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City Council - 2002-123 (5)
PARKSIDE ESTATES EIR #97-2 COMMENT CARDS AND COMMENT LETTERS PUBLIC INFORMATION MEETING MAY 1491998 & JULY 259 2001 VOLUME III 10 ) 6 � � w - u• y w v a.r - .a uu v v gs�rvr- � ry Prepared for: The City of Huntington Beach Planning Department 2000 Main Street Huntington Beach,CA 92648 Prepared by: EDAW,Inc. July 2002 PARKSIDE ESTATES EIR No. 97-2 Volume III COMMENT CARDS AND COMMENT LETTERS ON THE DRAFT EIR AND NEW ALTERNATIVES TO THE DRAFT EIR STATE CLEARINGHOUSE NO. 97091051 PREPARED FOR: THE CITY OF HUNTINGTON BEACH PLANNING DEPARTMENT 2000 MAIN STREET HUNTINGTON BEACH,CA 92648 PREPARED BY: EDAW,Inc. July 2002 o� 0 n 0 3 n y 6.1 Comment Cards Public Meeting May 14, 1998 DRAFT EIR COMMENT CARDS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE COMMENT CARDS SERIES 1. Sandy Genis SG 1586 Myrtlewood Costa Mesa, CA 92626 2. Connie Boardman CB 8401 Sweetwater Huntington Beach, CA 92649 3. Eileen Murphy EM 201 2151 St. Huntington Beach,CA 92648 4. Aimee Toth AT 4536 Heil Ave. Huntington Beach,CA 92649 5. Joseph Racano JR 301 Main St. Huntington Beach,CA 92648 6. Joe Buley JB 17192 Greenleaf Ln. Huntington Beach, CA 92649 7. Kim Kennedy KK 122 9`'St. Apt. D Huntington Beach, CA 92648 8. Jan Vandersloot JV 2221 E. 16`h St. Newport Beach, CA 92663 9. John Scandura JS 17492 VaIeworth Circle Huntington Beach, CA 92649 10. Charles Beauregard ChB 17221 Greenleaf Lane Huntington Beach, CA 92649 11. Bob Schwarte BS 5422 Glenstone Dr. Huntington Beach, CA 92649 DRAFT EIR COMMENT CARDS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE COMMENT CARDS SERIES 12. Marty Annenberg MA 17152 Camelot Circle Huntington Beach, CA 92649 13. Elda Barry EB 4089 Aladdin Dr. Huntington Beach,CA 92649 14. Susan&John Rogers S&JR 17172 Greenleaf Huntington Beach, CA 92649 15. Dixie Grimmett DG 5322 Kenilworth Dr. Huntington Beach, CA 92649 16. Glenna Touhey GT 4665 Twintree Dr. Huntington Beach,CA 92649 17. Mary Ann Toler MAT 15051 Baylor Circle Huntington Beach, CA 92647 PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: �7 ��S Address: S� Date: Do you wish to speak tonight? Comments: `- Gr%� -- �D 'Note:Time limit for speakers Is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: ; cat Address: u / Date: Do you wish to speak tonight? Comments: / 2 IS As lhtL 'Note:Time limit for speakers is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: — e e Address: D +t'•�".�;�?• ��°'•�'.`.'.131K-., s�y ri. .. v s_��9.. 'F"a• . bate: n Do.you wish to spea two fight? 4 - '% �J•Z''''.� .. .. . FT.. "r- r'.�--�st,C ,S�x' ;�: 4., p RVI,.. Comments: 'Note:Time limit for speakers is three(3)minutes. _ CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional sp ace on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: Address: L- 9 2.6 Date: Do you wish to speak tonight? -ems Com ents: �it� e / 6� 1 c 1Wt� y_ woV.-Q t S' c t �f?> 'Note:Time limit for speakers Is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: Address: 301 M a;A f-• Ca. Z.-b y Date: o you wish to speak'tonight? Comments: 'Note:Time limit for speakers Is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATM: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: co:- -Address: / /9 Z- Date: Do you wish to speak tonight? L��s Comments: rrrLT e.r 'Note:Time limit for speakers i ree( minut . / CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: Address: Date: Do you wish.to speak tonight? Comments: lek 'Note:Time limit for speakers is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: (/ Address: Date: Do you wish to speak tonight? Comm nt s .Tu.� 3 `( C� C � ` Vote:Time limit for speak rs is three(3)minutes. CITY OF HUNTINGTON BEACH /O� G"-" 2000 MAIN STREET, HUNTINGTON BEACH, CA 9264�f �lJ �$7� (Additional space on back) ATTN: JIM BARNES v y' 91 cr,�� PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: Date: Do you wish to speak tonight? Comments: �' �c c <<, c s 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Ugc�-s Address: / '7azl r r r,7��ea Date: Do you wish to speak tonight? X-5s Comments: 'Note:Time limit for speakers Is three (3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Job 1`z� )onu0t1Qj Address: 5 1-V-12% C=,-UNsiome, 1�. fL Date: 5. 1 4 .4 8 Do you wish to speak tonight? s Comments: W a3m r p u m o i>,g - s i.A e, a 10-6 y -Ce- `A'o-t" a re s - T{-a-41-c o a..a 6 terns +n s xt'e. 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: A&-rV -4dr=rMCIC�z- Address: r Date: Do you wish to speak tonight? Comments: 'Note:Time limit for speakers is three (3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: L AR Pq Address: Ll ..< q- R I > D � -b K ur�ri`Per d tiI 1� 8-P6od e. 16 - 12 � Date: Do you wish to speak tonight? j Comments: 1:k M r-Y S 01,Z i�o L IS ra�l� �tG, e. HDA Al 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH -,�ppi4ye --rT1 F 2000 MAIN STREET,HUNTINGTON BEACH, CA 92648 additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: LY Date: Do you wish to speak tonight? Commen s: - t � C'�•• X a � aK�P� �T Q �'�c� �.�5 i� c��.� C14�� � C�C� {� v .Dote:Tim imit for sp kers is three(3)min CITY OF HUNTINGTON BEACH � � �..k� -C • 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: Address: Date: .5- ! Sp- Do you wish to speak tonight? comments: �s�r�x oj�u 7�, LQ �B LG G L AP !mot �J ho ze- �L e 'Note:Time limit for speakers lktthr a(3)minutes IZP ,e ivoy a �� 7�'�-e- CITY OF HUNTINGTON BEACH .�h000 v, `n b-L 2000 MAIN STREET, HUNTINGTON BEACH, C 92648 41�, AdditionalX eon b c ,TTN: JIM BARNES lv"'r � u,.Ge— 4, �_ "/.2 PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT Name: - a Add r ss, Date: .—� ' Do you wish to speak tonight? Comments: 0 Note:Time limit for speakers Is three (3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: JIM BARNES mac.� 11'3,�,,,- lam- � old / PARKSIDE ESTATES EIR 97-2 CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: 4wN Address: 1SD SSA 1�$ L(b Date: Do you wish to speak tonight? N� Comments: 14ra A-1 iV 5 7 A-Iv 'Note:Time limit for speakers Is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: JIM BARNES 6.2 Comment Cards Public Meeting July 25,2001 NEW ALTERNATIVES TO THE DRAFT EIR COMMENT CARDS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE COMMENT CARDS SERIES 1. W.R. Curran WRC 1 17131 Pleasant Circle Huntington Beach,CA 92649 2. Scott Vi Cowden SVC 1 124 16`h Street#1 Huntington Beach, CA 92648 3. Lee Haber LH 1 —2 5392 Glenroy Drive Huntington Beach , CA 92649 4. John Ayala JA 1 17152 St. Andrews Lane Huntington Beach,CA 92649 5. Dr.Julie Lauterborn JL 1 —3 17101 Greentree Lane Huntington Beach,CA 92649 6. June Ross JRs 1 —6 5472 Kenilworth Drive Huntington Beach,CA 92649 7. George R. Ross GRR 1 —4 5472 Kenilworth Drive Huntington Beach,CA 92649 8. Jennifer A. Thomas JAT 1 5432 Kenilworth Drive Huntington Beach, CA 92649 9. Linda Moon LM 1 Amigos de Bolsa Chica 16331 Bolsa Chica Road#312 Huntington Beach,CA 92649 10. Barbara Olson BO 1 5262 Kenilworth Drive Huntington Beach,CA 92649 NEW ALTERNATIVES TO THE DRAFT EIR COMMENT CARDS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE COMMENT CARDS SERIES 11. Shoy Yee Kong SYK 1 5402 Kenilworth Drive Huntington Beach, CA 92649 12. Don Pichovich DP 1 17131 Camelot Circle Huntington Beach,CA 92649 13. Fred De-Nuccio* FRN 1 17092 St. Andrews Lane Huntington Beach, CA 92649-4565 14. Douglas Stewart DS 1 —6 5342 Kenilworth Drive Huntington Beach, CA 92649 15. Jeff Roeder JR 1 —3 5431 Kenilworth Drive Huntington Beach,CA 92649 * No written comments were included on comment card. PARKSIDE ESTATES1 NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: i 7/ / �� li ��� ��, _9�7-G Date: Do you wish to speak tonight? Yf,� Comments: 470 G 1- 'Note: Time limit for speakers is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: Date: i Do you wish to speak tonight? l 1'n Comments: j �(( I yr e, 6')'f h 7 d 4- i 5 h r. c� C c, r �a K d S s U 'Note:Time limit for speakers is three(3) minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) A rr%1. A A A MN/DCTu 0nr%CnCd1 PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR ' CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINn Name: �E- a� t✓r Address: 5392 G lexn r•oy Dr-lye. w1+i m �o r-\ g2o.c.� GA Cl 2.6�-�-� Date: 7A5lo Do you wish to speak tonight? Comments: F9., -07 9 4 Rj 4 4 uP FEMH WA OM(? . A lf(ac a. ne (' o aL)a o+r a (i i-+j e- 6Jo W e ro c&ng Ie.ve ls- +" T((xLt �i2(t �+ 11 ' ,►`1omZS c�►(�- ors ro.ise�C �owLflorls Cf iy • on �;(I) {?aGLyo.+'0.S Onty ��rTle a.voV4 �+.�, Sc�r2e.� ��l tV 1• ! k:5 woU.I� 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN t"'o C,00 'inLLe- o- o-xlc'/or InAIP.5 wctA— ete..sja�,ons 0boje- 41j. look Lve. I �a c Ly ar _<, W o AA 6 e. 0. av�n� 'this ��r o.� U•Y'GG� ��o r wo,�e r� c.�oc��r� �S' sprer,,.k 4 - Wc,f'Q.s; ova— a r► 4 r o 6 l e n W1 c 9�5 t=CC or . S�o.�-a�c- �v.rhe k o n Gt2�4 Woudi no+ 6e.. 0.S CY� In +L ndgJ Or-r 004 n (oc,c?er' s�' ��vcfions J� " -�D �, 0�`14L, nzicLri -- -o nori-h `Kn;Loac�k)C_ tvh�a) e-}L.) ani Jauoer- vC�iCyar& ele,Vo.�1on5 w 's it" hs_, 6mf'5 ro.ig�c9- qv. n&' `ons Cniol" on PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT E1R CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: 1 ,�- - Address: -7 Date: 7— LS Do you wish to spe �7'z,'- /-57 ? �d Comments:Pi �l �12� �S7` 1s i X) 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH / v 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINn Name:,&,juji e L,.k c6ouj Address: /-7/V Date: �/� S�/o / Do you wish to speak tonight? Comments: M.r hA c-Ps-- /,76P cgc®► 4J il-6du2P ss IAYI /ate U/- a W,9 u n Z 01*? t4 'Note:Time limit for speakers is ree(3)minutes. CITY OF HUNTINGTON BEACH a-717 d �4�� � j 14 2000 MAIN STREET, HUNTINGTON BEACH, CA 92"S (Additional space on 6aCIO ATTN: MARY BETH BROER.E_N Ccr;�t C el?n S alb t /J �t,/�esE'�� e. ACL/10,*-1'� IW� - Lln 0 ply L,4-- - a 4 'r,C,4� 7a h n07 cAlt C PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRMM Name: 3 Lf'- 00's-S Address: G4:7a- ZjbetcLa" -- /fUW-11'zG-7'b-Cj 9 0-"q 9Z6 4L o7 Date:f)7 ]?,0 o J Do you wish to speak tonight? AA, Comments: t. s 61v Xt gay l 16 gut u4 41 /A A Am I T .. 'Note:Ti limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) ATTN: MARY BETH-BROEREN J), �h2 J'/Gfhc, rpokL4 a�-t �&A-j M a4a.,,L &4sck N Goy ,old UJ A"ae�7"tzg a.n 0/ � /'ua q� a� f p �G� Id ,�.C� � 6�cCa / f fir✓� a.lic.�t �" � on pla par-"-"", OVA. l� !°C,k(-IG ? PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: f /<1 �o gs Address: _ 1;,�-7Z K e o z-cj ,-/ L"Z-.r - Date: Do you wish to speak tonight? Comments: .2, tyiyr� t.x,s—i.11z, H�Gh' TJ4.lGFie �c97��L5 o�J �R9tsr��`i D*�41(,as %�ty' seX¢�1L Z'�3Jfi� 'Note:Time limit for speakers Is three(3)minutes. e� ,F3Y O,fO�'�1rii Y i0 ,Cill���rG W A.�73-966a CITY OF HUNTINGTON BEACH 2000 MAIN STREET,HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH.BROEREN 3• �«�... A�Jz' e.orrllz�xra�:�iJ � ,9z�,0� �� _K� i�cac��� ,J�sc3 lD�s� !F , cvic.L ,�,v�• �a�-iF�a.rss�:�o� /�G ��,vc� �� �rt� L o� d t= pR�v'fte Y 1..vss o F oe�9�J ✓t v zc> ��� ..��-c,P�c-saw •�h�l s� Y�Z S e r�C PeQvx,rt• : 7- o r- �c� nT�J r9-e-e es-� r�-,F-�4 Tp Z x p-!2"�'t GcJ/G L SlC.Jr/GlGl3sJi'Z,� PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: J6-AWF-tr— 4 _ Y )33 Address: 4 2 K e,n i w or+k Date: Do you wish to speak toni ht? Comments: �" e- ✓� e, Ad Y1 �r +tnY rye, i �(G n1 t 4- t4ou lA bc muc o g-' A I A n t i TD ac, e, rn S tanA 1S S0me✓ 6� 4 -e— 1 *5� uV1 &-/�A0DeA 1an�• 1--' ct- 56 'Note:Time limit for speakers Is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 dditional space on bac ATTN: MARY BETH BROEREN c' Y) al�y-'JL � Tkis b, 1 J as w cA--\ o►nSs . &b s� p� p 0 (a-n 1 Qj 0 �"�r 6c'1j60Tyy)cn� PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: Date: Do you wish to speak tonight? Comments: � �� 'Note:rime limit for speakers is three(3)minutes. o I G���j /Y�/'�di�G:J r CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: 6� 2 �- �5 �sQ Address: Date: _ 7�� �� % Do you wish to speak tonigh; Comments: J coZF ,A' „j 6 Al ��/ r 'Note:rime limit for speakers is three(3)minutes.y � ��//�Kl --fW1 G 1'�0 1RE� f L7 k�' Go(nl�Tv7 b�- �GX I-r W 1�' /1)0 [ Lc� �.K a /�Ecc1 G u1✓t!G (L L— 7' ASS (r l r S S CITY OF HUNTINGTOFfBEACH�' f 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD ✓Gi (PLEASE PRINT) �O J Name: �-H O y Y�E Address: d i-- cti--n�' CA- S�G q-S Date: Do you wish to speak tonight? Sc, Comments: �hv :5f, our CcJ>-ePr-,4-s - JVl — ,� o�ee�vr� o� -n u-�esia. c$!` /C — c c�-tIc so��,. 'Note:Time lim for speakers is throe d minutes. � �� � 6k 7/- CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EiR CITY OF HUNTINGTON BEACH /r PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: -DON }�1� 0 V I �1 Address: ! t l C A fy\-e-L m V C 12 CL E Date: 2S`0 Do you wish to speak tonight? NO Comments: 7`R��F�c 477— "uw VT)!3tR 2 A SLR A CCl pery T-z> OCG u Q. e:y4' Z%y Fe.W O Pi S - 1-hf ' 00 o se c,+ WILL 1A10aaA,:5,e TR4FF/c. fZR-/hRT[GALL` CoA/5TRlG7'l NG- E6eess /30-Al ICtN«weeTW TO 61?h*&M , Too mHNy CR41?S o 'Note:Time limit for speakers is three(3)minutes. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH, CA 92648 (Additional space on back) ATTN: MARY BETH BROEREN PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: 1> Address: l-t�.59 Date: 25� n 1 Do you wish to speak tonight? 1 Comments: ote:Time limit for speakers is three(3) minutes. NGTON. .BEACH ETHUNTINGTON BEACH,CA 92648 (Additional space on back) BROEREN "s��,` PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Address: *v,-, lecam , c"i gzc4q Date: :5/0 l Do you wish to speak tonight? Comments: We, :hovtJ ab(e�' :ffn Y-eAr`/a&k) --�Kp CLTM 0kglA-/'K CaM O f` 'TT) fM LN-16 LIM►'1'&-iA Z CAM ` Ai _C 0-day 11<n1l V-P S Cm a-(&,tS Ckg- __ 'Note:Time limit for speakers is thre (3)minutes. d Y CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 ` (Additional space on back) ATTN: MARY BETH BROEREN 'ehl J o b � �A 1 I C� d � PARKSIDE ESTATES NEW ALTERNATIVES TO THE DRAFT EIR CITY OF HUNTINGTON BEACH PUBLIC INFORMATION MEETING SPEAKER/COMMENT CARD (PLEASE PRINT) Name: Date: ©� Do you wish to speak tonight? Comments: Lv�J�✓`C. O_y'G ��r �C/�� G� D/r,���d ,S�il f,� / �/Or•C W/ S1�M17'I P_/'LR.�� 'Note:Time limit for speakers Is three(3)min es. CITY OF HUNTINGTON BEACH 2000 MAIN STREET, HUNTINGTON BEACH,CA 92648 (Additional space on back) 4TTN: MARY BETH BROEREN �° �f� 0 0 �o r _-� 7.1 Comment Letters on the Draft EIR DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENURESPONSE WRITTEN COMMENT LETTERS SERIES 1. Southern California Association of Governments SCAGa 1 J. David Stein 818 West Seventh St., 121h Floor Los Angeles, CA 90017-3435 2. Ronald E. Reed SCGC 1 Southern California Gas Company, Box 3334 Anaheim,CA 92803-3334 3. Joe and Geri Buley J&GB 1-12 (Copy of letter also sent to Councilmember Garofalo) 4. Marianne and Joel Tonjes M&JT 1-5 5. Miriam Wedemeyer MW 1-6 4165 Warner Avenue 103 Huntington Beach, CA 92649-4255 (letter sent to Planning Commissioners and City Council) 6. Donnamarie Risse DR 1-4 5422 Kenilworth Drive Huntington Beach,CA 92649 7. Department of Transportation DOT 1-3 Robert F. Joseph District 12 2501 Pullman Street Santa Ana, CA 92705 8. Dr. Michael A.Cohen MC 1-6 19741 Elmcrest Lane Huntington Beach,CA 92646 (Also sent to Mayor Detloff—Received 5/27/98) 9. Adrea Stoker AS 1-2 5157 El Roble Street Long Beach, CA 90815 10. Elda Barry EB 1-2 Ms. Senior America of California 4089 Aladdin Drive Huntington Harbour, CA 92649 DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 11. Jack and Dori Vance J&DV 1-3 Management Research,Inc. 3592 Venture Drive Huntington Beach,CA 92649 (also sent to councilmembers) 12. Jean McGrath JMa 1-3 16341 Anita Lane Huntington Beach,CA 92647 13. Jean McGrath JMb 1 16341 Anita Lane Huntington Beach,CA 92647 (letter to Mayor Detloff) 14. Mrs. Patricia S. Bystrom PB 1-2 18091 Brentwell Circle Huntington Beach,CA 92647 (Also sent to Councilmember Bauer—5/29/98) 15. Jacqueline G.Dvorman JD 1-2 17128 Bluewater Lane Huntington Beach, CA 92849 (Also sent to Mayor Detloff—received 5/27/98) 16. Environmental and Project Planning Services OCPD 1-19 Division, County of Orange George Britton,Manager 300 N.Flower Street, 3rd Floor Santa Ana,CA 92702 17. Barbara Olson BO 1-6 18. Sylvia Marson SM 1-6 339 Walnut Street Costa Mesa,CA 92627 (also sent to Councilmembers) 19. John Hermann JHa 1-2 6424 Madera Long Beach,CA DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 20. Joan Hemphill JHb 1-5 1905K East 15t Street Long Beach,CA 90802 (also sent to Councilmembers) 21. Betsy Neuwirth BN 1-5 1640 Pasadena Glen Rd. Pasadena,CA 91107 (also sent to Councilmembers) 22. Mr. and Mrs. George Maylor GM 1-3 23. W. Craig Hoad WCHa 1-6 P.O. Box 121 Sunset Beach,CA 90742 (also sent to Mayor Detloff) 24. W. Craig Hoad WCHb 1-2 P.O. Box 121 Sunset Beach,CA 90742 (letter to Councilmember Bauer and also sent to Mayor Detloff) 25. Leonora Holder,Everett Gantz&Family LH 1 9130 Marina Pacifica Drive North Long Beach,CA 90803 26. Susan Fish SF 1-3 17442 Hillgate Lane Huntington Beach, CA 92649 (also sent to Mayor Detloff) 27. Katherine Lander KL 1 28. Sally Ludlow SL 1-5 16696 Intrepid Lane Huntington Beach,CA 92649 29. Samuel and Rose Moreno S&RM 1-4 4821 Los Patos Drive Huntington Beach, CA 92649 (letter sent to Mayor