growing gourmet produce which he sells to local markets as well as to markets around the country. The LEHC is concerned with the conversion of open space near the lagoon to urban uses. Although agricultural practices can create problems for wetlands such as nutrient loading, the DER /" Page 5-2 states that continued urban pressures make the economical viability of the site for r 7 c -. If the remainder of Green Valley is developed, will this farmer be able to find equally suitable land elsewhere in the County? Local markets which are currently supplied by this farmer will have to import produce from a longer distance. The EIR needs to quanti@ these impacts. The EIR needs to review whether farm protections on the Ecke Ranch could be transferred to the Carlsbad Partners site? What benefits would this have for offsetting the cost of protecting the site as open space? Would this provide superior long term protection for sensitive habitats in the Green Valley? As indicated above, the EIR needs to review current information related to the productivity of the land being farmed to the south (yield and profits) and how this applies to the Carlsbad Partners site. The farmer is using well water which appears to be of good quality. The DEIR does not present objective data regarding the sterile nature of the soils or the quality of the water. It is very possible that poor agricultural practices were responsible for problems that occurred in the past (nematodes and mildew). Even contour farming was not employed despite the obvious erosion problems. Better farming methods could render this site very suitable to agriculture. Many farms do minimal disking; thus reducing erosion problems and allowing the soil to develop structure and soil horizons. The DER assumes no significant impact to agriculture. However, this is not supported by any objective evidence; in fact, the farming just due south would suggest otherwise. A recent article in the L.A. times indicated that coastal California is the third most threatened agricultural area in the country. Most of this loss is due to land planning policies which do not protect agricultural lands within the urban boundary. Alternatives which protect agricultural land on this site need to be hlly and objectively examined for impacts and benefits. r Open Space The EIR needs to clarrfy if the Carlsbad General Plan determine densities based on gross acreage or net acreage (after environmentally constrained areas are removed, such floodplains, wetlands, slopes, etc.). Are required buffers or easements included in density calculations? (see p.4.1-4) Page 4.1-10 notes that the LFMP allowed 486 residential units. Are there other policies that suggest a lower number is more appropriate? The DEIR noted that the Carlsbad Planned Community Zone requires 15% of the entire Master Plan be set aside for open space. This would mean 42 acres of open space would be required. The DEIR indicated that the 194 acres of natural open space in the proposal satisfies this requirement. However, it is unclear if natural open space can be used to satisfjr this 15% requirement. Please clarifjr. constrained areas) must be set aside for open space uses and must be available concurrent with development. Is this a separate policy from the Planned Community requirement? What is the environmentally constrained acreage in Zone 23? Is there table that indicates environmentally constrained land in Zone 23 on a parcel by parcel basis? Is any of this environmentally constrained land being used as part of the 15% open space requirement? It is unclear from page 4.12-5 if the 18.8 acres of open space is part of the proposed project, or is it proposed open space for Zone 23? Is all this acreage "non-environmentally constrained" open space? Page 4.12-3 indicates that if planned park facilities for Zone 23 are hnded and implemented then the overall park requirements for Zone 23 will be met. Is the fkding available or likely to become available at buildout? - Page 4.12-5 indicates that 15% of the total land area within the Zone (exclusive of environmentally Facilities proposed development. Please clarifjr. It is unclear if the fees paid to schools and sewage facilities is sufficient to offset the impacts from the r 8 /1 -? Cumulative Impacts The DEIR notes that air pollution impacts cannot be mitigated. It also notes that Carlsbad has over 50 policies designed to reduce vehicle travel and air pollution. The LEHC encourages a review of alternatives which would reduce the overall amount of development, traffic and air pollution impacts in the Green Valley. Current development proposals (if approved) would transform this large undeveloped valley into a Major Regional Retail Center which would be larger than Plaza Camino Real. Cumulative effects of current proposed projects need to be analyzed in detail, with sources sited. 7 Alternatives Other alternative locations for a Regional Center (other than the Robertson Ranch) need to be analyzed. The City of Encinitas submitted a letter (April 8, 1993) reflecting four areas of concern: 1. Economic viability of two major commercial centers in the Green Valley. 2. Impacts on the riparian habitat. 3. Traffic impacts on Encinitas and the financial burden associated with it. 4. Impacts on bluff habitats due to proposed adjacent land uses. LEHC agrees that more alternatives need to be reviewed for land uses in the Carlsbad Partners property, including the no project alternative. From a biological, traffic access, and infrastructure standpoint, a major Regional Retail center appears to be more appropriate on the Ecke Ranch. Even visibility is superior. The LEHC encourages the two cities to work together to create a superior project for residents and businesses in the south Carlsbad and north Encinitas areas. Since both cities are members of the MHCP, cooperation between jurisdictions which allow for biologically superior alternatives is consistent with the goals of the MHCP. r Robertson Ranch Alternative It appears that the Robertson Ranch is similar to Green Valley in many respects. Alternative sites that have substantially fewer environmental constraints should be reviewed. However, it appears that this alternative is superior from an environmental standpoint. The EIR should clarify the distribution of Coastal Sage Scrub (CSS) and the impacts associated with a Regional Retail center on this site. What is the largest patch size of CSS? The DEIR noted that 300 acres would be set aside for open space if the Robertson Ranch were developed as Regional Retail. This appears to be a significant benefit since this is more open space then is proposed in the Carlsbad Partners plan. This benefit needs to be fully examined. alternative. The alternative land uses examined for Carlsbad Partners would have to be balanced against the impacts and benefits of having the Regional Center located on the Robertson Ranch. There is not enough information on the Robertson Ranch to say whether LEHC would support this