 |
|
|
Lagoon Valley Draft Environmental
Impact Report (DEIR) Talking Points
The Lagoon Valley Draft Environmental Impact Report is flawed because:
- The DEIR’s Analysis of Air Quality Impacts Is Incomplete
The air quality section says that the following project design characteristics
would reduce the project’s significant air quality impacts:
-Mixed residential and nonresidential uses that encourage walking and
biking
-Pedestrian walkways
-Bikeways
In an urban setting, near jobs that match housing prices and downtown
services, residents and workers might use other means of transportation
than the automobile.
However, this site is far from existing transit services. The freeway
is the main means of access. Jobs to match the housing prices are not
readily available nearby. This argument is unrealistic and disingenuous.
In addition, it is vague. The DEIR does not address the following questions:
1) How many auto trips are these features are expected to reduce?
2) What is the relationship between job salaries and housing prices?
3) How many new residents will be expected to live and work on the project
site?
4) How many new residents will be expected to walk or bike to work?
5) How will the site be redesigned for bus access?
6) What is the current bus service to the site?
The DEIR does not analyze the air quality, traffic and other impacts
of increasingly longer commutes. These long commutes are a result of
the growing distance between jobs and affordable housing for Solano
County residents and workers. This project will exacerbate this problem.
- The DEIR Fails to Analyze Land Use and Planning Impacts Adequately
The DEIR fails to describe all relevant city policies and plans, and
fails to evaluate the consistency of the project with each policy. The
report cannot just say the project is consistent with city policies
– it has to show that it is consistent. A revised DEIR must respond
to the following questions:
1) What are the specific inconsistencies between the project as proposed
and the various applicable General Plan maps, diagrams and policies?
2) What are all of the General Plan amendments required for project
approval at this time?
3) What was the study area used to determine cumulative land use impacts?
What projects and total development assumptions were used in the analysis?
Does the analysis include the general plans and projects in adjacent
cities and unincorporated areas? If not, why not?
4) How is the project consistent with applicable plans, policies and
regulations of all responsible agencies?
5) How will project development before the preparation of the Countywide
Habitat Conservation Plant (HCP) affect the HCP? Will it prejudge reserve
areas for special status species? Could it potentially undercut the
HCP’s effectiveness?
- The DEIR Fails to Adequately Analyze Transportation/Circulation
Impacts
The DEIR lacks evidence to support its conclusions that impacts to transportation
and circulation will be less than significant after mitigation. A revised
section must answer the following questions:
1) How will the project support transit? The DEIR does not disclose
or adequately explain that:
-The project’s proposed location and low density will contribute
to the region’s suburban sprawl.
-The project’s land use will perpetuate the exclusive use of automobiles
for transportation, which has already caused major traffic and air quality
problems in the area.
-The project’s pattern of development will continue to frustrate
efforts to promote transportation alternatives to the car.
2) What are the specific cumulative impacts of needed roadway improvements?
There are many roadway and intersection/interchange improvements related
to the project. They will have direct and indirect impacts on traffic,
grading, air quality, biological resources, water quality and more.
Diagrams of each improvement, total amount of grading, cut and fill
and other information should be added.
3) When does each of the needed roadway improvements need to be completed
for acceptable levels of service to be maintained? When will impact
fees be raised for these improvements?
4) Where does the DEIR analyze traffic-related impacts to the lake?
5) What is the average number of “service” trips associated
with proposed executive units (e.g., maid service, maintenance, deliveries,
etc.)? How does this compare with assumptions made in the traffic analysis?
6) How much will this project generate in traffic mitigation fees? How
will those fees be used? Certain traffic improvements are necessary
to maintain adequate levels of service; will there still be a gap in
the funding needed to complete these?
A revised analysis must also include information about existing transit
service in the area, including, but not limited to: types of transit,
routes, headways, capacity, and plans for expanded service in the region,
city and at the site.
- The DEIR Fails to Adequately Analyze Impacts to Hydrology,
Drainage, Water and Water Quality
Pollution carried by storm water and urban runoff is the largest source
of contamination to surface water both in California and nationwide.
Construction sites, in particular, have been identified as significant
dischargers of polluted storm water, involving high concentrations of
silt and turbidity, as well as oil and grease, trash, sewage, and other
chemicals used in construction activities and equipment maintenance.
Despite this well-known and well-documented problem, the DEIR fails
to adequately describe the project’s potential impacts on the
area’s water quality. These include project-related and cumulative
construction activities, and on-site and off-site drainage “improvements.”
The DEIR fails to address:
1) Whether the extent of drainage alterations is an acceptable project
feature.
2) Whether the proposed system of drainage features will actually be
a viable system over the long term, and effectively mitigate significant
impacts to the natural drainage system.
The best way to ensure that water quality is maintained is to “cluster”
the project to reduce its footprint. A second way to ensure that water
quality is not compromised is to delete golf courses from the project.
For both of these reasons, we urge that a revised DEIR give serious
consideration to new alternatives: infill first, and next, a truly clustered
alternative without a golf course.
The following are questions about water supply and water quality
that a revised DEIR or FEIR should answer. These questions include,
but are not limited to:
1) What are the water controls that will ensure no increase in turbidity,
sedimentation or other pollutant loads into the lake?
2) What are the estimated total daily loads of sediment and other pollutants
from this project and cumulative development into the lake? Include
all pollutants generated by site development and post development operations
of the development and golf course.
3) What are the water quality impacts of the golf course? What are the
specific quantities of pollutants that will be used to maintain the
course?
4) What are the cumulative water quality impacts of all cumulative development?
Please quantify.