Detloff) DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 30. Mrs.CR Robison CRR 1-2 4682 Warner Avenue,B204 Huntington Beach,CA 92649 31. Nancy Bucciarelli,MD NB 1 6695 Pageant Drive Huntington Beach,CA 92648 32. Timothy Roberts TR 1-5 4791 Curtis Circle Huntington Beach,CA 92649 33. OCTA OCTA 1 Kia Mortazavi, Manager 550 South Main Street PO Box 14184 Orange, CA 92863-1584 34. Mary Jane Wiley MJW 1-7 6192 Moonfield Drive Huntington Beach,CA 92648 35. Robert Neuwirth RN 1-3 1640 Pasadena Glen Road Pasadena,CA 91107 36. Mrs.Jean M. Anderson JMA 1 37. Marinka Horack MHa 1-10 21742 Fairlane Circle Huntington Beach,CA 92646 38. Marinka Horack MHb 1 21742 Fairlane Circle Huntington Beach,CA 92646 39. Jody L. Graham JLG 1-3 5151 Skylark Drive Huntington Beach,CA 92649 DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 40. California State Lands Commission CSLC 1-19 Dwight E. Sanders 100 Howe Avenue, Suite 100-South Sacramento, CA 95825-8202 41. Barbara L. McCoy BLM 1-3 42. Mr. and Mrs. Sing Joe Kong SJK 1-6 5402 Kenilworth Drive Huntington Beach,CA 92649 43. Suzi Tomkins ST 1-3 19871 Deguelle Circle Huntington Beach, CA 92648 44. Wendy Morris WM 1-5 45. Mary Camarillo MaC 1-4 16192 Brent Circle Huntington Beach, CA 92647 46. Mr. Robert Williams RW 1-16G 9161 Annik Drive Huntington Beach,CA 92646 47. Mr. &Mrs. James L.Denison JLD 1-2 6931 E. 11 th Street Long Beach,CA 90815 48. David Carlberg,Ph.D., President ADBC 1 Amigos de Bolsa Chica P.O. Box 3748 Huntington Beach, CA 92605-3748 49. Edward F. Hughes EFH 1 8886 Plumas Circle, 1122B Huntington Beach, CA 92646 50. Susan Dominguez SD 1 DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 51. Lee J.Haber LJH 1-9 5392 Glenroy Drive Huntington Beach, CA 92649 52. Juana R. Mueller,Vice President BCLT 1-59 Bolsa Chica Land Trust 207 215` Street Huntington Beach, CA 92648 53. Ken Feldman KFa 1-7 5411 Glenstone Drive Huntington Beach, CA 92649 54. Kenneth Feldman KFb 1 5411 Glenstone Drive Huntington Beach, CA 92649-4705 55. Kenneth Feldman KFc-1 56. Jayson Ruth JR 1-5 6452 Oakcrest Circle Huntington Beach,CA 92648 (also sent to Mayor Detloff—6/15/98) 57. Michael J. Lester MJL 1-5 5096 Tortuga Drive,#211 Huntington Beach, CA 92649 (letter also sent to Councilmembers) 58. Lionel Okun LO1-5 13 801 El Dorado Drive#11 F Seal Beach, CA 90740-3923 59. Alan White AW 1-4 P.O. Box 596 San Clemente, CA 92674-0596 60. Steve Van Nattan SV 1-3 3727 Canehill Avenue Long Beach,CA 90808 DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 61. Neil Wagner NW 1-13 17241 Berlin Lane Huntington Beach,CA 92649-4505 62. Connie Boardman CB 1-37 Professor of Biology I 1110 Alondra Boulevard Norwalk,CA 90650-6298 63. John Scandura,Chairman JES 1-13 Environmental Board 64. Dr. Robert Winchell REW 1-36 Department of Geological Sciences CSULB 6411 Weber Circle Huntington Beach, CA 92647 65. Jan D.Vandersloot,M.D. JDV 1-34 2221 East 16`h Street Newport Beach,CA 92663 66. James Hudson,Jr. JLHa 1 5331 Kenilworth Drive Huntington Beach, CA 92649 (sent to Ms. Melanie Fallon) 67. James Hudson Jr. JLHb 1-2 5331 Kenilworth Drive Huntington Beach,CA 92649 68. Orange County Area Supervisor CCC 1-19 California Coastal Commission Stephen Rynas,AICP 200 Oceangate,Suite 1000 Long Beach, CA 90802-4302(sent via Fax 6/15) 69. Local Agency Formation Commission LAFCO 1-3 Dana Smith,Executive Officer 12 Civic Center Plaza,Room 235 Santa Ana,CA 92701 (sent via fax 6/16) DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 70. Douglas Stewart RPA 1-68 Resource Preservation Alliance 5342 Kenilworth Drive Huntington Beach, CA 92649 71. So. Cal.Association of Governments SCAGb 1 David Stein,Manager 818 West Seventh Street, 12`h Floor Los Angeles,CA 90017-3435 72. US Fish and Wildlife Service USFWS 1-9 Jim A. Bartel,Asst. Field Supervisor 2730 Loker Avenue West Carlsbad,CA 92008 (also sent via fax—6/15) 73. State of California,CPR OPR 1 Antero Rivasplata 1400 Tenth Street Sacramento,CA 95814 74. Department of Fish and Game DFG 1-12 Ronald D. Rempel,Regional Manager 330 Golden Shore, Suite 50 Long Beach,CA 90802 (also sent via fax—6/15) 75. Dan Kittredge DK 1-4 5332 Glenstone Drive Huntington Beach, CA 92649 76. Bryan&Robin Foster B&RF 1-10 5282 Kenilworth Dr. Huntington Beach,CA 92649 77. Glenna Touhey GT 1-3 4665 Twintree Dr. Huntington Beach,CA 92649 78. Cherie&Danny Maruki C&DM 1-3 5176 Tortuga Drive# 110 Huntington Beach, CA 92649 1 n �a SOUTHERN CALIFORNIA 11998 April 21, 1998 Mr. Jim Barnes ASSOCIATION Of Project Planner GOVERNMENTS City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 Main Office 818 West Seventh Street RE: SCAG Clearinghouse 19800190 12th Floor Draft EIR for Parkside Estates Subdivision Los Angeles,California 90017-3435 Dear Mr. Barnes: t(213)236-i800 We have reviewed the above referenced document and f(213)236-1825 determined that it is not regionally significant per Areawide Clearinghouse criteria. Therefore, the project does not warrant www.scag.ca.gov clearinghouse comments at this time. Should there be a change in • the scope of the project, we would appreciate the opportunity to Dfsee� President: Snpe vwr Judy Mikels, Ventura County•First Vice Preidenc Mayor.Bob review and comment at that time. Bartlett.City of Monrovia•Second Vice President:. Supervisor Yvonne Brathwaite Burke,Los Angeles Kelly. Pa� late Put President:Mayor Dick SCA a- Desert A description of the project will be published in the May 1, 1998 County of[lon,El C Samentro Sharp,Imperial County Intergovernmental Review Report for public review and comment. •Dasid Dhillon,El Centro Country of Los Angeles:Yvonne Brathwaite Burke. Los Angeles Ang less.Ei Los;leen Angeles The project title and SCAG Clearinghouse number should be used •Richard Al,,.—.luorre.Cos Angeles•Eileen Anuri, , Diamond Bar•Bob Bartlett.Monrovia Baum in all correspondence with SCAG concerning this project. Barrows.Cerritos•George Bass,Bell•Sue Bautt. Glendora se ad-Lac Los Angeles•Robert Correspondence should be sent to the attention of the Brueuh,Rosemead•Kura Chick,Los Angles -Gene Daniels.Paramount•Doug Drummond. �I r: n s a �' �vJ;M.=+ r f you ('\��i.� !•:\/ n 10� !c C nIP�l Cao Clew ir: ho.ase ;.co ,oar a an .,L, t: r:.�, �,.._..., Long Bach•John Ferraro.Los Angeles•Michael y Feuer.Lot Angelo•Jane Friedkin,E Segundo- contact me at (213) 236-1917 or Bill Boyd at (213) 236-1960. Ruth Galin[er. Los Angeles • Eileen Givens. Glendale•Jackie Goldberg,Los Angeles•Garland Hudeman. inglr,o • Mike Hernandez. Los Angeles • Natc Holden, Los Angeles • Keith Sincerely/McCarthy.Downey•Barbara Messina.Alhambra• Cindy Miscikowski,Los Angeles•David Myers. Palmdale • George Nakano.Torrance • Pam O'Connor.Santa Monica•Jenny Oropeu.Long Bach•B Tre Proo,Pico Rivera•Mark Ridley. o Thomas.Los Angeles•Diann Ring.Claremont Richard Riordan, Los Angeles•Marcine Shaw, J. DAV1D Compton•Rudy Svorinich,Los Angeles•Joel Wachs.Lu`Angeles•l,b W''t`cs,Los c. Sou Manager Performance Assessment Dennis wuhburn.Calabuu • Paul Zee.South , Pasadena and Implementation County of Orange:William Steiner, Orange County•Steve Apodaca.San Clemente•Ron Bates. Los Alamitos•Art Brown.Buena Park•Jan Debay. J DS.II Newport Bach•Richard Dixon,Lake Forest- Charlene Hatakeyama,V Palma•Bev Perry.Brea Cour'^,Riverside James Venable. Riverside Coi/ Lela.Beaumont•Dick Kelly.Palm Des Lodge.Riverside•Andrea Pug,. Coma- ..on Roberts.?mecula County of San Bernardino: tarry Walker,San Bernardino County • Bill Alexander. Rancho Cucnnunga • Jim Bagley,T—ritytune Palms David Eshleman.Fonuna•Lee Ann Garcia,Grand Terrace•Gwenn Norton-Perry.Clunu Hills•John Surbuck.Highland Country of Ventura:Judy Mikels.Ventura County Andrew Fox.Thousand Oaks • John Mellon, l San.Pa.a•Tini Young.Port Hueneme 2 The Gas Company® Orange Coast Region April 21, 1998 City of Huntington Beach F, Community Development Department 2000 Main Street Huntington Beach, Ca. 92648 APR 2 31998 Attention:Jim Barnes DEPARTMENT OF COMMUNITY DEVELOPMENT SUBJECT: EIR-Shea Homes Parkside Estates Subdivision, Graham Street S/O Kenilworth Gas Company This Gmpany This letter is not to be interpreted as a contractual commitment to serve the proposed project, but Mailing Address: only as an information service. Its intent is to notify you that the Southern California Gas Box3334 Company has facilities in the area where the above named project is proposed. Gas service to Anaheim,CA the project could be served from an existing main as shown on the attached atlas sheet without 92803-3334 any significant impact on the environment. The service will be in accordance with the company's policies and extension rules on file with the California Public Utilities Commission at the time contractual arrangements are made. The availability of natural gas service, as set forth in this letter, is based upon present conditions of gas supply and regulatory policies. As a public utility, the Southern California Gas Company is SCGC-1 . under the jurisdiction of the federal regulatory agencies. Should these agencies take any action which affects gas supply or the condition under which service is available, gas service will be provided in accordance with revised conditions. Residential (System Area Average) Yearly Single-family 750 therms/year/dwelling unit Multi-family units 475 therms/year/dwelling unit These averages are based on total gas consumption in residential units served by Southern California Gas Company and it should not be implied that any particular home, apartment or tract or homes will use these amounts of energy. Estimates of gas usage for non-residential projects are developed on an individual basis and are obtained from a Market Services Staff representative by calling (800)427-2000. Market Services can also provide assistance in selecting the most energy efficient appliances or systems for a particular project. Sincerely, Ronald E. eed Technical Supervisor tap EIRCORES.DOC 1 SOUTHERN COUNTIES GAS COMPANY Of CALIFORNIA 0 " O C 137-3 N M N 1y tS eV h ♦ _ Amv O rrrj2 ,� ♦s� a v v S•/fOSIt S•/SciS�S to /,%42 0. ✓, O ,f Q 3u v 17t�52 4 lT st 171�'sj I l Si'sS4% — > /•'' ♦A ��.• •)" ,,y - s-/so s �. 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W I \` TORTUG �N.m{YvtwFdrDR. ��% 1 r0 ,.i`aa ./ ��' ' 1� t 1 LRitMi6� 'I I 1 If7>:o `U ` A ^� G-?30858•® z- rq 11 1 / �•.� � I�Q"'1+w !M ��� :e 3q � � •s :..r s 1 1•K .o« _'` ! �3' '��• J N r� L05'P/r17 5 1 Iols Yt>£ i s O lopS •�a' �s3 Jj J�j �N IM JN1 iN J� J� 1� jy IN IMy �3oJaT-6sB 2•/eN /./T•P! -- —� 2 I i 6o t .bs Ecs N THE SUBSTRUCTURE LOCATION SJO'N'ON TY.IS j MAP ARE APPRCYi?t?R',E ONLY.111E COMPAWI 1 C o WILL Ir-XPEC,in,Sc Ri:Ml?•3MD FOR COST 1 ' OF a REP IR8,tOIMFAC:ILIT.is: GAS CO. � SOUTHERN;.r{L1-{�^tilft ti:r1S CO. . 18 SW,E CO+J.EGE800. P.O.SOX 3333 ANA.11-014,CAU- ORNIA 12M3 R. S. va 92 — 19,2,9 z a F m -3 x V z x V 60 IIAII111f0 nnn Innonnp n �. O n 1 1 mat^ie >z�� anlrnlliunr,lunu„1I,11II u ;d1, .1111::.; t.,. t . .. ._ .. QC I � O `OD fm \� N \ 041Z-Se CWIC.4 571 (VACA7tD) IA*rV.,. ,,J 6'`� (VACATED) 0. �• � 1 -M•�• I L.S. LI[A+S! LINO 12'2!'!t � � 16-M • G00 O N `IO (fs'�+F-•o tq i111?r to C:••r7�in�•.�- s-cs !r mri:, L Q 4R f7- 00 G'cly:7g "1 IG:i7 co 7� fp if lgr 40 Ys i d i a Q• 4 IH C 1'ISO i 40344-i24 L''PC M to lowUl ' +4 i�� di ti i a i4tE•6 N 1h 'tom %*28 5•S4 -" �24y \ o + l co III \ J � '� �'�(s'?� 'w 4n 0 i •....�►� � a �► �yI � `lT9 '�d� pwN of C1 r(Spl M h V r •� s 0 ` a y ooa 4 ��t yrKM u w Ite Z� S may- ef (�a mr REVISED Btl KRE '2-12-95 i VECTOR FILES oG87.2.42 OC 138^� VECTOR CRE,.TED err KRE 12-12-95 RASTER FILE: ocV.2.clt SOUTHERN ORANGE COAST 9 May 3 , 1998 Jim Barnes, Project Planner City of Huntington Beach d Department of Community Development M'9y 0 6 kw 2000 Main HuntingtonStreet Beach, CA 92648 CCMr UN�Ty Re: Draft EIR No 97-2 for Shea Homes Parkside Estates Subdivision MFNT Comments Dear Mr. Barnes: Pursuant to your notice dated April 16, 1998, I have had the opportunity to review a copy of the draft EIR available at the Central Library. Having followed the notification process since my first contact with you on February 27, 1997, attended meetings, and given input( my letter 3/24/97 and public comments 10/9/97) I feel the neighborhood concerns have truly been listened to and that the J&GB-1 EIR is an excellent presentation of all the relevant issues. The neighborhood had many relevant issues that needed to be properly addressed and the EIR certainly shows that these issues were real. Many of the issues have been addressed and properly mitigated. However, some of the major issues and those most often expressed by the neighborhood still are open to interpretation and need to be brought to a more definitive closure. No Vehicle Access From Greenleaf Lane The EIR does address this issue and Exhibits 26 and 27 do show anI emergency access designation overlay over the park designation. However, as was so strongly suggested at the various hearings, J&GB-2 councilman and people change. Their is ample precedent that in later years a different public majority(i.e. the new residents of Parkside Estates) could lobby for and obtain a second access fromi their development via Greenleaf Lane. Second Access From Bolsa Chica A second access to Parkside Estates from Greenleaf Lane should be forever removed from consideration and a second access from Bolsa J&GB-3 Chica should be planned into the development for the following reasons. page 2 EIR 97-2 comments May 3 , 1998 - It is the natural and obvious connecting link between the Bo lsa Chica Wetlands, Parks and New Family Community( See attached map ) . J&GB-4 As discussed below, it provides a direct access for the existing and new residents to the overall development of all the parks and trails and to the coast. - It provides an immediate and second access to the newIJ&GB-5 development lessening the traffic impact and congestion on Graham. - The arguments for not including a second access from Bolsa Chica appear to be found in the Darnell letter dated November 5, 1997. This letter at best is very misleading. It alludes to alignments but includes no sketches. It states that a designated speedlimit of 45 MPH would pose a safety issue. However, one or two traffic lights at the referenced intersections and reposting of a lower J&GB-6 speed limit would alleviate this safety issue. It alludes to a maximum grade requirement of 8 percent leaving the new development, whose width of cut and slope requirements would seriously impact the amount of real estate available for future developement on the bluff. However, this concern can be mitigated by the proper incorporation of benching and use of retaining walls. It would seem logical and cost effective to incorporate the proposed haul road ( see exhibit 15 ) into the final approved plan as the permanent connector-second entrance into Parkside Estates. This design could also be coordinated to include the connecting J&GB-7 walkway, bike trail, etc( see also Exhibit 25, city/county designated trails) . It also would alleviate congestion in the new and existing developments by providing separate access and parking for the public use of the designated park. Designated Park Area It does appear that the neighborhood request for a non-competative park with no night lights has been adhered to. It also appears that the granting of $250,000.00 by Shea to the Community Services Department for developement of the park suggests that the park will J&GB-8 be immediately developed in conjunction with the housing development. This park development plan should be outlined in detail with scheduled development dates. page 3 EIR 97-2 comments May 3 , 1998 The plan should outline grassed area's. Is the softball, soccer/football field and park going to be grassed and maintained. How is the tot lot going to be developed. Is water for watering and drinking purposes going to be made available. Are toilet facilities and garbage removal provided. What about security. Agency Support for above overall coordination Referring to Technical Appendices- Vol I the following excerpts are on point and in support of the above recommendations. - Fish and Wildlife Service letter dated 10/16/97, paragraph 3. J&GB-9 alludes to greenway and trail at and up to westerly edge of the Shea property. Suggests that the 25 houses within 4.9 acres of Orange County would propose conflict. - California Coastal Commission letter dated 10/24/97, paragraph entitled "Public Access". " . . .the project is adjacent to recreation areas; the EIR J&GB-10 should include a comprehensive public access and recreation plan which is compatible with adjacent public access and recreational amenities" . Construction concerns and mitigation What the EIR report does detail, with incorporation of all the mitigation measures, is that this project is a Major construction undertaking. The neighborhood should be kept aware of this through constant education and strict construction environmental rules should be defined upfront, before any construction begins, and strictly enforced. These measures are well known to the construction industry and include such measures as noise control, hours of work, no weekend work, dust control, etc. J&GB-11 When you overexcavate to a depth of 19 feet over a large area, lower a "perched" water table that is now at a 4 foot depth with 40 to 60 submersible pumps over a period of 4 to 6 months with the recommendation that this work be