LEHC Proposal Alternative proposals in Green Valley. (see enclosed material). Taxes could be divided in an equitable fashion between the two cities. A variety of implementation tools are suggested. These could provide adequate compensation to the land owners. LEHC asks that the LEHC Proposal be reviewed as an alternative to current development c Growth Inducing The growth inducing aspects of a Regional Center in the north Green Valley need to be reviewed in more detail. A major Regional Retail center could create pressure to develop associated commercial centers nearby. This might lead to more intense use of existing commercial centers (as 9 part of a redevelopment project). This is the last large undeveloped coastal property Jwith significant upland vegetation) in north county (other than Camp Pendleton). Is a Regional Retail center the best long term use of this property? Coastal north county will need large areas of parkland if this area is to maintain a high quality of life. Preservation of large areas of Green Valley, as open space, should be examined for the long term benefits. F Suggested Survey & Meeting LEHC suggests that surveys of local citizens be conducted to determine support for the current proposal vs. alternatives (including opinions on all developments proposed for the Green Valley). LEHC requests that a meeting be held between Representatives of the City of Carlsbad and Encinitas, and representatives of the County, Wildlife agencies, the MHCP (including a conservation group like Endangered Habitats League), and concerned citizen groups. LEHC would ask that our proposal be reviewed at this meeting. Thank you for this opportunity to comment. Please notify us regarding meetings relevant to this project. Sincerely, Los Encinitos Heritage Conservancy 126 Village Run West Encinitas, CA 92024 ,r Ph: (619) 944-7247 fax: (619) 632-6693 10 Los Encinitos Heritage Conservancy Draft Alternative Development Plan (See Maps 1,2,3,4) Proiect Description The following is a brief explanation of the components of the Los Encinitos Heritage Conservancy (LEHC) Draft Alternative Development Plan for the Encinitas Ranch, Carlsbad Partners, Home Depot and some adjacent properties. The purpose of the LEHC Plan to provide citizens and agencies an alternative vision of the potential to preserve critical biological, aesthetic, and agricultural resources on over 1000 acres of coastal and near coastal properties in the City of Encinitas. The LEHC plan does not prohibit development. Rather, it incorporates most of the development types currently being proposed by the land owners. The LEHC plan strives to protect large continuous areas of open space by transferring development to the least sensitive lands and placing open space uses on and near the most environmentally sensitive lands. r A city wide trails system is a major focus of the LEHC plans. The LEHC feels that people need opportunities to enjoy nature within their own community. This creates an appreciation of nature and provides a setting conducive to positive social interaction. This, in turn, leads to friendlier communities were citizens take pride in their city. The LEHC has followed the progress of several City and County committees including: 1) The Multiple Habitat Conservation Program (MHCP) 2) The City of Encinitas Economic Development Committee 3) The Leucadia Blvd. Task Force 4) The Encinitas (Ecke) Ranch Task Force 5) The County Regional Open Space Committee The LEHC proposals are based on information obtained fiom these committees as well as fiom residents and business people in Encinitas and south Carlsbad. The Department of Fish and Game has asked that the LEHC alternatives be reviewed as part of the Environmental Impact Report (Em) for the Encinitas (Ecke) Ranch. r- Los Encinitos Heritage Conservancy Draft Alternative Development Plan Greenway (Trails System) The Greenwayflrails system shown on Map # 3 shows an extensive trails network that connects to each major neighborhood area. This trails system provides recreational and alternative transportation opportunities since the trails connect to major shopping, recreation, and community centers. Due to the scale of this map, we were unable to show the trails connections that would extend east (along Encinitas Creek) towards southeast Carlsbad and eastern Encinitas (Olivenhain). The trails system is planned to connect with the proposed Escondido CreeWSan Elijo Lagoon Trails. Both of these trails systems are proposed to tie in with the San Dieguito River Park trails system that will run along Escondido Creek. The San Dieguito River Park is proposed to link Julian Mountain (east of Escondido) to Del Mar (near the Del Mar Racetrack). As a result, the LEHC trails proposal would provide regional trails connections. (See TDC Information Sheet, CAL.PA W '94 Bondfinding, that could aid in implementation of the regional trails system discussed above.) Critical Greenwaymrail Connections The following lists the areas that must be acquired. The success of the LEHC trails system is dependent upon certain key trails links being implemented. f- Indian Head Canyon (# 12 on Map # 2) This area is a critical site due to the fact that this property is a hub for the residential area of Leucadia (north of Leucadia Blvd.) In addition, the property is bordered on the north by Saxony Canyon (an area that already has open space protection for the steep slopes), and on the east by sensitive habitat, including the Magdalena Ecke Nature Park. These two areas provide trail and habitat connection opportunities to Batiquitos Lagoon and to the bluffs that lie west of El Camino Real. A series of feeder (spoke like) trails can provide trail access to neighborhoods in Leucadia. This will likely increase the value of existing and proposed homes. Quail Botanical Gardens & Cottonwood Creek Trails (# 20,22, & 24 on Map # 2) This trails connection is vital to providing connections to the YMCA Sports Park, the Downtown business district, the Railroad Transit Station and RR-ROW, and the beach. LEHC will be seeking CALTRANS funding via ISTEA grants to provide the money for this trails link. Home Depot Specific Plan Area (# 2, & 3 on Map #2) provide the crucial connection to the inland regional trails svstem. Without this link, north Encinitas and south Carlsbad will be shut off fi-om the County Regional Trails system. Home Depot should be relocated to another site (such as the Ecke Ranch), if the LEHC plan is to be successhl. In order to receive grants, it is imperative that groups like LEHC demonstrate "Regionall' planning (e.g. trails and habitat links). Otherwise, fbnding agencies are apt to deny grants. The current (approved) Home Depot will remove the only off road trails connection that would - 2 LEHC Proposed Land Uses ,- Developed Areas "Big Box" Regional & Creekside Commercial Center Festival Grounds Housing (Single Family and Clustered Multi-Family) Community Use (Churches, community meeting halls, schools, etc.) Office Space, including Biotech Research Facilities Historical & Cultural Areas Open Space Areas City wide greenway system Expanded Quail Botanical Gardens Active Parks (ball fields, etc.) Agricultural Land Natural Open Space (upland and riparian) Target Style Golf Course LEHC Proiect Components 1) Arroyo La Costa Project No changes proposed 2) Greenway System & Biological Preserve *(Critical Regional Trails Link) (This is the proposed Home Depot Site) 0 Potential use for passive parkland and possible use for a soccer field in the flood plain. 