5) How will water quality measures be paid for 20 years from now and
beyond? Is a bond required? If so, how much is the bond?
- The DEIR Fails to Adequately Analyze and Mitigate Impacts
to Biological Resources
The biological analysis section of the DEIR is inadequate for numerous
reasons, including, but not limited to the following:
1) The DEIR underestimates the importance of the project site for species
habitat and wildlife movement. What research indicates that species
will utilize golf courses and traverse areas of low density? Information
should be provided for each species that may occupy the site.
2) The DEIR fails to adequately mitigate for the indirect and direct
losses of habitat currently occupied by endemic wildlife. Because the
DEIR fails to provide adequate mitigation to offset these impacts, project-related
and cumulative impacts to biological resources should be identified
as significant and unavoidable in a revised DEIR.
3) The DEIR fails to identify feasible mitigation measures. These include,
but are not limited to:
-Eliminating the golf course and clustering development so that large,
unfragmented open space areas remain intact.
-Significantly increasing setbacks (e.g., to 1,000 feet minimum) from
development to sensitive habitats on the project site, including the
lake.
-Payment of a substantial open space mitigation fee (open space conversion
fee/resource conservation fee).
-Specific mitigation for loss and disturbance of wetlands and riparian
habitat. Mitigation measures call for additional information about project
impacts and mitigation to be developed after project approval. Postponing
the specifics of mitigation for this impact and impacts to other biological
resources until prior to improvement plan approval will not result in
adequate public review.
A revised DEIR must also explain why avoiding resource disturbance is
not feasible. For all of the above reasons, a revised DEIR must adequately
analyze project-related and cumulative impacts to biological resources
and corridors.
- The DEIR Lacks Any Analysis of Population, Housing and Employment
The DEIR lacks any analysis of population, housing and employment. Where
jobs and housing are imbalanced, the result is increased traffic, commute
times and other effects that can contribute to the significant impacts
of a project.
A revised DEIR must respond to the following questions:
1) What assumptions were used to calculate employee impacts (e.g., commute
times, distances, total trips) on traffic, air quality and noise?
2) What is the total estimated current and projected gap in affordable
housing units in the region and city? The projected gap should be based
on projected total new jobs based on the adopted City General Plan and
regional information from ABAG (the Association of Bay Area Governments).
New jobs should be broken out by type of job and salary range, and compared
with projected new housing in the region.
3) How were the estimated number of construction jobs calculated? Over
what period would these employees be working? Where are construction
employees expected to reside? What is the cumulative total number of
construction employees in the study area during the total construction
period for the project?
4) Describe the likely commute trends in 15 years if the current trends
continue in terms of the growing gap between affordable housing and
new employment. Describe the likely total number of affordable units
projected to be built in the region and city over the next 15 years.
5) Based on the above, characterize the project-related and cumulative
jobs, housing and population impacts on traffic, air quality, etc.,
and describe any needed mitigation.
- Consideration of the Project is Premature
Consideration of the proposed project is premature for at least three
reasons.
1) The County has initiated a Habitat Conservation Plan. The City should
delay further consideration of the project until the HCP is completed.
2) The project should be delayed until a new General Plan is created
that is consistent with this type of development in Lagoon Valley.
3) Further consideration of any project on the site should be postponed
until the project applicants redesign the project so that it reduces
or eliminates the 14 identified significant and unavoidable impacts
listed in the DEIR.
- The DEIR Does Not Adequately Discuss Alternatives to the Proposed
Project
The DEIR fails to adequately analyze alternatives.
1) One of the development alternatives is “transparently”
based on a comprehensive constraints map. This map identifies areas
of high resource values. It also identifies areas that should be avoided
based on city policy and regulations, as well as other guiding policies
and regulations.
A revised analysis should include an alternative based on a site constraints
map. This map illustrates current information about high-value resources,
wildlife corridors, habitat areas, hazard areas (landslides), and other
environmental features on the site. This alternative should also cluster
development in a true cluster development pattern, rather than the “sprawling”
cluster pattern.
2) Consideration should be given to an alternative which calls for delaying
any action on the project until a Habitat Conservation Plan has been
completed for Solano County.
3) The DEIR fails to address the possibility of locating a similar project
closer to Vacaville’s urban center, which would be considered
infill development. Such development would automatically reduce the
significant air quality and habitat impacts of the current project.
- The DEIR’s Discussion of Growth-Inducing Impacts is
Inadequate Under CEQA
The DEIR’s growth-inducing analysis fails to adequately analyze
the potential growth inducement associated with the project’s
new and extended services and infrastructure, its new residents and
employees, and the demand for services and facilities by new residents.
A revised report must include an adequate analysis of the project’s
potential for growth inducement. This would include, but would not be
limited to the following:
1) A complete list of infrastructure and road improvements funded in
part or whole by the project, and a determination of whether any of
these will support additional growth beyond the project.
2) A list of all other infrastructure improvements and expansions necessary
to serve the project, and a determination of whether any of these will
support additional growth beyond the project. This would include:
-The status of development permitted on adjacent properties or on the
project site under all applicable plan and policies.
-Other services in the area that may expand as a result of major new
development in the valley (e.g., business services, retail services,
churches, schools, home care services and the like).
If no additional development is contemplated on the project site, a
permanent conservation easement, development agreement, or other legal
instrument should be included as a mitigation measure to ensure that
development on this site is permanently capped.
A more thoughtful evaluation of these impacts is warranted given the
scale of this project and other projects in the region. This analysis
should also be used to inform a revised analysis of cumulative impacts.also
be used to inform a revised analysis of cumulative impacts.
|