done only in the summner months; move, dry and recompact/ replace 470,000 cubic yards of soil while importing 210,000 cubic yards of new fill it is a major undertaking that requires significant schedule and project controls. page 4 EIR comments May 3 , 1998 In addition the proposed borrow pit should be required to be returned to a natural graded, contoured, and grassed condition J&GB=12 that totally blends into the surrounding landscape. It should not be allowed to be left as an open pit eyesore. Sincerely, /Joe and Geri Buley "A" License 483362 cc: Dave Garofalo Doug and Tracy Stewart BOLSA CHICA 1Atrtl flds,Pals OWNWMW Pwrc J AUM NEW NOSOM PARK ' arra SCHO 1.AND TRA S , t i T A T It a a A a a ASP I11iA 4 May 13, 1998 City of Huntington Beach Jim Barnes ;`E C E I V E D Community Development Department 2000 Main Street MAY 151998 Huntington Beach, CA 92648 DEPAR.H,.AE,aT OF Dear Mr. Barnes: CO'.11141UNITY DEVEI IJFIMENT In regards to the EIR relative to the SHEA Homes development in the Beanfield off of Graham, 1 am submitting my dismay at what has been approved. I understand a significant amount of ground water will be pumped from the area. I know from building a pool that the water table in this area is extremely high and if too much is drained from this area it may cause the neighborhood that borders this area to sink. M&JT-1 Also, the biggest problem I see is the one exit from this tract through my neighborhood. My neighborhood of Prestige homes near the corners of Graham and Warner have narrow streets and consists of single family homes where many children live. Since these are very small streets we receive very little traffic patrol by police. We already must live with some neighbors who drive too fast and don't stop completely at the few stops in our tract. If more drivers are forced through our small neighborhood, the traffic and concerns for the safety of our children will increase significantly. If Kennilworth is the only exit the drivers heading toward Warner will weave through the tract and have to head out through Greentree. These streets were not made to handle that kind of traffic. Our houses will lose value as the nice quiet neighborhood we bought into will become congested. M&JT-2 If drivers are heading out to Graham and if they need to turn left to Warner they will have to wait several minutes, especially during peak traffic times when many parents and buses are heading to Marine View. This stack-up of cars on Kenilworth will cause a delay for us to get to school and work and will raise the exhaust in our area. Because of the hill over the waterway it would be difficult to put a stop sign on Graham. M&JT-3 The only thing that makes sense would be to make another exit to get directly to Bolsa Chica. Most of the traffic will be work related and most drivers use Bolsa Chica to get to the freeways and also the elementary school for this area is Harbour View and parents would be heading west. If a road was made that would go up the hill that borders the eucalyptus trees and the condominiums and would meet up to where Bolsa Chica deadends it would avoid our neighborhood. It would be a straight shot. I know that this land is owned by other parties, but it could be bought or how about eminent domain? M&JT-4 Please do a traffic survey in our neighborhood, especially during peak traffic, i.e. 7:30 a.m - 8:30 a.m. and then again after school 2:00 -2:30 p.m. and then at 5:00 -6:00 p.m. so you can see the difficulty we already have exiting our tract. The light at Warner and Greentree only lets about 2 cars per green through. The stop sign at Newquist is constantly being "run". Unless you plan on allocating more police to patrol our streets, I do not see this "one exit" as a viable option. M&JT-5 Sincerely, Marianne and Joel Tonjes 5 Miriam Wedemeyer 4165 Warner Avenue 103 Huntington Beach, California 92649-4255 May 15, 1998 _ MAY 1 91998 QEPART,iENT OF Planning Commission COMMUNITY p—VELOPMENT City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 RE: Shea Homes'`Parkside Estates"EIR 97-2 Dear Commissioners: Please extend the public review period for EIR 97-2 to 60 days. A number of extenuating circumstances were noted by speakers at the May 14 Public Information Meeting,including the following. Disputed existence of wetlands on the proposed site. MW-1 a Inadequate study of earthquake,ponding and flooding hazards. MW-1 b Inadequate study of impact on Bolsa Chica Wetlands, Mesa and sensitive wildlife MW-1 C habitat. Inadequate public notice of proposed development and EIR review period. MW-1 d Further, I strongly oppose the proposed project on the following grounds. Alternative 1,No Project/No Development is the only mitigation measure that adequately reduces impacts: Alternatives 2 and 3 misrepresent by exaggeration the degree of mitigation; MW-2 Use of Bolsa Chica Mesa development as precedent or as mitigation measure is not viable as that project is in litigation. City infrastructure is incapable of managing additional drainage and sewage: Home owners in neighboring areas will be harmed by ponding and backup. I MW-3 City infrastructure is incapable of managing additional traffic impact: Warner Avenue and Graham Street are frequently jammed now. MW-4 An unsafe condition is inherent in a single entry-exit point: Extension of Bolsa Chica Street is NOT a viable alternative; MW-5 Routing traffic through existing neighborhoods is NOT a viable alternative. After units are sold,the developer will leave; the City and taxpayers will be saddled with the burden of negative impacts. MW-6 Please do not approve this project; our city is already unpleasantly crowded and congested. Thank you for the opportunity to respond. Sincerely, Miriam Wedemeyer i 6 R C E � . MAY 1 91998 Donnamarie Risse ,�: 5422 Kenilworth Drive AA COpiut1�Ty7,,cL.L�CF LOPNIENT Huntington Beach, CA 92649 May 18, 1998 Jim Barnes,Project Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Re: Parkside Estates Subdivision Dear Mr. Barnes: I took the time today to go by the library and view the environmental impact report. Two points jumped out at me...one far more important to me than the other. • On page 2-7 of volume I, water from the new development"may result in subsidence of the property just north of the property boundary."--That's me! My property has already subsided as DRA evidenced by the cracks in my pool decking coupled with the fact that the field side of the back wall is 1-2 feet higher than my side. Further subsidence could crack my pool, make me liable to flooding during winter rains,and be a thoroughly unpleasant condition with which to cope. • On page 2-1 of volume I, access to the property will be"via Warner Avenue." Does this mean that during all construction phases, large vehicles will not be entering from Graham Avenue? This would seem strange to me as well as inconvenient as Kenilworth Drive(the street in front DR-2 of my home)would be a possible outlet if Greenleaf access was used. Homes on Kenilworth would possibly be exposed to construction dirt from front and back of their property. , I would like to know what recourse I would have if the property which I own just north of the development does subside following the city's approval of building permits. Would I have to sue both the City of Huntington Beach and Shea Homes for irresponsible action in building in a I DR-3 location that endangered my property? I have never opposed the tract as proposed,but I have successively pointed out the land movement already observed • No note was made of this that I could find, but I was also concerned if another wall would back my present wall bordering the property or what arrangements would be made to provide an DR-4 attractive division between the two lots. Except an offhanded"they wouldn't build another wall back to yours,"no guarantees or concrete arrangements were made. Sincerely, Donnamarie Risse,owner (714) 840-3252 cc: Shea Homes STA T E C=CA.=CRN!A-5USiNESS,AND TRANS?CRT TOCN AGENCY = - DEPARTMENT OF TRANSPORTATION DISTRICT 12 / '501 E.,LLI;AN STREET ::: r C- SANT:;AN C. 92705 a C May 18, 1998 MAY 2 6 1998 Co11,i ',L'1J Ty D&"Vr= T„S�tVT Julie Sakaguchi File: IGR/CEQA City of Huntington Beach SCI-I�- none Department of Community_ Development 2000 Main Street Huntington Beach, CA. 92648 Subject: Parkside Estates. Dear Ms. Sakaguchi: Thank you for the opportunity to review and comment on Draft Environmental Impact Report on Parkside Estates. The project consist of a proposal by Shea Homes to construct a total of 208 DOT-1 single family homes on approximately 49 acres located on the west side of Graham Street between Warner Avenue and Slater Avenue. Caltrans District 12 is a responsibie agency and has the following comments for your consideration. Caitrans concerns are with potential traffic impacts to Pacific Coast Highway (SR-1). Therefore, please provide additional information concerning the impacts to the intersection of DOT-2 Warner and SR-1 and mitigation measures the city will implement to lessen impacts to that intersection. We appreciate the opportunity to comment on this document. If you have any questions (DOT-3 concerning these comments piease contact Aileen Kennedy on (714) 724-2239. Sincerely, „ Robert F. Jo e , Chie Advance Pla fig Branch C: Tom Loftus, OPR Ron Helgeson, HDQTRS Planning Massoud Tajik, Traffic Operations North Judv Hever, Transportation Planning 8 Dr. Michael A. Cohen 19741 Elmcrest Lane MAY 26 1998 Huntington Beach, CA. 92646 (714) 964-9173 ©i_Q.f R I:'e'lEN- Jr C^P;'UNiTY DE'>E�C ,fE�i7 May 22, 1998 Jim Barnes, Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Re EIR#97-2 I am writing to you regarding two issues that are very important to me, and all of the residents of Huntington Beach that care about preserving Bolsa Chica for now and future generations MC-1 The first topic is that Shea Homes wants to build 200 units on 49 acres of the Bolsa Chica lowlands. This project is on the old Metropolitan Water District land on the north side of Wintersberg Flood Control Channel below the Bolsa Chica Mesa. , 1. The scope of the EIR is inadequate. It addresses impacts only to the 49 acres of development and ignores the impacts this development(and the cats, dogs, light MC-2 etc.)will have on the wildlife in the Ecological Reserve and on the mesa. 2. The plan provides only one way(onto Graham Street) in and out of the project. This is unacceptable from a safety standpoint as well as the impacts on nearby residents. Both alternatives proposed are unacceptable. One is to allow traffic onto MC-3 Greenleaf- into a residential neighborhood, and the other extends a road from the development onto the Bolsa Chica mesa. 3. The City does not have surplus water to provide water to the houses planned for i MC-4 the small piece of County land. 4. The EIR states that there are no wetlands on this land despite weeks of standing water on the site during the winter months. The EIR claims there are not enough wetland plants on the site. Well, the area is plowed repeatedly of course there are MC-5 no wetland plants on the site! The site needs time to recover from the plowing before a wetland determination can fairly be made. Issue number two is that I have just learned that the Koll Company (now called i California Coastal Communities) has approached the City with plans to put 21 units on 7 acres of City land on the mesa on Los Patos Ave. The City Council in the past-directedf staff to have no dealingsWtYthe Koll Company, since due to litigation there is no MC-6 Coastal Commission approved Local Coastal Plan. The Council needs to know that the community does not support this plan ! We must not let Koll get a foothold on the mesa! Please understand that the concerned citizens of Huntington Beach do not want any building anywhere at Bolsa Chica ! Thank you for our help_ /^ Dr. Michael A. Cohen 9 9 'S MAY 2 61998 COfl"MIJINTY D` OF P ENT I ' , - �� AS-1 r f • l� �� �� k- i AS-2 �on� tge� Lh� Cf2's Roni5 10 RECEiVEO MAY 2 6 1998 COMMUNITY]DEVELOPMENT Ms. Senior America of California • tq , 1et9� 1 , EB-1 EB Oct 4089 Aladdin Drive Huntington Harbou4 CA 92649 (&9) 592-2137 11 �1 JACK O. VANCE MAY 2 7 1998 Management Research, Inc. _ 3592 VENTURE DR HUNTINGTON BEACH,CA 92649 �•;' ' "' 714-846-7875 s'f�slq� %tAcA. C ►cct.. �A kL'L l R J&DV-1 AA� wri'i 4 0--1- OL6 crCAO (tk tJed, V4A ate. K611" e o . o.M. -\,D � 2 k \ k J&DV-2 Y �4� G � `"Ct�e�� l •�"v n tkYP, cioc MOA WC-40S 0 1 . 12 R E C E I ED MAY 2 71998 May 26 , 1998 CEFAR7'-rE-vT OF COMMUNITY DEVELOPti1ENT Mr. Jim Barnes , Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Subject : Shea Homes — Bolsa Chica Dear Mr . Barnes : It is my belief that the scope of the EIR is inadequate regarding the building of 1JMa-1 200 units on the Bolsa Chica lowlands . In addition, the CIty does not have surplus water to provide to the houses planned for IJMa-2 this small piece of County land . Please keep all the Bolsa Chica free of development . I want my grandson ' s IJMa-3 children to be able to enjoy the Bolsa i Chica as it is now -- not built with homes . 4 Sincerely , )wE Jean McGrath 16341 Anita Lane Huntington Beach 92647 cc: Shirley Detloff Ralph Bauer Dave Garafalo Tom Harman Dave Sullivan Peter Green Pam Julian 13 May 26, 1998 Shirley Detloff , Mayor City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Subject : California Coastal Communit*es 21 Units on Los Patos Avenue Dear Mayor Detloff: ff Please do not approve the plans to put 211 units on the Bolsa Chica Mesa. There is no Coastal Commission approved JMb-1 Local Coastal Plan. As a resident of Huntington Beach, I oppose this plan. i Sincerely , ", .I )V -' � Jean McGrath 16341 Aftita Lane Huntington Beach 92647 cc: Ralph Bauer Dave Garafalo Peter Green Tom Harman Pam Julian Dave Sullivan _ ° V MAY .2 7 1998 14 MAY 2 71998 MAY 26, 1998 MR.JIM BARNES CITY PLANNER 2000 MAIN ST. HUNTINGTON BEACH,CA. 92648 DEAR MR. BANKS: AS A MEMBER OF THE BOLSA CHICA LAND TRUST AND A HOME OWNER IN HUNTINGTON BEACH I AM WRITING TO REQUEST THAT YOU TAKE ACTION TO HALT KOLL CO. ( CALIFORNIA COASTAL COMMUNITIES) FROM BUILDING 21 UNITS ON 7 ACRES ON LOS PATOS AVE. THIS BEING CITY LAND WILL MEAN MORE SERVICES PLUS IT IS T00 CLOSE TO THE PB-1 SENSITIVE BOLSA CHICA WETLANDS. I ALSO URGE YOU TO PREVENT SHEA HOMES FROM BUILDING ON 49 ACRES BELONGING TO THE OLD METROPOLITAN WATER WATER DISTRICT. SEVERAL THINGS APPEAR TO BE POOR PLANNING SUCH AS ONLY ONE ENTRANCE IN AND OUT ONTO GRAHAM ST.WITH SEVERAL ALTERNATIVES THAT ARE NOT ACCEPTABLE.AGAIN WE WILL BE ASKED TO PROVIDE WATER, SCHOOLS AND SO ON. I ASK YOU TO PLEASE LOOK INTO BOTH PB_2 OF THESE PLANS CAREFULLY. AS A CITIZEN OF THE CITY I FEEL THERE IS MUCH TOO MUCH BUILDING GOING ON RIGHT NOW SO I SAY PLEASE NO MORE AND AGAIN REMEMBER THE WETLANDS NEED TO BE PROTECTED AND BUILDING CLOSE OR AROUND THEM WILL CERTAINLY NOT! SINCERELY, , PATRICIA S. BYS OM MRS PATRICIA S. BYSTROM 18091 BRENTWELL CIR. HUNTINGTON BCH. ,CA. 92647 15 Mav 23. 1998 tIlAY 2 7 1298 Jim Barnes, Planner City of Huntington Beach O�'MENT 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Barnes: I am very much opposed to two developments on the Bolsa Chica Lowlands. The first issue is the building of 200 units on the Bolsa Chica lowlands. The EIR is much too limited as it only talks of the impact on the 49 acres of development and does not address the effect of the development on the entire area. Also, the plans doesn't provide JD-1 for adequate egress to the area and will congest the already existing residential area. The second issue is the plan to put 21 units on 7 acres of city land on the Los Patos Avenue. Please do not continue planning for this site. JD-2 I am a long-time resident of this city and live near the wetlands...so I know the impact of the kind of development. Please reconsider these issue. Sincerely, Jacqueline G. Dvorman 17128 Bluewater Lane Huntington Beach, CA 92849 16 } c;� THOMAS B. MATHEWS County of Orange DIRECTOR U 300 N. FLOWER ST. Planning & Development Services De artme e% ��DFLOOR `' ��' g P P � � NTA ANA, CALIFORNIAF �LIFOR� JUN MAILING ADDRESS: 1 - 1998 SANTA ANA, CA 92702-QU MAY 2 7 1998 Co�,�MUtir�pEVE�o�M F(714) && i ENT NCL 98-23 Jim Barnes, Project Planner City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 SUBJECT: DEIR for the Parkside Estates Dear Mr. Bames: The above referenced item is a Draft Environmental Impact Report(DEIR) for the City of Huntington Beach. The proposed project would develop 208 single residential homes on 49 acres of property located west of Graham Street and south of Kenilworth Drive. Approximately 44 acres are located in the City of Huntington Beach and approximately 5 acres are located OCPD-1 within the County of Orange. The County of Orange has reviewed the DEIR and offers the following comments: Flood t 1. We generally concur with Mitigation Measures 1, 2, and 3 whereby the developer is required to provide local drainage improvements, add a pump to Slater Pump Station, and reconstruct the East Garden Grove-Wintersburg Channel (EGGWC) levee adjacent to both the 44-acre City parcel and the 5-acre County parcel. Any levee reconstruction should be accomplished in accordance with recommendations contained in the project report for EGGWC and to standards and criteria used by the Orange County Flood OCPD-2 Control District(OCFCD) for similar facilities. It is also important to note that the reconstruction of EGGWC levee alone may not provide the required flood protection for the development nor remove the project site from a 100-year flood plain. Adequate additional steps, such as raising the pads of the homes, may also be required to provide the necessary flood protection for the proposed development. 