0 Wetland restoration to restore original wetland acreage. 3) Greenway System & Biological Reserve Restoration of bluff vegetation (Southern Maritime Chaparral) in damaged areas due to illegal 0 Long term management will need to address illegal encampments. encampments. 4) Creekside Commercial Center /c 0 This portion of the Encinitas Creek (South Fork) is currently in a culvert; there is little or no habitat value. The LEHC plan calls for restoring the creek to an urban creek setting similar to what was done in San Luis Obispo. This creek used to be in an underground culvert. Citizens lobbied to have the creek day-lighted and landscaped with plants, boardwalks, trails, etc. (See Exhibit "A',). 0 As with San Luis Obispo Creek, the south fork of the Encinitas Creek is proposed to be revegetated to a more natural state. In addition, pedestrian and biking trails, boardwalks, and overlook decks would be incorporated into the creekside shopping area. This setting would allow people to enjoy the creek environment while shopping and dining. social interaction and community events such as dances, street festivals, and musical entertainment. The Creekside Shopping area would be integrated into the Big Box Shopping area. Housing or Office The second or third stories (over the shops) could be used for housing or office space. Design: 0 The Creekside Shopping area would likely be designed in a Mediterranean architectural theme. 0 This environment would be a unique attraction in the City of Encinitas. It would encourage 5) "Big Box" Regional Shopping Center 0 This area would provide 60 to 70 acres of mass merchandise stores such as Toys R Us, Ross Dress for Less, Mervyns, KEA, etc. The slope of the land would allow the stores adjacent to Leucadia Blvd. to be recessed below the level of the road. This would reduce the apparent height and mass of these stores. However, the stores would still be visible from El Camino Real (ECR) since (ECR) is lower than the shopping center. r Parking: There is potential for a two or three level parking structure in this area. Due to the slope, this parking structure could be designed such that it would not appear to be a parking structure. Structured parking would allow for an increased amount of commercial stores; this might help in terms of providing increased Transfer of Development Right opportunities from more sensitive properties in the planning area (e.g. Home Depot and Carlsbad Partners Properties). Design: The Big Box stores would follow the Mediterranean architectural theme of the Creekside Shopping area. The Big Box stores would be designed with open roof trellises that could be planted with flowering vines such as Bougainvillea. In addition, the trellises would be designed to create a varied roof line that would diminish the apparent mass of the individual Big Box stores. 6) Community Park (East Entry Park) 0 The Community Park would provide a welcome vista from the East Entrance of the City At least one baseball diamond and two all purpose playing fields would be included. There may (Olivenhain Rd). be enough park area to accommodate at least one more playing field in the future. ,F 4 . 10) Existing and Proposed Residential Area - No major changes proposed. Projects not yet approved should be required to set buildings back from the bluff edge and, if necessary, limit the height of the homes. This would protect views of the bluff system as it is seen from lands near El Camino Real; thereby, creating the illusion of taller hills and more open space. 11) Saxony Canyon Area Most of the steep hillsides in this canyon are protected open space. Due to the highly sensitive habitat in this area, as well as erosion control issues, the remaining developable lands in this canyon should be preserved in natural open space as suggested by the City's Master Environmental Assessment. 12) Indian Head Canyon "(Critical Trail Hub) 0 The LEHC has not proposed plans for this area. However, the majority of the canyon should be protected in natural open space. This would allow for habitat continuity between the open space along the north portion of Saxony Road and Magdalena Ecke Nature Park and the bluffs which lie east of Indian Head Canyon. course fairways). A thorough study of sensitive species will be necessary to determine the appropriate areas for development . Limited development could occur in the north east portion of the canyon (near the proposed golf 13) Golf Course (Target Style) r 0 The LEHC plan retains the golf course as proposed by the Encinitas Ranch plan with only minor modifications (see ## 19) which would allow for a continuous and complete greenway and habitat system. 0 The LEHC plan calls for a Target Style (Scottish Links) golf course. This type of course utilizes much less sod and, instead, incorporates significant areas of native habitat. The fairways are usually divided into two to four sodded areas with native vegetation between each section of sod. Vegetation consists of native grasses, shrubs, trees, and even wetland plants. Target Style golf courses are successklly used in many low rainfall areas such as deserts. Advantages of Target Style Courses: Significant reduction in water, fertilizer, and pesticides which can significantly alter and harm Less ground water pollution due to reduced fertilizer use. Reduction in saturated soils (from irrigation). Saturated soils can create water movement along sedimentary layers. In Encinitas, water moves along sedimentary layers and eventually flows out along the ocean bluffs. This has contributed significantly to beach bluff erosion which threatens bluff top homes. Less maintenance costs since the "groomed" sod areas are smaller than in a standard golf course. Target Style courses (which incorporate native flora) provide a greater aesthetic experience than standard courses. In arid climates, extensive areas of sod look "artificial", especially if the golf course is adjacent to natural open space areas (such as on the Ecke Ranch). Target style courses, on the other hand, blend harmoniously with the native landscape and provide an attractive visual scene. native plant and animal species. 6 In addition, the diversity of flora and fauna enhances the aesthetics of outdoor recreation; the smell of flowers in bloom, the scent of leaf oils, and even the sounds of wildlife add a pleasing dimension to the golfing experience that is usually absent in a standard golf course. Golf Course Flower Theme 0 Due to the strong flora-culture history of Encinitas (once known as the flower capital of the world), the golf course could also incorporate a flower theme. Each fairway could have its own floral motif which represents a local nursery's flower or plant specialty. For example, there could be a fairway landscaped in honor of Weidner's Begonia Gardens. Species of begonia from that nursery would adorn the fairway. Since many nurseries probably specialize in plants that are showy only during a certain season, each fairway could have multiple flower themes from several nurseries. Each nursery would be represented by flower plantings that bloom at different times of the year. This would provide year round interest in the landscaped fairways. In order to cut down on maintenance, only the tee off and green areas of the fairways would be landscaped in the flower motif (unless the plants were drought tolerant and non-invasive). There are fewer plants that bloom in the winter. Most flowering plants bloom in spring, summer or late fall. As a result, it would be interesting to have the winter blooming poinsettias planted on all fairways. In the deep of winter (such as it is Encinitas), the fairways would come alive with an explosion of poinsettia colors! Each fairway could have one color variety of poinsettias dominate, with accent colors from other varieties. This could provide a major tourist attraction that could be integrated with the festival ground activities (Winter Poinsettia Festival) Poinsettia Theme Throughout r 14) Bluff System Preserve (Southern Maritime Chaparral Community) Southern Maritime Chaparral (SMC) historically occurred only from Carlsbad to La Jolla, CA. This habitat type is rated SUG1 by the State Fish and Game. This is the highest possible rating for a habitat and indicates that there are fewer than six sites or 2000 acres remaining. The only protected site of SMC is Torrey Pines State Park in La Jolla. The other two large areas of SMC are located in Del Mar and within the bluff system west of El Camino Real that extends from Batiquitos Lagoon on the north to San Elijo Lagoon on the south. A substantial portion of this bluff system is located in the Ecke Ranch and Carlsbad Partners properties. SMC habitat is far rarer than the highly publicized Coastal Sage Scrub (CSS). The latest statistics reflect the comparative rarity of these two habitat types. Acreage of CSS and SMC Habitat Original Acreage 1988 Acreage YO Change 1993 Acreage YO Chanee Total YO Chanm css 480,260 135,370 (-) 71.8 108,436 (-) 19.9 (-) 77.4 SMC 20,620 2,530 (-) 87.7 1,3 11 (-) 48.2 (-) 93.6 Ratios of CSS to SMC Habitat Tvne OriPinal Acreage 1988 Ratio Factor of Chanpe 1993 Ratio Factor of Cbanpe Total Factor css 23.3 53.5 2.3 82.7 1.44 3.6 SMC 1 1 1 1 1 1 - Ratio - Ratio of Chanpe /" (sources: Environmental Perils San Diego Region with abstractspom Thomas A. Oberbauer and Julie M. Vanderwier, editors Patrick L Abbott and William J. Elliott, Oct. 20, 1991, San Diego Association of Geologists, San Diego County Department of Planning and Land Use Library; and the Proposed GIs Habitat Evaluation Model for the MHCP Study Area DrajZ 4/6/93, Table 1) 7 The above statistics show that between 1988 and 1993, the rate of habitat loss for Southern Maritime Chaparral has been much greater than the rate of loss of Coast Sage Scrub, (-19.9% to -48.2%). Originally, CSS was 23.3 times more abundant than SMC; by 1988, CSS had become 53.5 times more abundant than SMC. In other words, the relative abundance of CSS compared to SMC had more than doubled by 1988. In 1993, CSS was 82.7 times more abundant, reflecting a 3.6 times increase in total change of relative abundance between CSS and SMC . Thus SMC has been experiencing a much greater rate of loss than CSS. Overall, original Coast Sage Scrub habitat has been reduced by 77.4% while Southern Maritime Chaparral has suffered a 93.6% loss! Further loss of SMC should avoided as much as possible. 0 The LEHC proposes a southern alignment for Leucadia Blvd. in order to protect the bluff as a continuous habitat (see ## 16). Furthermore, the number of trails through the bluff would be limited and existing service roads used as much as possible to avoid new disturbances to this habitat. (The road may not need to go as far south as indicated on the map.) - 15) Agricultural Preserve The LEHC plan includes about 100 acres of agricultural land on the upper mesa. This would provide the 3 5 acres necessary for the relocated poinsettia operation as well as extra agricultural land that could be leased to other growers. Poinsettias are highly sensitive to air pollution and need dark night skies (14 hours of continuous darkness in winter) in order to bloom. Therefore, it would be best if the 35 acre poinsettia growing area were set at the northern end of this agricultural area. The adjacent golf course and bluff habitat would provide the greatest buffer to pollution and light impacts from passing cars. Leucadia Blvd. would be set below grade and buffered with plantings to prevent head lights from penetrating into the poinsettia growing areas. r 16) Leucadia Blvd. (Southern Alignment) The LEHC proposes a southern alignment for Leucadia Blvd. that would go around the bluff system rather than bisecting it as the Encinitas Ranch plan currently proposes. The Department of Fish and Game has indicated to City planners that a southern alignment (similar to the LEHC plan) would be biologically preferable. The LEHC will be seeking advise from traffic engineers on the southern alignment and its affect on traffic flow. While it may not be necessary to curve the road as far south as is currently shown, it is important to make sure that any damage to SMC (via the southern alignment) is no greater than what would occur with the direct route proposed in the Encinitas Ranch plan. An alignment hrther north would allow more land south of Leucadia Blvd. (on the south upper mesa) to be used for development. 8 17) Mixed Use (Housing, Office, Light Commercial, or Community Use) 7 0 Provided that development is sensitive to the existing single family homes located to the south of area # 17, any mix of housing, office, light commercial, or community use would be appropriate for this area. access should not require additional stop lights on Leucadia Blvd. (other than those shown on the map). Access should be off of Quail Gardens Drive or Via Cantebria. 0 Land adjacent to existing residential areas should be used for single family housing or community use. Clustered housing could be located further north to provide a transition to any office or light commercial areas along Leucadia Blvd. 0 Although area # 17 is considered very good agricultural land, development of this area would provide a recipient site for Transfer of Development Credits from the Carlsbad Partners property (# 8 & 9) and from the residential portion of the Home Depot site (# 3). This would make protection of areas #3, 8 and 9 more economically feasible. 