2. The Federal Emergency Management Agency (FEMA) uses different criteria from that used by the project proponent in Technical Appendices—Volume II, Appendix F, Flood Plain Analysis to analyze levee channel systems. Consequently, the results of the OCPD-3 analysis provided in the appendix is not suitable for delineating a floodplain or setting pad elevations. It is suggested that the flood plain analysis be based on FEMA regulations. 3. For your information, the County has retained WEST Consultants to prepare a floodplain I OCPD-4 study on EGGWC for submittal to FEMA. However, the study is not complete. 4. Work within OCFCD right-of-way, or work on the proposed improvements to Slater I OCPD-5 Pump Station will require a County encroachment permit. I Recreation 5. Bikeways: The Commuter Bikeways Strategic Plan and the County Bikeway Plan each designate a Class I (off-road paved, striped and signed)bikeway along the alignment of the East Garden Grove-Wintersburg flood control channel (C05) from Graham Street/Slater Avenue to Pacific Coast Highway. The project should implement the proposed bikeway: OCPD-6 on that part of the flood control facility within the project boundaries to facilitate connection with the flood control facility that will remain in the Bolsa Chica wetlands restoration plan. Developer should continue coordinate with County regarding this facility. a) Exhibits 6c and 6c-1, Section"A"—"A"; the label "Proposed Trail' should be changed to "Proposed Class I Bikeway". Moreover, the standard width for a Class I OCPD-7 (paved off-road) bikeway is 14 feet which includes 10 feet of bikeway surface and at least 2 feet of clearance on each side. The DEIR should be so revised. b) Page 3-14, Park/Open Space Uses; it is suggested that the proposed park be linked to OCPD-8 a Class I bikeway along the Wintersburg Channel via a Class I connector bikeway. c) Page 3-30, Project Objectives (Applicant); it is suggested that the following project objective be added: "Provide a Class I bikeway connecting the project site to Graham Street,the OCPD-9 proposed local park and the future Bolsa Chica open space trails/bikeway system". 6. Local Park Code Compliance: a) The DEIR should provide an analysis which indicates both the City and County Local Park Code requirements based upon the proposed number of dwelling units to be OCPD-10 built. Moreover,how the requirement is being met should also be indicated. Transportation 7. The project is adjacent to Graham Street, a designated secondary arterial highway. If Graham Street is not currently built out to this standard, the project should provide for OCPD-11 implementation of this facility consistent with its classification. Water Quality 8. In the County's EIR NOP comment letter dated October 15, 1997, it was requested that the EIR address the fact that a downstream body of water receiving flow from the project (Huntington Harbor) is officially recognized as "impaired" and thus in need of OCPD-12 improvement from current conditions. This was not discussed in the EIR. Consequently, an appropriate criteria of significance of impacts for any development projects in this area should be "whether runoff from the completed project area may adversely affect the designated Beneficial Uses in the runoff-receiving watershed, or OCPD-13 substantially impact public agency efforts to improve recognized conditions of current water quality impairment". Since no scientific or environmental studies were conducted in the process of developing the Countywide Drainage Area Management Plan Standard Conditions referenced in the OCPD-14 EIR, concluding that compliance with these standard measures would ensure the project has no significant impacts may be unwarranted. Geology 9. We suggest that special publication 117—Guidelines for Evaluation and Mitigating Seismic Hazards in California, adopted March 13, 1997 by the State Mining and Geology OCPD-15 Board, in accordance with the Seismic Hazards Mapping Act of 1990, be utilized in evaluation of the subject site. 10. We recommend that discussion/evaluation relative to lateral spread or seismically I OCPD-16 induced landslide hazards be provided in the EIR. i 11. The EIR should address any potential adverse impact upon the stability and/or function of existing utility/service lines or other improvements (e.g. Flood Control Channel). Any OCPD-17 grading and/or improvement activities impacting County improvement will require an encroachment permit. Other 12. Although the County can begin processing discretionary permits in consultation with City of Huntington Beach subject to Coastal Commission's approval on the required Coastal Development Permit,the County can not process the subdivision map, Tentative Tract OCPD-18 15419, before annexation because portions of lots within the proposed Tract 15419 are located in both City of Huntington Beach and the County of Orange jurisdictions. Thank you for the opportunity to respond to the DEIR. If you have any questions, please contact I OCPD-19 me or feel free to call Charlotte Harryman directly. Charlotte may be reached at(714) 834-2552. ; Ve y e George Britton,j�-a- ger Environmental and Project Planning Services Division 17 BO-1' -2LXX7 BO-2 B04 ItL h-F�/ � d 4- BO-4° 4 BO-5' a 18 May 25, 1998 Jim Barnes, Planner MAY 2 81998 City of Huntington Beach 2000 Main Street r C: Huntington Beach, CA 92648 :i-,-UNiTYOE-VELC MENT Subject: Bolsa Chica Development—EIR Report, Comments I am writing to you to express my concern about building on the mesa and to urge you to consid what the impact of development will do to this ecosystem. Specifically, Shea Homes wants to SM-1 build 200 units on 49 acres of the Bolsa Chica lowlands. Listed here are my comments on the ! EIR. 1. The scope of the EIR is inadequate. It addresses impacts only to the 49 acres of development( and ignores the impacts this development will have on the new wildlife in the Ecological `SM-2 Reserve and on the mesa. 2. The plan provides only one way in and out of the project (onto Graham Street). The other alternatives are to allow traffic onto a residential area(Greenleaf) or extend the road onto the SM-3 mesa. This is unacceptable from a safety standpoint as well as the impacts on nearby residents. 3. The City does not have surplus water to provide water to the houses planned for the small ISM-4 piece of County land. 4. The EIR states that there are no wetlands on this land and the EIR claims there are not enough wetland plants on the site. Well,the area is plowed repeatedly—of course there are SM-5 no wetland plants on the site! The site needs time to recover from plowing before a wetland determination can fairly be made. In addition, I understand that the Koll Company(California Coastal Communities)has plans to put 21 units on 7 acres of City land on the mesa on Los Patos Avenue. Do you have any additional information regarding this activity? SM-6 Please include my comments in the EIR process. Thank you for your attention to this matter. Sincerely, Syf -a Marson 3 3 9 Walnut Street Costa Mesa, Ca 92627 cc: City Council members: Ralph Bauer, Shirley Detloff(Mayor),Dave Garafalo,Peter Green, Tom Harman, Pam Julian, Dave Sullivan 19 F1E EIV7 MAY 2 8 1998 CO%iMl sv-f T 6424 Madera Long Beach, California May 23, 1998 Mr. James Barnes , Planner City of Huntington Beach, California 2006 Main Street Huntington Beach, California 92648 Dear lair. Barnes : May I recommend the halting of the Shea Plan development below the Bolsa Chica Mesa. How many times have EIR assurances proved not only inadequate JHa-1 but misleading. How many coastal area have been irreparably damaged because an EIR evaluation has proved inadequate, h_s proved to have overlooked important considerations. Thank God that there is one outstanding community on the coast, like yours , that does not fill its harbor JHi-2 with oil islands and will fight to protect the few wildlife areas that are left. Best. John Hermann cc: Connie Boardman 20 1905K E. 1ST STREET, LONG BEACH, CA 90802, USA 5621432-0421 May 25, 1998 C E D Mr. Jim Barnes, Planner MAY 2 81998 City of Huntington Beach 2000 Main Street CO1'd'"UNITy O�yE ppMENT Huntington Beach, California 92648 Re: Public Comment on Environmental Impact Report No. 97-2 Proposed Construction of 200 Units by Shea Homes on Bolsa Chica Lowlands Dear Mr. Barnes: I am writing to make two comments on the environmental impact report (EIR) recently I JHb-1 released on Shea Homes' proposed construction of 200 units on the Bolsa Chica lowlands. My first comment is that the scope of this EIR is insufficient. The function of an EIR is to analyze and quantify the impacts of a proposed project on existing environment. The subject EIR confines discussion and analysis of impacts to the 49 acres of development itself, ignoring the impacts which that development will have on existing fragile habitat. This deficiency is JHb-2 particularly egregious because the project is sited close to an ecological reserve and other undeveloped habitat that by virtue of their rarity along the Southern California coast play a crucially important role in the perpetuation of species that reproduce in coastal wetland areas My second comment is that the EIR's assumption that the subject land is not wetlands is specious. The subject acreage has been plowed over and over again, suppressing the plants that JHb-3 would otherwise readily identify the land as wetlands. Sadly, such is the fragility of nature that land-use practices can actually alter its face. As I am sure you are aware, over ninety percent of California coastal wetlands have disappeared. This means that human intervention and inappropriate land-use practices have actually transformed the topography-of the land to the JHb-4 point that its original appearance and function are unrecognizable. The whole point of an EIR is to prevent the construction of such inappropriate, transmogrifying projects. As someone who lived in Huntington Beach for a decade and often walked along its still magnificent.coast to escape tractland, I urge you to find this EIR inadequate and to act to protect and preserve what is far and away the city's most valuable asset, its glorious coastal open space. JHb-5 Thank you for your kind attention to my concerns. Very truly yours, Joan Hemphill cc: Mayor Shirley Detloff Councilmember Ralph Bauer Councilmember Dave Garafalo Councilmember Peter Green Councilmember Tom Harman Councilmember Pam Julian Councilmember Dave Sullivan 21 Jim Barnes, Planner L .. r City of Huntington Beach MAY 2 2000 Main Street 1998 Huntington Beach CA 92648 Dear Mr Barnes While I live in Pasadena, so cannot vote in Huntington Beach, I frequent) come to your city to visit Bolsa Chica and the adjoining beach area to because your varied birds are not found in our foothill community. I feel close to BN-1, Huntington Beach and am concerned about its future., so feel distressed by two recent proosals I have just learned about. To start with, 1 find it difficult to believe that Koll Company is proposing to put homes on City land up on the mesa on Los Patos Ave. 1 hope the !1113N-2 Huntington Beach City Council will quickly quash this proposal. Surely it does not meet the Coastal Commission's guidelines which are designed to protect the! future of the area. ' My second concern is about the Shea Homes proposal to build 200 units on Bolsa Chica lowlands below the mesa. As I understand, the EIR looks at development as a sterile happening, forgetting that people moving into an area BN-3 bring with them pets (which will wander despite any well intentioned regulations passed) and children (who , if they are normal and healthy, will explore wild ! areas despite their parents rules). I am told that the EIR mistakenly states that there oar no wetlands on the north side of Wintersberg Flood Control Channel below Bolsa Chica Mesa. BN-4 During winter, water stands on the site for weeks. If the area were not plowed, wetland plants probably would be growing there. In fact, it would be interesting I to leave the area unplowed for a time to see if wetland plants would grow there, before declaring they will not. Please remember that we are all watching your decision and hoping you I113N-5 act with wisdom. Sincerel Betsy Neuwirth 1640 Pasadena Glen Rd Pasadena, CA 91107 cc: City Council members 22 � C MAY Z 91998 D (�YL GM-1 b—yc Z4 GM-2 23 SUNSET BEACH BUSINESS - FINANCIAL - TAX SE�,✓!gU E 111 E P.O. Box 121 - Sunset Beach, CA 90742 (562) 592-5334 MAY 2 91998 hoad-boston@woridnet.att.net Mr. Jim Barnes, Planner Cam':Z:iJiTY GEvELCzFI:iENT City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Barnes: I recently learned of Shea Homes' desire to build 200 residential units on 49 acres of the Bolsa Chica lowlands. Apparently, the land to be used is former MWD land on the north side of the Wintersburg Flood Control Channel below the Bolsa Chica Mesa. Please take into account my opposition to this proposed WCHa-1 project when considering the fate of the Shea proposal. Although I do not reside within the city limits of Huntington Beach, you are surely aware of how the actions of one municipality impact the environments of cities and unincorporated areas nearby. My reasons for opposing follow. 1. The EIR ignores the the impact of the Shea Development on the wildlife (WCHa-2 residing in the Ecological Reserve and on the Mesa - cats, dogs, lights, noise, etc. 2. The Shea Plan provides only one exit/entrance path (Graham Street) and is unsafe as well as an imposition on the residents nearby. Alternative proposals consist of diverting traffic onto Greenleaf and into a residential WCHa-3 neighborhood OR onto a road from the Shea Development into the Bolsa Chica Mesa, both unacceptable as "fixes" for a project that must not be allowed to f happen at all. 3. The City of Huntington Beach has no water surplus with which to provide the �WCHa-4 houses which Shea plans to construct on a small piece of County land. 4. The EIR reports that there are not enough wetland plants on the proposed building site and that there are, in fact, no wetlands on the site. Taking these two points in reverse order, the site has water standing on it during WCHa-5 all or most of the winter months. As for wetland plants, the site receives regular, periodical plowing. This discourages or eliminates wetland plant growth, to the benefit of Shea but denying an opportunity to assess whether or not wetland plants will or will not survive & thrive on the proposed building site. 5. Finally, as in all proposals to develop any or all of the Bolsa Chica Land, the incremental traffic north and south on Pacific Coast Highway will increase congestion which is always near grid-lock during peak traffic hours. Residents ,WCHa-6 of Huntington Beach, Sunset Beach and Seal Beach will think of you unkindly should the Shea Homes project become reality. (! Thank you for your consideration of my thoughts on this real estate project. i L� W. Craig Ho d 24 SUNSET BEACH BUSINESS - FINANCIAL - TAX SERVICE41 9 Z ?f E D P.O. Box 121 - Sunset Beach, CA 90742 (562) 592-5334 i'�i��{ ` 1998 hoad-boston@worldnet.att.net n,E=. ;,�; ;s OF cc':;,ti ; .s T Y C:_ cLCF MENT Mr. Ralph Bauer, Council Member May 27, 1998 City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Bauer: Today, I learned that the California Coastal Communities Company (formerly, Koll, until Don jumped ship) submitted plans to the City of Huntington Beach for the construction of 21 residential units on 7 acres of City land on the mesa on Los Patos Avenue. I understand that, in the past, Huntington Beach WCHb-1 City Council instructed Staff to have no dealings with Koll Company, since the City has no Local Coastal Plan approved by the Coastal Commission. I and many people of my acquaintance certainly hope that the name change will not result in a reversal of the policy as applied to Koll. Leopards don't change spots, even if one elects to call them pussycats. While I am not a resident within the limits of the City of Huntington Beach, II believe that the Council and Staff should know that residents and non- WCHb-2 residents alike want all parts of the mesa to be left alone, just as it is now. W. Craig Hoa 25 LEONORA HOLDER 9130 MARINA PACIFICA DRIVE NORTH MAY 2 91998 LONG BEACH, CA 90803 May26, 1998 ;VroF CC1:;;�7�,�JITY U-EVEIOpMENT Dear Mr. Barnes, The purpose of this letter is to inform you of my very grave concerns regarding Koll Company's(aka California Coastal Communities)plans to put 21 units on 7 acres of City land of the Bolsa Chica Mesa on Los Patos Avenue. My family and I have appreciated the fact that the City Council has directed staff to have no dealings with Koll Company because the city is in litigation with them and there is,thus,no Local Coastal Plan. The LH-1 Bolsa Chica area is a major recreational and educational area for us. Ticky tacky developments are a dime a dozen,but Bolsa Chica is the last rare jewel on the Coast, supporting all sorts of fish,birds and mammals that have been "developed out"bf most of -dwm original habitats. The area doesn't work as an ecosystem without the Mesa. Please continue to do the job this community expects of you—to safeguard natural treasures from greedy developers. Thank you. Sincerely, Leonora Holder PL Everett Gantz and Family 26 May 26, 1998 RECE , VE ® MAY 2 91998 COMMUDEPART�riE�;TE�EL CF OPMENT Jim Barnes, Project Planner NITY a City of Huntington Beach Department of Community Deuelopment 2888 Main Street Huntington Beach, CR 92648 Re: Draft Environmental Impact Report No. 97-2 - Notice of Ruailabilitg and Extension of Reuiew Period to 68 Days Rs a concerned citizen of Huntington Beach I am writing this letter to express my comments regarding the Shea Homes project proposed on SF-1 the property west of Graham Street and south of Kenilworth Driue. I am so disappointed in the way the city/elected officials haue developed the city of Huntington Beach. It seems that euery open space of land has been giuen to the deuelopers to do whatever they want. The elected officials should listen better to the citizens of SF-2 Huntington Beach and be more responsible in managing the growth of this city. I would suggest you work together, listen better and take into consideration suggestions from the citizens of Huntington Beach. 