0 Office, light commercial and community use sites could be located along Leucadia Blvd. but 18) Agriculture, Office, or Low Density Housing 0 This area is within an important viewshed of Quail Botanical Gardens, development should be limited. Architecture which compliments the rural setting should be required. This would be an ideal location for a community supported agriculture area or a community garden. If this is not financially feasible, other alternatives could be very low density housing or low density office space. (Any office use should relate to Quail Botanical Gardens, such as Biotech Research and Development office space.) 19) Golf Course This area slopes to the west and is the eastern side of a small north-south valley that extends up to 0 LEHC modified the Encinitas Ranch golf course layout by shifting two fairways (that were Leucadia Blvd. It is an important viewshed area of Quail Botanical Gardens. located south of the driving ranch) to this location (# 19). This provides a buffer around the existing low density residential area to the north. In addition, it provides excellent viewshed protection for Quail Botanical Gardens. 0 The Target Style golf course (with its native plantings) would provide excellent habitat connections for native species that live within the Quail Botanical Gardens native preserve area. The relocated fairways would provide a setting for a trails connection for area # 17. This would help to distribute biking and pedestrian traffic on two trails in the Quail Gardens area. This would prevent congestion on the greenway connection through the existing low density residential area northeast of Quail Gardens; consequently, existing home owners will not be subject to excessive impacts from the trail system. If there were any complaints from this residential group in the future that led to closing of the trails link (# 20), then the trail along the relocated fairways could provide a backup connection for the city wide trails system. 20) Quail Gardens Creek and Greenway *(Critical Trails Link) 0 The LEHC plan proposes a Greenway along the creek system. This creek has two headwater locations, one fork at each of the two ponds that are incorporated into the proposed golf course. These forks meet and water flows south towards Quail Botanical Gardens. would provide a second habitat and trails link to Quail Botanical Gardens. r 0 The creek is currently disturbed and should be revegetated with native riparian species. This 9 21) Quail Botanical Gardens Expansion F 0 The Gardens is currently 30 acres in size and receives 120,000 visitors per year. The expansion would provide needed space for propagation areas, rare and endangered species collections, educational gardens, biotech plant research facilities, and rare and endangered species collections. It would also attract many more tourists to the area, thus stimulating the local economy. 22) Greenway *(Critical Trails Link) 0 The greenway linkage would run along the north side of an expanded Quail Botanical Gardens. It would continue west along the north side of the YMCA Sports Park and across the freeway on a pedestrian bridge to Cottonwood Creek. 23) YMCA Sports Center The greenway would provide children and adults safe walking and biking access to the Sports Park. 24) Cottonwood Creek "(Critical Trails Link) 0 Cottonwood Creek is the City's historic creek; water was used by early residents of Encinitas. Since fresh water was plentifbl at the creek, the railroad built a train station here in the early 1900's to provide a place to refill water tanks. This spurred the growth of the City. 0 Cottonwood Creek is in a heavily disturbed condition due to the use of the property as a storage site for the Sanitary district. The creek should be revegetated and protected as a historical site. Three City committees and two elections have indicated overwhelming public support for the use of this site for a Park. The City has attempted to derail the Park plan in favor of commercial development. Cottonwood Creek crosses under 101 and empties into the ocean at Moonlight Beach. The Greenway system would terminate at Moonlight Beach Park. r 25) Railroad Station (Approved Plan) 0 The Greenway would connect from the Cottonwood Creek to the Railroad ROW which, in turn, The Railroad ROW should contain trails and be landscaped. People for Trees has received grants would connect to the railroad station. to continue their tree planting project on the ROW. 10 a . r f- Current Land Use Proposals (See Maps 4,5,6,7) Encinitas (Ecke) Ranch Carlsbad Partners & Home Depot Proiects Description Three major projects are currently being planned on over 1000 acres that lie south of the Batiquitos Lagoon. Taken together, the three projects would result in about 135 acres of "Big Box" Regional Stores, 1300 multi-family units, 380 single family units, and an additional 220,000 sq. ft. of commercial in the "Mixed Use" zones. Traffic from these projects is expected to generate 115,000 (+) ADT, far more traffic than was designated in the General Plan of Encinitas. The Encinitas Ranch project would create 2.5 times the traffic allowed in the General Plan for the 850 acre Ranch, and Home Depot would create 8 times more traffic than was called for in the General Plan for that 55 acre site. The following is a brief list of the major components of each project. Encinitas (Ecke) Ranch (850 acres) (Draft EIR due in late September) Developed Areas "Big BOX'' Regional Shopping Center (67 acres) Mixed Use (Commercial, Office, Housing) Housing (Single Family and Clustered Multi-Family) Community Use (Churches, community meeting halls, schools, etc.) Active Parks (ball fields, etc.) 18 Hole Golf Course Agricultural Land Natural Open Space (bluffs and riparian) Open Space Areas Carlsbad Partners (280 acres) (Draft EIR comments due Nov. 3, 1993) Developed Areas "Big Box" Regional Shopping Center (55 acres) 400 Multi-Family Units Natural Open Space (bluffs and riparian) Open Space Areas Home Depot Specific Plan Area (55 acres) (Project Approved Sept. 8, 1993) Developed Areas Home Depot Store (10 acres) Unknown Office or Commercial (5 acres) 5 Single Family Homes on the bluffs Natural Open Space (bluffs and riparian) Open Space Areas Current Land Use Proposals . 1) Arroyo La Costa Project This project is approved. Once built, the development will sever the biological connections in this area. As a result, the Encinitas Creek corridor and some of its adjacent uplands will be the only remaining wildlife corridor connecting the Batiquitos Lagoon and habitats west of El Camino Real with inland habitats. This corridor has been narrowed by existing development east of the Home Depot site. Nevertheless, due to the loss of the Arroyo La Costa area, this corridor will become essential for movement of species between the coastal zone and inland habitats. 2) Home Depot Specific Plan Area e e e e e r e e e This 55 acre PI& Area is one of the richest biological sites in the City. The Habitat Evaluation Model for the MHCP has given this site the highest rating for habitat value. It is recognized by the MHCP, the Department of Fish and Game, and the U. S. Fish and Wildlife Service as a critical biological connection. The Home Depot Specific Plan was approved Sept. 8, 1993 despite vigorous citizen opposition. The Plan violates numerous General Plan policies related to wetlands, floodplains, steep slopes, sensitive habitat, and traffic. Due to the proposed Home Depot store, this site will suffer from "edge" effects (impacts on sensitive habitat due to adjacent development). These impacts affect an area 100 to 300 feet from the developed area. Development of the Home Depot site will mean filling in wetlands and removing significant stands of Los Encinitos, or Little Oaks (Quercus dumosa) for which our City is named. Many of these trees are 75 or more years old. A lawsuit has been filed by Neighborhoods United (a citizen group opposing the project at this location) The community Trails System planned through this site will be eliminated upon construction of the Home Depot. Because the development will encroach so deeply into the wetland area, there will be no room left for the off road trails. This is the only remaining off road trails link in the north part of Encinitas that could provide the critical trails link to the County Regional Trails System. Neighborhoods United supports moving the Home Depot across the street to the Ecke Ranch which is being proposed for a "Big Box'' Shopping Center. Home Depot would be a welcome anchor for this center. Construction is expected to begin on the Ranch in the spring of 1995. Nevertheless, Home Depot does not wish to consider this alternative. (Home Depot's attitude seems inconsistent with their standing as a Corporate Sponsor of The Nature Conservancy.) The City also does not wish to consider the Ecke Ranch alternative, primarily because Home Depot does not wish to consider it. Due to major environmental impacts, LEHC supports transferring development credits from the Home Depot site to the Ecke Ranch. F 3) Residential Portion of the Home Depot Specific Plan Area 0 The proposed 17 home development was reduced to 5 homes at the Sept. 8, City Council meeting. The Council felt that this was adequate mitigation for impacts to sensitive species such as the Gnatcatcher. seriously degrade the biological and aesthetic value of the site. e The reduction of homes is a step in the right direction; however, the Home Depot store will 12 c . - 4) Active Park (Ball Fields) 0 One baseball and two soccer fields are proposed. A trail is planned along the creek. 0 (The LEHC plan proposes to move these fields just slightly north of the location shown on this r map.) 5) Mixed Use Area (Ecke Ranch) 0 This area is proposed for multi-family and mixed commercial uses. 6) "Big Box" Regional Shopping Center (Ecke Ranch) 0 This area would provide 67 acres of mass merchandise stores such as Toys R Us, Ross Dress for Less, Mervyns, KEA, etc. 0 Access to other Big Box stores in the valley will require crossing Leucadia Blvd. and El Camino Real. This will likely create significant traffic problems. (The LEHC plan would not require crossing major roads to access all the stores.) r 7) "Big Box" Regional Shopping Center (Carlsbad Partners) 0 This area would provide 55 acres of mass merchandise stores such as Toys R Us, Ross Access will require crossing Encinitas Creek with two roads. This will severely impact very high Dress for Less, Mervyns, KEA, etc. quality riparian habitat. Least Bell's Vireo were found during the constraints study for this project. Note: 0 In reviewing development plans, the City of Carlsbad does not require the same level of design detail as the City of Encinitas. Detailed drawings of the Encinitas Ranch development proposals are available for review, but LEHC has had access only to information about the proposed zoning areas on the Carlsbad Partners property. The building & parking layout for the Carlsbad Partners property (shown on Map # 5) are for conceptual purposes only. 8) Multi-Family Residential (Carlsbad Partners) 0 400 units are proposed. The high density of housing units will likely lead to degradation of the wetland and upland areas See Note above (# 7) due to excessive pedestrian encroachment and edge effects. 9) Wetlands 0 This portion of the valley contains wetlands and disturbed upland areas. It is likely that a portion will be used for sediment detention areas. 10) Existing and Proposed Residential Area Existing and proposed housing (not part of the Encinitas Ranch proposals). 11) Single Family Homes This portion of the upper mesa is planned for housing and golf course uses. (LEHC proposes to modi@ the golf course to a Target Style course) r 13 - 9 12) Golf Course (18 Holes) 0 This golf course is planned as a standard fill turf course. This will require an exceptional amount 0 Water runoff into Magdalena Ecke Park and other natural areas to the west will likely cause 0 Fertilizer and pesticide use could seriously harm native species that occur adjacent to the golf of water. severe impacts to native vegetation since many species cannot tolerate summer water. course. (The LEHC Plan for a Target Style course would reduce these impacts.) r 13) Leucadia Blvd. Extension 0 The proposed direct alignment will require extensive grading. The road will be an 8% grade. 0 The direct alignment will bisect one of the rarest habitats in the world. Wildlife movement across 0 The Department of Fish and Game has told City planners that a southerly alignment for Leucadia this road will be difficult if not impossible. Blvd. would be preferable since this would preserve a large portion of contiguous habitat. 14) Agricultural Area 0 The Eckes hope to move their poinsettia operations from the current location (just north of Quail Botanical Gardens) to the south part of the Upper Mesa. 0 Development of the Encinitas Ranch will provide the money that the Eckes need to modernize their growing operations. If the new high tech green houses are built, then only about 35 acres will be needed for the poinsettia operations. The rest of the land could be leased. 15) Single Family Residential (3 units per acre) 7 The homes proposed for this area will be highly visible from Quail Botanical Gardens. This is the 0 Quail Gardens has already suffered view loss on its east and south sides. A new project 0 Since Quail Gardens is relatively small, it is critical that viewsheds to the north and east be last viewshed that the Garden has which provides a quite rural scene. threatens to block much of the Garden's western ocean view (Beck Project). preserved. 