1 oppose this project altogether and would like to see something other than homes for this area of open land; and I would hope that city council would consider other possible projects or better yet leaue it the way it is. SF-3 Thank you for taking the time to listen to my comments on this proposed project. Susan Fish 17442 Hillgate Lane Huntington Beach, CR 92649 (714) 846-8528 cc: Shirley Detloff, Mayor 27 " VE MAY 20 91998 -r `. �I11i �dTGF CC-",',V--jm yY DEVELOPMENT May 22, 1998 Jim Barnes, Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Der Mr. Barnes : The scope of the EIR is inadequate. It addresses impacts only to the 49 acres of development and ignores the impacts this development (and the cats, dogs, light, etc. ) will have on JKLA the wildlife in the Ecological Reserve and on the mesa. I Please do not allow any development on the Bolsa Chica lowlands . Sincerely, Katherine Lander 28 Jim Barnes,Planner FCEIVEDS City of Huntington Beach MAY 2 91998 2000 Main Street Huntington Beach, CA 92648 DEPARTMENT GF COMMUNITY DEVELOPMENT Dear Mr. Bames: It has come to my attention that Shea Homes wants to build 200 units on 49 acres of the Bolsa Chica lowlands. I feel this is entirely unacceptable. This area is close to the Ecological Reserve and this development would affect the wildlife in the reserve. Pets SL-1 would prey on the wildlife and the light and noise from the units would disturb the wildlife. Traffic would be affected as there is only one way onto Graham Street in and out of the project. The alternatives proposed- one to allow traffic onto Greenleaf-into a residential SL-2 neighborhood or extend a road onto the Bolsa Chica mesa, is unacceptable. All of this impacts present residents unfairly. Again the City is expected to supply water to houses on county land. The county ISL-3 continues its irresponsible failure to provide for its own residents. The statement by the EIR that there are not enough wetland plants on the site to matter. Well if the area is plowed repeatedly, of course there are no wetland plants there. We SL-4 need to give this site enough time to recover in order to determine if there are wetland plants there!!!!! Why is the city determined to develope every last bit of land? Let us keep the entire �SL-5 Bolsa Chica undeveloped for the future generations of Huntington Beach and the state. Sincerely, SaA;%L:11-0)kw� 16696 Intrepid Lane Huntington Beach,CA 92649 cc , C"a- 29 3 4821 Los Patos Drive Huntington Beach, CA 92649 May 22, 1998 R E E ! V J U N 1 1998 Shirley Detloff,Mayor C c; each City of Huntington Beach CiTy Courcii Office 2000 Main Street Huntington Beach, CA 92649 ItUT Dear Mayor Detloff: We understand that Shea Homes wants to build two hundred units on the acreage on the old Metropolitan Water District land below the Bolsa Chica Mesa. Please determine if the following questions have been fully and adequately answered S&RM-1 before any development is allowed to proceed: How will such development affect the ecological reserve and the mesa? Have traffic issues been fully addressed? S&RM-2 Has the water supply issue been resolved? , S&RM-3 Is the Bolsa Chica area going to be eaten up piecemeal? S&RM-4 Sincerely, Samuel and Rose Moreno 30 ve L a-r-- 1998 CRR-1 L , CRR-2 r � 31 Nancy Bucciarelli, MD 6695 Pageant Drive Huntington Beach, CA 92648 C !� May 28, 1998 Jim Barnes, Planner J U M 2 1998 City of Huntington Beach _ .. ,_,„ OF 2000 Main Street Huntington Beach, CA 92648 Mr. Barnes: I have recently been informed of the proposed development of Shea homes to build 200 units on 49 acres of the Bolsa Chica lowlands. I believe this development is detrimental to the wetlands and mesa. Suburban living will be an extreme stress on the environmentally fragile ecosystem of the wetlands and mesa. This area cannot handle the 200 plus families with todays NBA of living including multiple automobiles, manicured lawns, pesticides, fertilizers, pets, large stucco houses with massive cement walls and hardscape. Water use will be extreme. Traffic and road development into the mesa will annihilate the wildlife. I beg you to stop this massive development. It is naive to believe this will not destroy Bolsa Chica. We must protect our last and only precious resource remaining in Huntington Beach. You know it is the right thing to do. Si cerely, ivancv 3 T iarelli, MD 32 Jim Barnes May 28, 1998 Planning ' _> City of Huntington Beach 2000 Main Street Ulf � Huntington Beach, CA, 92648 1000 RE: Bolsa Chica Mesa, Coastal Communities Developme"ii?`f Bolsa Chica Lowlands, Shea Development Dear Jim, The Bolsa Chica Mesa, Wetlands and Lowlands are three parts of the same TRA' ecological habitat and should be preserved as "one". I I was led to believe a hearing was scheduled for mid-June to review the plans' to build homes on the mesa. Now, we see fence going up and understand a TR-2 firm by the name of California Coastal Communities (formerly the Koll Company) plans to build 21 homes on 7 acres. This cannot happen! Furthermore, we see that Shea plans to build 200 units on the 49 acres in the area of the Bolsa Chica lowlands. Living near this area, I can tell you that !TR-3 you will frequently find standing water on this land. If it was left untilled it would definitely qualify as a wetlands. Who did the Environmental Impact Report on this land? It is hard to believe I TR-4 all factors relating to impact on this area were thoroughly considered. Look at what we have already done to threaten the wildlife in this wonderful open area, one of the few readily accessible to thousands of children. TR-5 Please stop the development on the Bolsa Chica Mesa and adjacent lowlands. We need your support! Sincerely, Timothy Roberts Resident 4791 Curtis Circle Huntington Beach 92649 33 BOARD OF DIRECTORS May 20, 1998 j i!tJ 2 1998 Sarah L.Catz Chairman ce i`11 ,nomasW Wilson Jim Barnes Vice-Chairman Laurann Cook Community Development Department Director City of Huntington Beach Tom Daly 2000 Main Street Director Huntington Beach, CA 92648 Miguel Pulido Director Charles V.Smith Subject: Draft EIR 97-2 for the Shea Homes Parkside Estates Director Subdivision Todd Spitzer Director lMlliam G.Steiner Director Dear Mr. Barnes: Robert P Wahlstrom Director The Orange County Transportation Authority (OCTA) has reviewed the Plans Michael Ward for the Shea homes Parkside Estates Subdivision (EIR No. 97-2) . OCTA hasl Director no comment on the project at this time. IOCTA- Susan Withrow I 1 Director We appreciate the opportunity to provide input on this project. If you have any! Mike McManus further questions please call Neil young at 714/560-5988. Governor's Ex-Oflicio Member Arthur C.Brown Alternate Sincerely James W.Silva Alternate Gregory T. Winterbottom Alternate Kia Mortazavi Manager, Planning and Programming Orange County Transportation Authority 550 South Main Street/P.O.Box 14184/Orange/California 92863-1584/(714)560-OCTA(6282) 34 Mary Jane Wiley 6192 Moonfield Drive Huntington Beach, CA 92648R May 30, 1998 JUN log$ DEPAR;s" COMMUNITY EVE—'— Jim Barnes, Project Planner City of Huntington Beach Dept. of community Development 2000 Main Street, Huntington Beach, CA 92648 Dear Mr. Barnes, Enclosed, please find comments on the Draft EIR on the Parkside Estates Subdivision. Sincerely, Mary Jane Wiley SHEA DEVELOPMENT A discrepancy appears in elevation numbers. Project Summary states 7.4 feet elevation near East Garden Grove Channel (4-5 feet change) This elevation change from the existing property on Kenilworth. MJW-1 NOP states 9.5 feet elevation change near East Garden grove Channel (2-3 feet change) from the existing property on Kenilworth. How do you calculate"Average" elevation, and how does it apply in this case? Traffic Study for Graham Street-June 1997 by Darnell and Assoc. For this traffic report Average Daily Traffic(ADT) was gathered in 1996. Daily traffic volumes were collected on Graham Street and Warner Avenue from the Bolsa Chica MJW-2 Traffic Study of 1994. Do these figures reflect today's traffic with the added Holly- f Seacliffand Seapoint Developments? Project generates 2,496 car trips a day. 208 units @ 12 trips per unit. Following Tables give incorrect figures compromising the Level of Service grade. Table H 5-69 Average Daily Traffic is 2,496 MJW-3 Table G 5-66 Existing ADT is 7,200. - Existing+project=8,200. Total should be 9,696.� The report gives their volume to capacity ratio as .63 or Level of Service B. How was this calculated? Page 5-74 Using the Caltrans Highway Design Manual, corner sight distance for the 45 mph road is approximately 500 feet. This distance is measured from a 3.5' height at the location of the driver on the minor road to a 4.25' object height in the center of the MJW-4 approaching lane of the major road. Based on existing topography, the 500'; of corner site distance at"A" Street was not attainable. This is considered a project-specific impact. Please give specifics on the"impact." i Parkin Page 5-75 Since the project is providing an excess of 66 spaces, no parking impacts are anticipated. - Map #1 Shows four homes sharing one common driveway. How does this impact City MJW'S emergency services? Map#2 Park Site has no off street parking for the park. With one access out of the project, and a traffic light at"A' Street, AM traffic will back up into the project causing a proliferation of exhaust fumes to rise into the homes while MJW-6 vehicles sit there waiting for light to change. How will this problem be mitigated? Southbound traffic on Graham at Warner using the proposed exclusive right hand turn:IMJW-7 Where is the pictorial representation of the intersection? LIMA- Tw- !� • - - ... � ` •-•� �o� �. ',.r�...M�i , ram\ . O.P. � AMR Pool, y� bt. �� .:.•• �. J.� ': IWIV .e \ \\ `� � .�;% � ` ��q►�.'�fit. �\ � \ lit NIS .i RNM , �!'� �ax Kj ��i 1'f - �I (, �� � fit• ,�'�� �, ;`\v mom wip Ills, �� ~"',I�cr+�`►� ,� � PWk. ' ' IV' VIN rVIP 1PC�F16 ��►� Via.. . AN 1131 ''��r�� k� :� ►�,[rl��QS���� ,\\\ram ����*�\; �\• \ ig, UMT %- A Lt 5 7 .I,; +�yj �. '� . ,�,��,�,� +✓may;,.-. �� ;'�i;�tj���\, .\ \\ PC *RN kill purr —P4 I mmo UNA OW G •� � � /� � .�' +�#++:..may\ '��,.'V� 3ar?7,es FIR"r•er Alot6v reX l/y! TIZpw o �tea✓���, LS A Y "s. // `' �ev+�o� �� /50Zs 41l ea t 7 0 7e4,.,n _ w�/c�,� ydu eve,. fib, ►c h �bu1J " '`Y/ t-o vr _ uf ./'r Ia6Gls 7 �'�t RN-1 1f2 rs Gre . cflealrAR � Pe r 4z GGtS C-04-f,'/ Cap^+ r ss.cam. Y',wi r�,-.tea, RN-2 yz-�f- $�fi1�RcT ri�r lvy+s�.-r. I I Ae 51 bw xow- �Yo S/c is-�._ �,L� /;,/efl;ll -do luT pin.7�t�-lG:r� '�t.�.Gc �Cf7`rccGffvG � C��Ytl�Q-��f"D�oSQ.�S. ^� w t ll R. A� -eG/�fic� 'h v?- Oh b� 4k, RN-3 re ver- Ce-re� Co a n'; WGJ r mG� NEUWIRTH 1640 PASADENA GLEN RD. PASADENA,CA 91107 rc,, Y 1 Z.ar��. � S h o t,.rnG..- e_ C� r(e, L"` YVC fi r ve- Tom-- V,,:� c 1 f� reSc re e 36 City of Huntington Beach s N 2000 MAIN STREET CALIFORNIA 92SU DEPARTMENT OF COMMUNITY DEVELOPMENT Building 536-S241 a "' Planning 536.5271 J U y 1998 May 19, 1998 _ TO: INTERESTED PARTIES C`'"yyV; y;Tr RE: DRAFT ENVIRONMENTAL IMPACT REPORT NO. 97-2 - NOTICE OF AVAILABILITY AND EXTENSION OF REVIEW PERIOD TO 60 DAYS The City of Huntington Beach is the Lead Agency and has prepared a Draft Environmental Impact Report(EIR)for the proposed Shea Homes residential project generally described below. Potential environmental effects identified within the Draft EIR relate to the following issues: Land Use Compatibility, Aesthetics/Light and Glare, Transportation/Circulation, Air Quality, Noise, Earth Resources, Drainage/Hydrology, Biological Resources, Cultural Resources, and Public Services and Utilities. A detailed project description, location,and the probable environmental effects are contained in the EIR on file at the City of Huntington Beach and Central Park Library. We need to know the views of responsible agencies and other interested parties as to the scope and content of the environmental information contained within the above referenced document. Due to the time limits mandated by State Law, your response must be sent at the earliest possible date, but not later than 60 days after initiation of the public comment period by the State Clearinghouse. The State Clearinghouse began the public comment period on Friday, April 17, 1998. The original 45-day review period has been extended to 60 days by a vote of the City Council of Huntington Beach; comments on the Draft EIR are due by June 15, 1998 in writing to Jim Barnes at the City of Huntington Beach Community Development Department at 2000 Main Street,Huntington Beach,CA 92648. Proiect Title: Parkside Estates Subdivision Project Description: A proposal to develop 208 single family residential homes on a 50t acre site. Proiect Location: The project site is located west of Graham Street and south of Kenilworth Drive. Project Applicant: Shea Homes,603 S.Valencia Avenue,Brea,CA 92823 For further information lease contact: Jim Barnes, Project Planner City of Huntington Beach Department of Community Developmen 2000 Main Street JMA 1 Huntington Beach,CA 92648 City of Auntington Be h Cit f f Huntmgton Beach Office of the City Clerk Department of Community Development 2000 Main Street,2nd Floor 2000 Main Street,3rd Floor Huntington Beach, CA 92648 Huntington Beach, CA 92648 (714) 536-5227 (714) 536-5271 Central Library 7111 Talbert Avenue Huntington Beach, CA 92648 (714) 842-4481 37 Marinka Horack 21742 Fairlane Circle Huntington Beach, CA 92646 May 28, 1998 Jim Barnes, Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Barnes: This is to express my alarm and objection to the proposed Shea housing project at the Bolsa Chica lowlands next to the Wintersberg Flood Control Channel. IMHa-I The following are reasons why this project must be rejected: • Huntington Beach is built out and paved over almost completely. • We have not even begun to experience the massive impact of the tens of thousands of new Sea Cliff residents who will be moving into our city. The MHa-2 controversy over the Edwards Street & Talbert signal is only the beginning of i the traffic mess we will live with every day due to too many people. • House cats from the proposed project would cause havoc on the endangered!MHa-3 birds of the wetlands. • The archeological value of the site would be destroyed by the project. I MHa-4 • Canada geese stop over at the site. It is a migration stop on the Pacific ,MHa-5 Flyway. There is good evidence that this site has been a wetlands. • The existing Bolsa Chica wetlands and the wetlands area that will be restored will be one of the most important coastal wetlands of California. It must be MHa-6 protected from the toxic urban runoff that this project would produce. • Water is limited in supply more and more. The city cannot provide unlimited MHa-7 amounts of water. • The proposed traffic plan is unsafe and adds more cars to an already over- . used and pot-holed road system. IMHa-8 • The city's infrastructure needs to be rebuilt. It can not handle any more MHa-9 population needs. • All the other services that the city provides are stressed. The needs of the current citizens come first. Planning must give high priority to quality of life oflMHa-10 the whole city. i Thank you for your time and consideration. Sincerely, Marinka Horack R MONDAY, MAY 4, 1998 LOS ANGELES TIMES EDITORIALS I CC 00, 1-0 040 1949 FL yr �IGA.o MARK H. WILLES, Publisher D O N A L D F. W R I G H T, President and Chief Erecutive O cer M I C H A E L P A R K S, Editor and Senior Vice President J A N ET C LA Y T O N, Editor of the Editorial Pages and Vice President Saving Our heritage is fast vanishing; lawmakers must act s budget-writing time approaches in million in budget investments that should be Sacramento, the interest groups are considered a modest additional commitment to getting out their wish lists for a slice of a the environment this year. Most of the money surplus that could run to $2 billion or more. would go to one-time projects that would not Before lawmakers divvy up the bounty, how- bind the state to additional spending in future ever, they should give special priority to the years. This is a prudent course since the state environment. legislative analyst does not expect budget sur- California resource and environmental pro- pluses to last beyond this year. tection programs have suffered at the budget A coalition of envi bnmental groups has table the past decade as pressures built for urged lawmakers to a ocate at least $100 mil- spending restraint and as the lion to he Wildlife Conservation i ioi1 siashed revenues. Now California resource and Board for purchase of critical is the time to begin to catch up. environmental protection natural areas, $65 million more In the state Parks and Recre- ro have suffered than Strom-Martin's proposal. ation Department alone there is a programs ered The $100 million would not be $500-million backlog of deferred at the budget table the unreasonable if the budget sur- maintenance and construction. past decade. Now is the plus runs toward the high side of The California Coastal Conser- time to begin to catch up. current expectations. vancy needs more than $500 The cost of land escalates from million for access and restoration year to year and some important of wetlands, riparian habitat and other projects. properties—such as the link between Chino The Santa Monica Mountains Conservancy is Hills State Park and the Cleveland National behind by more than $300 million. Forest—may be lost forever if they are not The state also lags in its commitment to local bought soon. flood control projects, the acquisition of wildlife These are pieces of California's natural heri- habitat and recreation lands by the Wildlife tage that are impossibl a to replace. They benefit Conservation Board and funds for urban river all interests: urban, - '. the economic, water parkways and open space. The story of unmet quality, the wildlife waterfowl and access needs is repeated throughout the budget. for all to the best o is left of natural Cali- - - "" P ----- 'TTT- --- ,. C.,+,,..n i+rnw n«n+inn0 LOS ANGELES TIMES B8 R MONDAY, MAY 11, 1998 p Open S ace ■ Re "Saving Natural California," editorial, May 4: I'm a native Cali- fornian and love this state with a passion, because there is- so much special and wonderful here. But the saddest and most frustrating thing has been the wholesale disappear- ance of exquisite natural country- side and farmland in county after county. Your editorial rightly points out that feverish urban development will consume the remaining beauty of this state, unless something on a large scale is done to prevent it. The Legislature must break free of the grip of big-developer inter- ests. Our children, grandchildren— everyone—need to experience nat- ural beauty for their well-being and for their souls' renewal. The state needs to allocate large sums of revenue to buy threatened scenic areas; and the counties coordinating with the Legislature must devise comprehensive zoning maps and ordinances with the intention of creating buffer zones of protected natural landscape and farmlands between urbanl' reas. WALTER R. DOMINGUEZ Los Angeles 38 - - • • :- . � . _ ..; • • : - — 111 - - • • :- • .• : � - • - �. � � L _ .. Y3Ji� SGtr�l�;,C 4 � � .e�` � -1�!is Y 2 k.: 'tF 7a2'T' t_ Rom."^YSc .. �: �• . !' K Y.a-`d ,j ..w sl e'c' �♦ f�� t r I r L .art `>/.r Z^• � 'f,.'. ,• 7 >.1,1 Y, C._ � j�ttc js. ^�,�r n'�i,2•i��. yry t � �3 r�"•i _ 5 � s4�, r. t '�:� .r.A�'5y •��k�,�s. M�qT .�•��r. �>.F" r:i �;+1.+ > �• s. •_ . .Y�� s %� _:;'''���4 '`�' V. tar R`�✓..Tx � �� r- ��x r. :^yt i.. >r� �� i '�•c. r "•;—�c'S 1C i•,� 7 T: k � -:,! �R i � 1 •c • - � , S 4 r �, L �`l 1 — i _ :.— .. _ s� _ - \ \ _ ' f � f � — I�_;sue_- � - �� } ,Z �^-'�`�7' � �Fi��� >:+. :: `'•yr x,;<< _ . . t ::y::•',,, -..S_iY';fi` � t y' 1.a.�:'s.;. 39 Jody L. Graham 5151 Skylark Drive, Huntington Beach, CA 92649 Home Telephone: (714)894-9792 June 3, 1998 Jay 5 1Q�S Jim Barnes, Planner cc`' City of Huntington Beach Ft�T 2000 Main Street Huntington Beach, CA 92648 Dear Mr. Barnes: I wish to comment on the EIR (#97-2) filed by Shea Homes in regards to their plan to build on 49 acres of the Bolsa Chica Lowlands. As a Huntington Beach resident and frequent visitor to the Bolsa Chica Wetlands, I take issue with several aspects of the EIR. First, the EIR does not address possible impacts on the wildlife in the area surrounding the 49 JLG-1'` acres. The surrounding area includes the Ecological Reserve and the mesa, both home to many wildlife species, some of them endangered. The 200 housing units, and the dogs and cats that come along with the human inhabitants, would certainly have a negative impact on the surrounding environment. The EIR also states that the 49-acre area contains no wetlands, a falsehood that is obvious to anyone who is familiar with the area. If there are currently no wetland plants in the area, as stated in the EIR, it is simply due to the fact that the plot has been repeatedly plowed and needs time to JLG-2 recover its native vegetation. The proposed project would also have a negative impact on city residents due to poor traffic planning, and no acceptable alternatives have been proposed. In my opinion, Huntington Beach will be a much less pleasant place to live if this project is approved. The wildlife species with whom we are fortunate enough to share our environment are deserve protection, and further encroachment on their habitat is unacceptable and irresponsible. JLG-3 Please help keep Huntington Beach a city in which responsible people can be proud to live. Thank you very much for your time and consideration. Sincerely, Jody L. Graham cc: City Council members 40 �,L,TE GF CAUFORNIA Pm wn SON.Coor mar CALIFORNIA STATE EXECUTIVE OFFICE LANDS COMMISSION s 100 Howe Avenue,Suite 100-South Sacramento,CA 95825-8202 GRAY DAVIS,Lieutenant Governor ROBERT C.HIGHT,Executive Officer (916) 574-1800 Fax(916) 574-1810 KATHLEEN CONNELL,Controller California Relay Service from TDD Phone 1-800-735-2922 CRAIG L. BROWN,Director of Finance —_ _ fnm voice Phone 1-800-735-2929 June 1, 1998 File Ref.: W 9997.216 Ms. Maureen Gorsen Project Coordinator The Resources Agency 1020 Ninth Street, Third Floor U U f J 1 S Sacramento, CA 95814 Attention: Nadell Gayou - CC.',... v -;4T Mr. Jim Barnes, Project Planner City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 Dear Ms. Gorsen and Mr. Barnes: The staff of the California State Lands Commission (CSLC) has reviewed the City of Huntington Beach (City) Draft Environmental Impact Report (DEIR) for the Parkside Estates EIR#92-2 project and offer the following comments and questions. The following comments are divided into three sections: Jurisdictional Comments, General Comments, and Specific Comments. Jurisdictional Comments CSLC-1 The CSLC holds title to the 880 acres of the Bolsa Chica Lowlands that are the subject of comprehensive restoration, Bolsa Chica Wetlands Restoration Project (BCVJRP), sponsored by the CSLC, the State Department of Fish and Game, the State's Resources Agency, the State Coastal Conservancy, the U.S. Fish and Wildlife Service, the National Marine Fisheries Service, the U.S. Army Corps of Engineers and US EPA. The CSLC and its partners are particularly concerned with any project which could have adverse direct or indirect impacts on the restoration of the Bolsa Chica Lowlands. General Comments Throughout the document, the City either does not recognize or minimizes the potential impact the proposed project may have on the BCWRP. The BCWRP area is < 100 yards south CSLC-2 and west of the project site. Ms. Maureen Gorsen Mr. Jim Barnes June 1, 1998 Page Two Based on the project's proximity to the BCWRP area, CSLC staff believes it is critical that this DEIR fully evaluate the potential impacts the Parkside Estates Subdivision project may have on the long term success of the restoration effort scheduled to begin in 1999. For example, the DEIR should evaluate: impacts on water quality within the wetlands due to CSLC-2 changes in storm-water runoff(both quantity and quality); (Cont.) g q y q ty); impacts of increased air pollution and non-point source pollution from landscaping methods (lawnmowers, leaf blowers, application of pesticides and fertilizers, etc.), vehicle emissions, oil and other chemical leaks, and roads, etc.; and the potential for non-indigenous plant and animal species that may become introduced in or affect the wetlands. Additionally, for every significant impact identified in the DEIR, the City should identify and discuss mitigation measures. Detailed information about project effects, as well as their respective mitigation measures, must be provided. Such mitigation measures need to be specific, feasible actions that will improve adverse environmental conditions. Furthermore, mitigation measures should be measurable to allow monitoring of their implementation. Due to the insufficient detail of the proposed mitigation measures, a thorough evaluation of the CSLC-3 Project and its impacts on surrounding natural resources is difficult. Based on the information in the DEIR, the project site has been designated for development of residential uses and is therefore consistent with the City Land Use Plan. This does not, however, diminish the potential impacts the project will have on the area. Specific Comments Page 3-29. The October 16, 1997, letter from U. S. Fish and Wildlife Service (USFWS) to the City of Huntington Beach does not appear to support the statement made in paragraph three on Page 3-29. The USFWS did not suggest that the property was excluded from wetland CSLC-4 jurisdiction; rather the Service appears to believe the issues of wetland function, jurisdiction and allowable use require a thorough and accurate coverage in this Draft EIR which is not present. Page 3-34. The CSLC should be included as an agency that has an interest in the environmental impacts of this Project. The Bolsa Chica Lowlands Restoration Project is either immediately adjacent to the proposed development or directly across the East Garden Grove-Wintersburg Channel. For example, 24.5 acres of wetlands, currently owned by MWD and Bolsa Chica CSLC-5 Land Trust that will be included in the restoration project, are directly west of the development, while 880 acres of wetlands are located south of the proposed development, across the Wintersburg Channel. Ms. Maureen Gorsen Mr. Jim Barnes June 1, 1998 Page Three Page 4-3 - Item 6. Please update this section to include the additional 24.5 acres of land, currently owned by MWD and Bolsa Chica Lowland Trust, which will be included in the wetlands restoration CSLC-6 program. This parcel of land lies immediately west of the proposed project site and east of Bolsa Chica Mesa. Page 5-2 - Surrounding Land Uses. The land immediately west of the 4.5 acre County parcel is intended to be included in the Wetlands Restoration Program for the Bolsa Chica Lowlands. Please include this CSLC-7 information in this section. Page 5-27 - Paragraph 5. The sentence reads, in part, "The project does not propose cul-de-sacs,. " yet, cul-de- sacs are clearly evident on Exhibit 5, Section 3.0. Please clarify this discrepancy. CSLC-8 Pages 5-29, 5-30. Please explain how the proposed Project will protect and preserve significant habitats including the Bolsa Chica Wetlands, conserve the natural environment and resources of surrounding lands, and maintain the visual quality of the area, thereby resulting in no conflictsCSLC-9 or inconsistencies with the Environmental Resources/Conservation Element. 5.2 Aesthetics/Light and Glare Site-Photos in the DEIR do not provide reviewers with the ability to evaluate how the area will look once the development is built out. It would be helpful if the DEIR displayed how CSLC-10 the surrounding neighborhoods and open space users would view the development. Please include new site-photos that accurately display this perspective. Cumulative Impacts. Again, the project proponents dismiss the concerns of the public regarding this project by stating that, ". .this project is an infill project within the City. . is designated as RL-7... CSLC-11 Therefore, . . the cumulative impacts . . are less than significant." 5.4 Air Quality Short-Term Impacts Please provide a more detailed description of the types and number of vehicles, the CSLC-12 hours these vehicles will be in operation, the emissions of the vehicles, etc. Please Ms. Maureen Gorsen Mr. Jim Barnes June 1, 1998 Page Four also provide a detailed description of assumptions used in calculating short-term emissions for CSLC-12 the project. Assumptions are not stated in the Air Quality section of the DEIR nor are they detailed in Appendix D, Volume I of the DEIR. (Cont.) Page 5-96. Table O appears to have several inconsistencies/errors regarding SCAQMD threshhold values. For example, the data presented on Page 5-93 displays values for construction CSLC-13 emissions in tons/quarter, yet Table O utilizes pounds/day. Please correct this table to allow a full evaluation of emission impacts. 5.7 Drainage/Hydrology Please clarify if the project proponents will be upgrading the East Garden Grove- Wintersburg Channel. If so, how? The DEIR discusses upgrading the Graham Street system, CSLC-14 but it is not clear from the document how this will prevent continued flooding of the East Garden Grove-Wintersburg Channel. What is the existing water quality of the area? This information is not provided in the DEIR. In fact, the Water Quality section lacks substantive information that would aid in the CSLC-16 evaluation of this Project's impacts on the surrounding water quality, most importantly the Bolsa Chica Wetlands Restoration Project. Water Quality-Mitigation Measures 2 &3. Please provide a detailed description of measures to be implemented, how they will be CSLC-16 monitored and by whom. 5.8 Biological Resources. The DEIR takes a narrow focus when addressing the project's impacts to Biological Resources. This focus suggests that changes within the proposed project site do not or will not CSLC-17 have any potential impact on biological resources found as close as 100 yards away. Generally, biological resources do not acknowledge the artificial boundaries. Page 5-161 Mitigation Measure #2. Please provide details regarding mitigation measure #2. The 880 acres of Bolsa Chica Wetlands were purchased by the State of California in February 1997, with the intention of restoring the wetlands. Have the project proponents approached the California State Lands CSLC-18 Commission regarding their intentions? Ms. Maureen Gorsen Mr. Jim Barnes June 1, 1998 Page Five Thank you for the opportunity to comment. If you have any questions, please contact me at the above address, by telephone at (916) 574-1880 or by Facsimile at (916) 574-1885. CSLC=19 Sincerely, � u Dwight . Sanders Chief, Division of Environmental Planning and Management cc: Robert C. Hight Members, Bolsa Chica Wetlands Steering Committee Mary Griggs Maurya Falkner OPR 41 uN 3 1��3 �e.a� /�11 t• �c�vnea j tz to I a4lYj CC-),L vP12•cr_ c t t ccpetarr � z.e urz BLM-1 _.. 6n lam: . �ie-z.iJ. Z, Lrz u-e �' Nc to WLZwT:c,>,7 U. G/ J -ChA �IiW L�`o-(, ? Vvt.u ¢. � BLM-2 ceval2,9 ok&WK4 4,") P,�LA P/Z,�vw Ghee_- CLI-1170, 641 G' -��, BLM-3 L� 42 -J C mmenr- on Parkside Estates Draft EIR Repor' it o. 9 i-2 Submitted by Mr. & Mrs. Sing Joe Kong C# 5402 Kenilworth Dr. pp ✓G � Huntinton Beach, CA 92649 ��, c, y +�� :Tune 6, 1398 VGtiS 49 , ToE9 Mr. .Jim Barnes, Project Planner F p City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 The draft EIR addressed eleven ( 11) issues which are deemed important to both the city of Huntington Beach and residents in the area affected by the proposed Shea Home development. These issues were summarized in Table B, along with the resulting impacts. Mitigating measures for these impacts were identified In all, there were 56 measures identified: ( 1) for Land Use, (7) for aesthetics and Light/Glare. ( 5) for Transportation/Circulation, (8) for Air Quality, (3) for Noise, (6) for Earth Resources, (3) for Drain/Hydrology, (2) for Biological Resources, (3) for Cultural Resources, and finally ( 18) SJK-1 for Public Services & Utilities. The compilation of these figures indicates that almost one-third of the identified mitigation measures ( 32%) is devoted to Public Services & Utilities, with only 3% and 5% to Drain/Hydrology and Transportation/Circulation respectively. We understand why the emphasis is placed on the Public Services & Utilities because they are important issues and key considerations for the efficient running of the city of Huntington Beach. But we are at a loss as to the seemingly light-handed considerations given to the drainage and traffic issues which are of immediate concerns to us. Following are our comments with our immediate concerns in mind: * On page 3-14. 