16) Quail Gardens Drive Extension The proposed alignment runs along a blue line creek system. If this road is located here, the riparian area will not hnction as a wildlife corridor. This blue line creek would likely be contained in a drainage channel, thus destroying its aesthetic qualities. This alignment would pull 12,000 cars per day through an extremely rural area of the City. The existing residential area which lies just northeast of Quail Botanical Gardens is very low density. The ambiance of this quiet community will be severely impacted if the road is located through the middle of it. The traffic noise would likely be a detriment to the quiet setting of the Botanical Gardens. The LEHC plan proposes that this road be shifted east to protect the blue line creek and the quiet, rural nature of this valley. 14 A -? 17) Mixed Use (Housing, Office, Light Commercial, or Community Use) 0 It is unclear what type of development will eventually be proposed for this area. The current 0 Quail Botanical Gardens is an extremely valuable resource. Loss of viewshed and increased noise 0 Quail Gardens contains native plant communities which are very sensitive to urban encroachment. FEHC proposes an expansion of the Gardens and protection of the remaining adjacent viewsheds r zoning proposal would allow a wide range of uses. and congestion will impact the ambiance of this Garden. The close proximity of Mixed Use development is inappropriate at this location. to the north and northeast.) 18) Single Family Residential This area is proposed for residential (3 units per acre), but it may also serve as an elementary (LEHC is not proposing changes to this area. However, buffers should be provided for Quail 0 The greenway connection will provide an excellent trails connection to the school. school site. Botanical Gardens and noise studies should be done.) r 19) MixedUse 0 This area is just north of the YMCA Sports Park. Possible uses proposed are office, commercial, 0 An outdoor amphitheater is one proposal being discussed for land adjacent to the fieeway. 0 Due to the western orientation of the slope and its proximity to the freeway, this site seems a poor and community serving (theater, etc.) choice for an outdoor amphitheater. However, an indoor theater would work well here and would have excellent tkeeway visibility. F 15 TDC Information (See Map ## 4) Transfer of Development Credits Tax Tools Mitigation Options & Developments that Generate Income & Taxes In order to implement the LEHC proposal, it is critical to provide economic incentives for the affected land owners and the two cities which are vying for tax dollars. The largest money generating areas for the three land owners and the cities are the "Big Box" Regional Shopping Stores. The LEHC plan reduces the current acreage proposed for this type of shopping from 135 acres to about 70 acres. There are two reasons to justifjr this change. First, the City of Carlsbad is in possession of a recent market study which noted that only about 60 to 70 acres of "Big Box" stores can be supported by the demographics of this area (at least in the near term). Secondly, the two cities have acknowledged that there is a race going on between the land owners (and the cities) to see who can get their plans approved first. Whoever gets approval first gets the profits! Obviously, if the area could support 135 acres of Big Box stores, there would be no need for a race. It is questionable whether this area can support over 1 million sq. ft. of Regional Big Box Commercial. ,- Another reason for reducing the acreage allotted for Big Box stores is the potential adverse and traffic impacts. San Diego County is not meeting traffic air quality standards. If this continues, fbnding from state agencies may be cut off. This could not only delay projects, but it could cost cities large sums of money in lost knding. Furthermore, much of the remaining undeveloped land in north Encinitas and south Carlsbad is environmentally very sensitive. According to Fred Roberts (U.S. Fish and Wildlife Service), this area of the County has the highest concentration of rare and sensitive species. Consequently, developers have had to face long and costly environmental studies and plan reviews. Constrained properties are oRen cheap to buy, but can be expensive and time consuming to develop. As a result, developers and cities can save time and money by directing development towards the least sensitive lands and preserving sensitive lands through a variety of creative economic incentives. This also reduces the chances of lawsuits by outraged citizens. The following is a list of planning tools and economic incentives that might be attractive to the Ecke /I Family, the Hunt Corp. and Home Depot. In addition, the cities could also receive an equitable distribution of tax money. 16 Economic Incentives r for Protecting Sensitive Resources Transfer of Development Credits (TDC) This planning tool allows land owners to move development rights from one property to another. Typically, development is increased on one parcel and decreased on the other. If this is done to comply with regulatory goals, there is often a density bonus given to the land owners. This technique can be used to protect sensitive habitats and agricultural lands. Required open space can also be traded to other sites where it is needed or wanted. In the case of the Eckes, this takes on new significance since much of their land is still under the Williamson Act Agricultural Preserve. Although a notice of non-renewal has been served (in 1992) on several large parcels, it is our understanding that it normally takes 10 years to phase out of the Williamson Act, during which time taxes are steadily raised until they match the current market value of the land. If an owner wishes to develop the property prior to the 10 year phase out, there are usually stiffpenalties and taxes which must be paid. Transferring Williamson Act Protection Representatives of the Eckes have noted that development could begin within 3 years. They may have to pay excessive taxes for that privilege (although they might have a very clever tax attorney). However, it might be possible to transfer the Williamson Act protection to other properties (e.g. Carlsbad Partners and Home Depot) thus avoiding the taxes entirely! Mitigation Development of the Ecke Ranch and the extension of Leucadia Blvd. (regardless of the alignment) will result in damage to the Southern Maritime Chaparral habitat and to wetland areas. It may be possible to mitigate to the Home Depot site which contains three types of wetlands and southern maritime chaparral. Clustered Housing Infrastructure costs rise as development densities fall. Money can be saved by clustering homes on smaller lots or in multi-family developments. Clustering also allows more community open space to be preserved since the area given to development is much smaller. This planning tool does not seem to be used much in southern California despite the need to do so. Density bonuses are usually given as an economic incentive for clustered housing. Perhaps the density bonus should be raised for large scale projects that have regional impacts, particularly if the final project provides superior resources protection and increases the amount and quality of community open space (parks, greenways, etc.). Clustered Commercial This type of clustering can involve multi-story shops, or it can involve "Mixed Use" developments where stores are located on the first floor and offices andhousing is provided on higher floors. Again, density bonuses may need to be increased to attract interest from land owners. 