4th. paragraph. it was stated that " it was proposed (by the developer) the existing wall to be removed The wall in question is the block wall in our backyard defining our property boundary in the back. We paid for the installation of the wall when we bought our house thirty-two years ago. Can someone just come around and tear it down jusf because someone decides to build on the property adjacent to it? If and when the permission to build were granted, how long would take the developer to tear down the wall, to SJK-2 dewater the soil, to replace the soft peat with a more solid soil substitue, to compact the new soil , and to build the retaining and the block wall? While the foregoing activities are going on, our entire house in the back will be totally exposed. What kind of security measures are taken to protect us from any outside intrusion? Who is responsible for assuring our safe environment? What will happen to our cinder blocks when they are torn down? Will they be reused, or scrapped? How are we to be compensated? ghat about our plants, shrubs. and trees near to the wall . which will be seriousiy affected by the new wall construction': Surely, careful considerations must be riven to all these questions. * On page 5-84. the 'report implies that by installing a traffic light at the intersection of Graham and "A" Street, the significant impact of the additional traffic created by the new development will be mitigated to the point that the impact becomes insignificant. It is very odd that no mention was made with regard to the additional traffic problem faced by the residents of our tract who choose to egress to Graham from Kenilworth or Pendleton. Currently. during the rush hours between 7 : 15 and 8: 45 in the morning, and between 4:00 and 6 : 00 in the afternoon, traffic is so heavy on Graham, thaf we are literally taking our lives in our own hands trying to enter into the north bound traffic. By adding a traffic signal at "A" Street will not relieve the traffic congestion. SJK-3 On the contrary, it will make life a lot more miserable for US. When the light is green for -the "A" Street motorists, we can picture cars from the 208 homes streaming unmercifully down Graham toward Warner. The same situation exists when the light turns red against the "A" Street traffic, because, now the traffic on the south side of the East Garden drove/ Winterberg channel bridge which has been building up due to tse light at "A" Street will be so heavy that it is impossible for us to venture into Graham. And no amount of lane adding or re-striping can alleviate this situation. The developer , therefore, must seriously consider an alternative whereby the Shea Homes traffic, in addition to "A" , will enter Bolsa Chica Street from the western end of their tract. * On page 138-141, there were many statements made concerning results of a hydrology study. We know next to nothing on the subject, but we can not help noticing the following which might require additional clarification in the EIR. # Flooding: ( based on 100 year rain ) The calculated flow rates of-- Area 1 = 77. 3 cfs Areas 2, 3 &4 = 405. 5 cfs Areas 1 thru4= 482. 8* ( * EIR No. was 472. 5 ) Proposed Site= 126. 1 cfs Total = 608. 9** ( ** EIR No. was 598. 6 It was further stated that to mitigate the flooding SJK-4 condition, only one additional pump, which was goted as being capable to deliver 147 cfs, was adequate to handle the added volume due to the new development. We do not know how many pumps are being used in the Slater Pump Station, let us just assume that three pumps are in use with a total capacity of 3x147 or 441 cfs. Comparing this capacity to the summed rates for Areas 1, 2, 3,&4 of 482. 8, the current pump configuration certainly is under capacity. We summized that this might be the reason for the statemant made in the report that the pump(s) are not adequate to handle existing run-off " . In several meetings hosted by the city, the EIR preparer, and the developer. statements were made to the effect that because of Shea Homes, and their proposed drainage system construction, the flooding. prevention would be improved. We cannot see how th6 is conceivable. Therefore. we feel that i,larificarion is in order. ISJK-4 (cont) On page 5-138, a statement was made that "the length of time and the channel would exceed its existing banks varies with location. but the longest time is about 2 1,-2 hours" . Does this mean that our home will be under this threat of flooding for this duration? It was also stated that a total of about 52 acre feet SJK-5 of water will acruallv overtop the north side of the East warden Grove-Winterberg Channel. It would appear, that this amount will overflow into the now vacant land of the proposed Shea Homes site. Was this 52 AF factored into the determination of the reported cumulative flow rate of 598. 6 cfs ? * On page 5-140, 1st. bullet: "With all of the area north of this point taken out of the existing Graham St. drainage system, this area should experience a reduction of flood occurrence. " Questions : What "point"? SJK-6 How is it taken out? and to where? The foregoing sumerizes our concerns with regard to the impact of the proposed development on us. Your careful consideration in the matters brought forth will be greatly appreciated. Mr. & Mrs. Sing Joe Kong/ cc: Councilman Tom Harman Doug Stewart 43 ✓(/� sine 871998 Mr.Jim Barnes,Planner 10 �J City of Huntington Beach CCM4004—i j ^ 1998 2000 Main Street Ucb`T Huntington Beach,CA 92648 �lij P (714) 536-5271 0164f, RE: EIR#97-2 - Shea and the Koll Company plans for two building sites Dear Mr.Barnes: I respectfully request that the City of Huntington Beach reconsider the above actions in addition to the weL' intentioned but inadequate and inaccurate Environmental Impact Report#97-2. I'm sure you STA have received many requests such as mine,and I implore you to take these pleas as seriously as you would your personal desire for clean air,water and unpolluted food for yourself and your family. You are undoubtedly aware that the Bolsa Chica wetlands is one of the last remaining wetlands in Southern California. If you are familiar with the geographic area,this is an appalling statement considering that the size of our wetlands has already been reduced due to development. All of the ST-2 habitat that is currently undeveloped desperately needs to be protected in order to support the precio little that remains of natural flora and resulting native inhabitants including many migrating birds. Much has been said regarding this issue. Much has been repeated regarding this issue. Much still needs to be done regarding this issue The EIR is inadequate,inaccurate and misleading. The Bolsa Chica lowlands must be given time to recover from current misuse in order to achieve an accurate determination as to it's correct status and importance as a Wetland area. The wetlands survival depends on ALL the land that remains. ST-3 Please,please give this time and due consideration. Please,please show the integrity of stewardship that will benefit all of us. I very much appreciate your consideration of my input. Thank you. Sincerely, S mp 1 871 D Ile Circle Hun gton Beach,CA 92648 E-mail address: theloft@gte.net cc: Mayor Shirley Detloff Council:Ralph Bauer,Dave Garafalo,Tom Harman,Dave Sullivan,Peter Green,Pam Julian 44 FCC: - .. .. . J uff 1 1 DEPARTML ----- -- -- --_---- COMMUNITY DE-v�_ -.._ _.._ ---- fin_-yam✓ � ,� --- _ . _ 14 --- `i�- w If-S-1Z. - p WM-1 - --.. _..----------- - ----- -- !ram - �_ _�- - - __ _ ----�- -^ Q _ _ � WM-2 - -------- Z_=Z 1�1 9-WM C>ff -Illy -wm 45 June 3, 1998 Jim Barnes, Planner .tau JUrJ City of Huntington Beach 2000 Main Street Huntington Beach CA 92648 ". ""ly I am a Huntington Beach resident, property owner and tax payer. I understand that Shea Homes wants to build 200 units on 49 acres of the Bolsa Chica lowlands. I have strong concerns about this development. First of all, the scope of the Environmental Impact Report is inadequate as it Mac-1 addresses impacts only to the 49 acres of development. The EIR ignores the impacts that this development would have on the wildlife in the Ecological Reserve and to the mesa. This proposed development would increase the number of hunting cats, barking dogs, increased light, etc. Secondly, the plan provides only one way in and out of the project (onto Graham Street). This is unacceptable from a safety standpoint as well as the impact on MaC-2 nearby residents. I am one of those nearby residents! In addition, the City of Huntington Beach does not have surplus water to provide water to the houses planned. I do not want my water bill to increase to fund this MaC-3 development! Finally, the EIR erroneously states that there are no wetlands on this land. During the winter months there have been weeks of standing water on the site. This is obviously not a site where homes belong. MaC-4 My morning commute past the open mesa is the highlight of my day. The Bolsa Chica Wetlands and Mesa represent the last open space on the California Coast. We must preserve this site! Please do not allow Shea Homes to build homes on the wetlands. Mary Camarillo 16192 Brent Circle Huntington Beach CA 92647 cc: Ralph Bauer Shirley Detloff(Mayor) Dave Garafalo Peter Green Tom Harman Pam Julian Dave Sullivan 46 Rldl O gwo pe E C Ell V CA qO4-e N 4 1998 WWI RW-1 �-M 1 o P , A4- v AIA - _ /IVA RW-2 RW-3 /�/N/'I^�a/►mow Y �/�� L/ /�S Ipy //(��—'• ��� �,e+�ud����,°-cu.`7 R W-4 a-Ili, . - f 4� f ,,�. - - � O ✓ �SG� i+ Jas RW-5 )Wit r- r t � *J-Z RW-5 . �' cons) r , � I���� Y• � e f ' UU /�.��1,��'�' �V�-.`'�(/n'+/ l!J`�Q-��J-�d�•,�latt,�dt�2r. I 1 4 a"It'& &ate - - R W 7 �e� C ORS--S3 A i.&AU- 1 i U4u .I i',v.�,�,�.2 C�-ORA-S�3s .O� 34 Pd., M—W-,?3S f RW-9 RW-10 M7,0 -1-W 13Oq IT !_A- r e . . 1. a () • Rw-11 r P 172� Rw-12 fu� �Q.��i ♦ • RW-13. 10 AUZU U V RW-14 • / j, , � , � 1, i � 1 ►� , � .,1. i i � 1 s 1 , A r � ► � , s r l If r / 47 A+tr.&Mrs.,lames L Denison/.;Y- {j,Wb��93^ et 1_E. 11th Stre ` r J 'il 121 N - - 5 p1W,17Xlr �� -� xm a� emu , �i,l� 1 L„�I�f�l{, ►1, 111111,t,III o„11111 rn �; s but JLD 1 A;6 i 57 JLD-2 48 s �.0. Box 3748, Huntington Beach, CA 92605-3748 (714) 897-7003 Amiggs B61sa ica June 12, 1998 Mr. Jim Barnes, Project Planner FNT City of Huntington Beach 2000 Main St., Huntington Beach, CA 92648 Dear Mr. Barnes: Thank you for the opportunity of reviewing the draft environmental impact report 97-2 on the Parkside Estates project. Our comments will be focused on the issue of Biological Resources. The greatest and long-standing concern of the Amigos de Bolsa Chica is the loss of additional wetlands in the Bolsa Chica through development. In 1989 the EPA, using criteria established at the time, found up to 8.3 acres in the city parcel of the Shea property to be wetlands. This is supported by maps dated as recently as 1935 showing the Bolsa Chica wetlands covering the entire city parcel and reaching as far north as the intersection of Warner Avenue and Graham Street. The Army Corps of Engineers subsequently removed wetlands protection from the city parcel, citing it to be prior cropland. It is unclear on what criteria the Corps based that finding, in that the analysis of aerial photographs (Section 5.8 of the DEIR) with the possible exception of the 1987 photographs, found no evidence of agricultural crops between ADBC-1 1952 and 1995. All that was observed were signs of tilling or disking, which were inferred to indicate agricultural activities, but may have simply been the results of weed abatement. In every instance, regardless of the time of vear, all that was ever observed was that the parcel was "recently tilled" , until 1991, when disking became less frequent. No definite evidence of crops were ever noted by the consultants. In addition, in their on-site inspection of the city parcel for vegetation, the consultants reported no remnants of supposed past agricultural activities. All that was noted was a long list of ruderal vegetation that is common in unused, open fields throughout Southern California. Also, little or no signs of typical wetlands habitat was observed, which is not surprising since they had been obliterated by frequent plowing over many years. Patches of Salicornia had been observed earlier in the county parcel, but even these were completely destroyed by plowing just prior to the consultants' on-site visit in 1997. Again older maps show this area also to be an extension of the Bolsa Chica wetlands, but it has suffered severe damage due to the construction of the Wintersburg flood control channel and then finally, as mentioned, complete obliteration in 1997. It is obvious that the wetlands that once thrived on the Shea property cannot be restored. Human activities on the property have resulted in the deliberate destruction of nearly 14, if not all 50 acres of wetlands. It seems to us that in keeping with the philosophy of "no net loss of wetlands" that has been expressed by all ADBC-1 levels of government, that it would be fitting to require the present landowners (Cont.) and/or past landowners to mitigate the loss of at least 14 acres of wetlands. Further, since the mitigation would be off-site, that the mitigation ratio of 4:1 be invoked, that is, at least 56 acres of coastal wetlands be restored as a condition of this development. We therefore request your response to the following question: In light of the destruction of at least 14 acres of wetlands in the Shea property by human activities, should the present or past landowners mitigate that loss through the restoration of 56 acres of coastal wetlands? Again, thank you for this opportunity of expressing our comments regarding this document. Sincerely, David Carlberg, Ph.D. President 49 ley Ij U LIMIL21on 3each ar L,Banis: 'IM -0 a ia 0 , I()N, U To-�j -W �ve - - prj-,ies e or Posed !he building Of 200 houses oil I e Bolsa C! ImIds. do not need ativ 11'�ore houses bujldL n our fra2ile. renlail=,, iica .11 00as,_ T'her�near the i3t . also -m to build anv-,N -.,roiesi cons dering the Koll's appiiemic a chica Waieau. 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Kel I en F a. o r L L cAE>P-r s o a, m e-m c • 1�- S� r1 0..� ,,, 1 C1S L 0.11Z • i W S 1 S nc>� ��S cSS LJH- P G tS- �. r t 'fC" ..�.W n 1 �'1 o t�'� / 1(8 l' ° b Y1 p S�r- LJH-9 LA (Cont) v k,r)ce r eA 5' Q Z G jest ro , l�. �G�r nQ,s , >Z q7-o Z 52 o sa =� dim- 5 1 �� COMMUNj� 1998 7rvitl�TOF L A N D T R U S T °EVELOPM�vr BOARD OF DIRECTORS NANCY DONAVEN June 15, 1998 PRESIDENT CONNIE BOARDMAN PAST PRESIDENT FLOSSIEHORGAN Jim Barnes, Project Planner CO-FOUNDER City of Huntington Beach Department of Community Development SANDY GENTS 2000 Main Street BUCK MARRS.PHD Huntington Beach, CA 92648 JUANAMUELLER Regarding: Draft Environmental Impact Report 97-2, EILEEN MURPHY Shea Homes ROCHELLE PAZANTI Dear Mr. Barnes: LYNETTE PRATT We are enclosing for your consideration a critique of the DEIR 1AYSON RUTH 97-2. This critique has received the professional input of a biologist, a geologist, an urban planner, and some other local JAN VANDERSLOOT.MD authorities. CO-FOUNDER ROBERT WINCHELL.PHD Please notice our conclusion that the Bolsa Chica Land Trust requests that "the City require a revised Draft EIr be prepared and recirculated if the project is to receive any further BCLT-1 ADVISORY COUNCIL consideration. Denial of the project does not required a SENATOR BARBARA BOXER certified EIR." RALPH BAUER. Accompanying the critique are a U. S. Coast Survey map from IMMEDIATE PAST MAYOR 1873, a series of pictures of the ponding on the Shea property HUNTINGTON BEACH near the flood control berm and a series of the ponding in the ROBERT SHELTON,(RET) middle of the property. Additionally there is a copy of the GOVERNMENT RELATIONS Metropolitan Water District sales sheet with an aerial photo of CONSULTANT the property. JANICE L.KELLOGG. CEO KELLOGG SUPPLY, INC. Sincerely, WALTER W.NEIL,DIRECTOR EXTERNAL AFFAIRS.ARCO VINCE KONTNY.