17 Joint Powers Tax Sharing the Ecke, Carlsbad Partners, and Home Depot properties could give the two cities the incentive they need to work together rather than in competition with one another. Although it could be argued that the cities would not want to do this, it is important to understand that a plan which is sensitive to the environment and residents in the area will gain public support. This will avoid lawsuits which delay developments and profits for landowners, which in turn delays the creation of sales tax dollars. An equitable distribution of tax money (under a Joint Powers arrangement) fiom the development of - Fast Track Agency Approval then agencies should commit to a fast track approval process. This could save considerable time and money. If the land owners are willing to develop a plan which provides superior environmental protection, Sales Tax Refund To provide hrther financial incentive to the land owners, the cities could give back a sigdicant portion of the sales tax revenue for a limited number of years. This could help to cover the expense of changing the current development plans. Fee Simple Purchase (Bond Funding, CALPAW '94, and others) The LEHC hopes to work with the cities and land owners in a positive and financially responsible manner. Mechanisms that provide financial incentives to protect resources will be actively supported. However, LEHC recognizes that there still may be a need to purchase land outright. Because of this, LEHC submitted an application for the proposed California Parks and Wildlife Initiative sponsored by Nature Conservancy, National Audubon, Sierra Club and Planning and Conservation League. We were one of 20 conservancies whose projects were selected to receive hnding if this bond should pass on the June 1994 ballot. Provided the bond passes, $6.5 million would be allocated for agricultural lands and sensitive habitats in the Batiquitos Watershed (more hnding could be available by application). The LEHC proposal could become a reality with the help of this hnding. We anticipate that we could apply for more hnding if the bond should pass. LEHC volunteers gathered signatures all summer to quali@ the measure for the state ballot. In fact, we were the first conservancy in the State (of those that pledged 10,000 signatures) to reach our goal. We also lead San Diego County with 12,000 signatures (2,000 more than our goal). r Charitable Trusts There are numerous types of Trusts (Charitable Lead, Charitable Remainder, etc.) that might provide the three landowners with more money than if they did not take these tax donations. The LEHC is not in a position to assist the landowners in this specialized area. However, the landowners should meet with tax experts (estate planners) and a major conservancy group to review whether Charitable Trusts could be used to save sensitive lands and provide a better economic return for the land owners (Home Depot, Hunt, Ecke). 18 --. .- "Big Box" Shopping Center yields more total gross sales and tax dollars simply because they are much bigger (60-70 acres vs. 4 acres) and because they are open year round. If a festival ground were 15 to 20 acres in size and was open most of the year for a variety of festivals, then it would yield substantial profits for a landowner and excellent tax revenues for a City. It would be necessary to hire specialists to develop and manage a Festival Ground, but this would be an excellent tourist attraction for this area. This tax money could support maintenance and security for the open spaces and trails system. r TDC Map Key (for implementation of the LEHC Plan) (4 4% (B) Home Depot transfers development rights to the Ecke Ranch. A sales tax refund for a few years and density bonuses could be used. (C) & @) Carlsbad Partners transfers development rights to the Ecke Ranch (Festival Grounds, Regional Commercial Center, and the housing area (at letter S). Density bonuses and sales tax refunds could be included. f" @) Golf course open space (2 fairways) is transferred to the area northeast of Quail Gardens, and agriculture zoning is put on the former site of the fairways. This might count as a trade of Williamson Act protection and result in tax savings. (SI aL (v) Williamson Agricultural Protection is moved from the current locations on the Ecke Ranch to the Carlsbad Partners property thus avoiding tax penalties. (T) Mitigation transfer to the Home Depot site to compensate for damage to Southern Maritime Chaparral due to road construction. (U) This is a minor shift in the location of the active park. (w) Mitigation for wetlands impacts due to extending Leucadia Blvd. are transferred to the Home Depot site. .i Festival Grounds Festival to determine the amount of tax money received by the City of Laguna Beach. It was surprising to learn that despite the fact that the Festival is only open for two months out of the year, if one does an acre per acre comparison, the festival generates more gross sales (during the business time period of two months) and far more tax money than a "Big Box'' Regional Shopping Center does. GROSS SALES COMPARISON (LAGUNA ART FESTIVAL & A DISCOUNT CENTER) Contrary to popular belief, festival grounds can generate substantial sums of money for landowners and Cities. LEHC researched the Laguna Art Business Time Period (in months) (Gross Sales means Land Use I Acres Gross Sales Gross Sales per Year per Acre per (based on total Year acreage) Used Laguna Art Festival Discount Center Yross Table Sales) 4 2 $3,3 3 3,3 00 $833,325 63 12 $200,000,000 $3,174,603 3.81 $264,550 Gross Sales per Acre per Month City Tax Revenue per Year from YO on Gross Sales (based on total acreage) $450,000 $2,000,000 $69,444 $2643 50 City Revenue per Acre per Year $1 12,500 $3 1,746 Ratio of Gross Sales per Acre (per year or per month) 3.5 1 .o period) time period) $56,250 21.26 $2,645 CITY TAX REVENUE COMPARISON (LAGUNA ART FESTIVAL & A DISCOUNT CENTER) fCitv Revenue means Citv Sales Tax Revenue) 1 .o $2,645 1 .o # I Land Use I Acres EZIr Center .I City Tax Rate on Gross Sales 13.5% ~ 1% City Revenue per Acre per Month $9,375 Gross Sales per Acre per Month (during the business time period) $4 16,663 Ratio of City Revenue per Acre (per year or per month) City Revenue per Acre per Month (during the business time Ratio of Gross Sales per Acre per Month (during the business time period) 1.57 1 .o Ratio of City Revenue per Acre per Month (during the business The City of Laguna Beach might also receive another 1 % in state sales taxji-om the gross sales. This would equal another 33,333 per year in sales tax to the City for a grand total of $483,333 in tax revenue for the city per year or $1 0,077 tax revenue per acre per month.