(RET) Juana R. Mueller EXECUTIVE FLUOR Vice President CORPORATION Attachments: (4) LOCAL SPONSORS: GARDEN GROVE EDUCATION ASSOCIATION.HUNTINGTON BEACH CITY COUNCIL. HUNTINGTON BEACH TOMORROW.ORANGE COAST LEAGUE OF WOMEN VOTERS NATIONAL SPONSORS: THE IZAAK WALTON LEAGUE.THE NATIONAL AUDUBON SOCIETY. THE NATURE CONSERVANCY.SIERRA CLUB.SURFRIDER FOUNDATION 207 21ST STREET • HUNTINGTON BEACH • CALIFORNIA 92648 • (714) 960-9939 COMMENTS ON THE PROPOSED PARKSWE ES ATES DRAFT EIR#97-2 .q THE BOLSA CHICALAND TRUST y� 1 $$ June 15, 1998 Y�'��"�'�� The following comments address the draft EIR(DEIR)for proposed General Plan Amendment No. 98-1/Zoning Map Amendment No. 96-5/Tentative Tract Map No. 15377(City)and Tentative Tract Map No. 15419 (County)/Conditional Use Permit No. 96-90/Coastal Development Permit No. 96-18/Annexation 98-1 and a Local BCLT-2 Coastal Program Amendment No. 96-4. These comments incorporate by reference the comment letters submitted by Connie Boardman,Professor of Biology, concerning the DEIR's presentation of biological impacts, Roberts Williams concerning the DEIR's presentation of cultural resources, and those of Dr. Robert E. Winchell, geologist, concerning the DEIR's presentation of earth resources. The proposed project would result in the development of 208 single family homes and an approximately 8.2 acre park site on approximately 49 acres of land; 44.5 acres in Huntington Beach and 4.5 acres in the County proposed for annexation to the City. About 3.2 acres of the park site would be intensively developed for active park uses(the flat useable acreage). The DEIR characterizes the property as"vacant, BCLT-3 undeveloped land." DEIR at 2-1. The DEIR presents the property as insignificant from a biological standpoint. This representation of the property ignores substantial evidence that the site contains wetlands and other biological resources of significance particularly when evaluated in conjunction with the adjacent Bolsa Chica habitat areas. It is noteworthy that in 1986,the City took action to change the land use designation on most of the property from Residential to Conservation on the Coastal Element land use plan in reaction to the intensive development proposed on the adjacent Bolsa Chica property. None of the graphics in the DEIR clearly show the relationship of the project site to the Bolsa Chica property. However, it is clear that the relationship of BCLT-4 this property to the Bolsa Chica is significant. The project site is connected to approximately 200 acres of open space on the Bolsa Chica mesa. Also,the DEIR acknowledges that the County parcel is a part of the Bolsa Chica planning area. Consideration of the project site at one time as a"compensatory" open space area if the Bolsa Chica more intensively developed suggests its potential importance as open space and habitat. The entire project area,both the City and County parcels,is significant as wetlands habitat from historical and recent records. Recent photos, after last year's rainfall,indicate that naturally occurring wetlands on the City and County parcel correspond with the historic tidal wetlands shown in 1873 U.S. Coast Survey maps. No BCLT-5 evidence is provided that the soils and hydrology are no longer consistent with wetlands habitat on the parcels. A revised DEIR must be prepared which properly discloses the 1 extent of wetlands on the parcels and the relationship of the property to the adjacent BCLT-5 Bolsa Chica open space areas. (cont) It is not too late for the City to reconsider protection of a major portion of the project site for open space and habitat uses to buffer and expand upon the Bolsa BCLT-6 Chica area. Unfortunately, this DEIR fails to adequately describe the significant wetlands values of these parcels, and likewise, fails to offer any alternatives that would achieve this public benefit. The DEIR fails in other respects as well. Indeed, it is a masterful document in terms of deferring both impact analysis and mitigation measures. Moreover, it fails to identify, let alone analyze, alternatives which are capable of reducing or eliminating project-related and cumulative impacts. Most astonishing,the DEIR BCLT-7 concludes that there will be no significant adverse unavoidable impacts of the project after mitigation. The following comments set forth the defects in this DEIR and conclude with a request for the recirculation of a revised, adequate DEIR. I. THE DEIR CONTAINS AN INADEQUATE PROJECT DESCRIPTION An EIR must contain an accurate description of the project. Section 15378 of the CEQA Guidelines defines "project"as"the whole of the action, which has the potential for resulting in a physical change in the environment,directly or ultimately. . . ." An accurate and complete project description is a critical part of the EIR. If the project description is not complete and accurate,the DEIR cannot adequately BCLT- 8 disclose significant impacts and identify mitigation measures and alternatives to reduce or avoid those impacts. Nor can the public and decision-makers accurately weigh the project against feasible alternatives. In this case, the DEIR fails to describe critical components of the project. Therefore,the DEIR understates the significance of project-related and cumulative impacts. Key examples include,but are not limited to,the following: 1. The location of borrow materials to fill the site. The DEIR refers to another EIR,Certified EIR 551, for a description of the location of sites for importation of 210,000 cubic yards of dirt to raise the elevation of the site. However,this DEIR fails to summarize the conclusions of that EIR or to properly incorporate that BCLT-9 document by reference. Moreover, it is unclear from the project description whether the 470,000 cubic yards of material proposed for removal and recompaction will be balanced on site. A revised project description must provide detailed information about how much soil will be hauled off site,what will be the locations where that soil may be disposed of,how many truck trips off-site could result,what routes will be taken, and the like. 2 In addition, EIR 551 must be properly incorporated by reference if it is to be relied upon to deal with the impacts of importation of fill. EIR's may incorporate any portion of any relevant documents that are both a matter of public record and generally BCLT-9 available to the public. The EIR must summarize the contents of the incorporated (cost.) material. The incorporating materials must inform the public where the document can be reviewed. The DEIR should identify any significant impacts related to the incorporated topic in the impact summary. Finally,the impact sections should provide documentation that the fill material at the borrow sites identified meets the specifications necessary for this project. If not,alternative borrow sites must be identified. The borrow sites and BCLT- 10 potential for hauling and disposal of removed fill from the site have the potential for traffic, air quality and other significant impacts(e.g. destruction of habitat areas)which also must be analyzed in the appropriate sections of a revised DEIR. 2. The location of on-or off-site affordable units. Mitigation measures for affordable units include an option that the units could be built off-site at another Shea holding. A revised project description, or a discussion of potentially significant secondary impacts of the mitigation measure,must disclose the likely location(s)where these units could be constructed. If this information is not added to the project description,the potential off-site location(s)of the units must be disclosed in the DEIR and the impacts analyzed, either as part of the project, as a cumulative impact or as BCLT- 11 a secondary impact of the proposed mitigation measures. Clearly, other Shea ownership's where these units could be built is a known fact which can be disclosed in the DEIR. The mitigation measures link this project with a future affordable housing project in a manner which must be,at the very least, analyzed as a secondary or cumulative impact of the project. 3. A description of the construction activities and phases. The DEIR must describe the construction activities and phases including a phased breakdown of types of equipment(e.g. dewatering); duration of use; noise levels and durations; number BCLT-12 of employees and construction-related trips; construction traffic routes; and the like. In the absence of this information, project-related impacts cannot be adequately analyzed in terms of noise, air quality and traffic, among other issues. IL THE DEER CONTAINS INADEQUATE SETTING INFORMATION Also critical to the adequacy of an EIR is beginning the analysis of impacts with a complete and accurate description of the project setting,both locally and regionally. Setting information that appears to be incomplete or out-of-date includes,but is not limited to,the following: BCLT- 13 1. Recent surveys of potential wetlands and wetland habitats. The last noted wetlands surveys for the DEIR prepared by the developer's consultant were in November of 1997. Since that time, rainfall indicates where additional wetland resources naturally occur on the City parcel. These wetlands correspond to the historic tidal wetlands identified on 1873 U.S. Coast Survey maps. See attached photos illustrating an arc of wetlands from the proposed park-site across the City parcel to the Wintersburg-Channel across. This recent information raises serious doubts about the reliability of the DEIR's conclusions concerning the presence of wetlands on the City parcel. The EPA wetlands delineation of 1988 also shows wetlands on the City parcel. A revised delineation must be prepared if this site is to be further considered for BCLT-13 development. See also enclosed MWD sales information showing the current extent of (cont.) wetlands on the parcels. A more recent delineation of the County parcel should have been included in the DEIR to the extent that this site is proposed for development. The last delineation map in Appendix G, appears to show more wetlands on the County parcel than are described in the DEIR. Complete and current information about the biological resources on the two parcels is critical to decisions concerning mitigation and alternatives. The lack of current and verified information about wetlands on the County parcel renders this document inadequate to support an informed decision about the future potential for BCLT- 14 development of that site. However, since it is a part of this whole project, rather than segment the future consideration of development on the County parcel from the City parcel, a revised DEIR should be prepared which includes complete information about biological resources on both parcels. 2. Artificially narrow study area. CEQA requires that the setting be described for both the local area and the region. While the DEIR does not describe the setting study area, it appears the geographic area for evaluation of most impacts was BCLT- 15 limited to immediately adjacent to the project. This limitation fails to take in areas of cumulative impact, including the borrow areas for purposes of trips and air quality on the Bolsa Chica property,the Bolsa Chica area for purposes of biological impacts and the City and adjacent cities for traffic impacts, at a minimum. M. THE DEIR FAILS TO ADEQUATELY ANALYZE PROJECT IMPACTS In judging the legal sufficiency of the DEIR, the focus is on adequacy, completeness and good faith effort at full disclosure. The document should provide a sufficient degree of analysis to allow decision-makers to make intelligent judgements BCLT- 16 concerning the project and its impacts. A reasonable effort means that an EIR must support with rigorous analysis and substantial evidence the conclusion that the environmental impact will be insignificant. This DEIR lacks such support for most of its conclusions. Specifically, the DEIR fails to support with evidence and analysis that numerous impacts will be insignificant. First,the DEIR fails to find a number of impacts significant without any analysis, including impacts due to the loss of open space and BCLT- 17 agricultural land; impacts of the borrow sites on habitat, air quality, and related impacts; 4 aesthetic impacts associated with conversion of open space to development; and growth inducing impacts, among others. A number of impacts are found to be potentially ignificant with mitigation measures that merely defer BCLT-17 significant, but reduced to ins definition of the mitigation to a later date. Such impacts include: project inconsistency (coot.) with the City's affordable housing policy; impacts to wetlands and cumulative biological resources: impacts to flooding and water quality; impacts to air quality; among others. It should also be noted that it is difficult to tell whether impacts are considered significant because of the failure of the DEIR to clearly identify the disposition of impacts before and after mitigation. For example,the Summary Table includes numerous vague references to impact significance: • The proposed project may result in impacts to County-proposed trails. DEIR at 2-4. • Potential impacts may result from ground shaking. DEIR at 2-6. BCLT- 18 • The proposed project may result in impacts to affected species locally and regionally. DEIR at 2-7. These are the types of statements typically found in Notice of Preparation(NOP) Environmental Checklists published prior to the EIR analysis of impacts. It is not clear from Table B or the text whether these impacts are significant and the exact nature of the significant impact. For example, what is the potentially significant impact to regional species? Table B, and the text of the DEIR should be revised to include clearly worded statements of significant impact. One explanation for the lack of such clear statements is that the DEIR failed to accomplish much additional analysis since the NOP was prepared. The incomplete and conclusory impact discussions support this explanation. The following are examples of the DEIR's lack of analysis and evidence to support its conclusions regarding the significance of impacts associated with the project. A. Land Use Comnatibili This section contains numerous statements that are conclusory in nature with little or no explanatory text. The result is confusing at best and more likely misleading about potential project inconsistencies with applicable plans and policies. BUT- 19 Examples include,but are not limited to,the following: Environmental Resources/Conservation Element: The section simply concludes that the project will not result in inconsistencies with this element. There is no explanation of how developing on .2 acres of wetlands is consistent with the applicable policies of this element. Moreover,the discussion is in conflict with later statements in the biological resources section that the .2 acres have been destroyed by disking. DEIR at 5-150: 5 "Nothing remains of these patches following the most recent disking and clearing of the BCLT-19 site." Both discussions appear to conflict with the wetlands delineation map in Appendix (cost.) G. This discussion needs to be revised to explain the applicable policies and how the project is consistent or inconsistent with each policy. Bolsa Chica LCP Elements: Land Use Plan: "The proposed project may result in impacts to the LCP LUP." DEIR at 5-32. The paragraph describes that the project is within the adopted density and has been accounted for in the LUP. The paragraph concludes: "Implementation of the proposed project will not result in conflicts or inconsistencies with the applicable goals and policies of the Local Coastal Program Land Use Plan." DEIR at 5-32. There is no BCLT-20 explanation of what possible impacts could result as indicated in the leading sentence. Nor does the paragraph clearly indicate that the proposed 27 units on the County parcel are within the unit cap for the Bolsa Chica Area; a question asked in a comment on the NOP as well. This paragraph should be revised to clearly describe the impacts that may occur,their severity, and whether the units on the County property are within the Bolsa Chica unit cap. Resource Restoration and Conservation Component: The County parcel contains .2 acres of pocket wetlands, according to the DEIR. DEIR at 5-32. The site appears to contain more wetlands based on the wetlands delineation map in Appendix G and recent rainfall BCLT- 21 photographs. The DEIR discussion finds no conflicts or inconsistencies with the applicable goals and policies. Yet, plan policies require that wetlands be protected. A revised explanation of how proposed mitigation measures ensure compliance with these policies is required. Coastal Element: This element provides for protection of significant habitat areas requiring wetland enhancement and buffer in exchange for development rights; and Improvement of the aesthetic and biological quality of wetlands; among other policies. It BCLT-22 is therefore unclear how the destruction of the wetlands on this parcel is considered consistent with the policies. This discussion should be rewritten to explain how mitigation measures render wetland destruction consistent with applicable provisions of the general plan. CoasWASdarine Resources Component: Again,without any explanation or analysis,this three sentence discussion find no conflicts or inconsistencies with the LCP. There is no explanation of how the project will implement water quality management and flood BCLT-23 control policies. Explanation and analysis must be included in a revised discussion describing how the measures in the drainage/hydrology section of the DEIR result in the finding of consistency. Conclusory statements are not adequate. Each of the subsequent discussions also suffer from a lack of explanation as to how the project and/or proposed mitigation measures ensure project consistency with applicable BCLT- 24 policies related to physical resources(DEIR at 5-32);visual and scenic resources(5-33); 6 public access/visitor-serving recreation(DEIR at 5-33); and regional circulation(5-33). These discussions of land use compatibility and plan consistency must include an explanation of how proposed elements of the project and/or mitigation measures render the project consistent with applicable policies. Moreover,the section should be revised BCLT-24 to include a table that includes each applicable general plan and LCP policy and an (cont.) explanation of how the project is or is not consistent with each policy before and after mitigation. As presently set forth,the section does little more than lay out the applicable policy framework and leave the reader to determine whether the project is or is not consistent with the City's policies. The land use compatibility section concludes with a paragraph which states that the project in combination with other cumulative projects will not result in any conflicts or inconsistencies with any applicable goals or policies of the City's general BCLT- 25 plan and LCP including the following elements: Environmental Resources/Conservation; Coastal; and the Bolsa Chica Land use program. The DEIR lacks an explanation of how the cumulative projects together may impact coastal wetlands and other resources protected by policies in these element. Finally,with respect to land use impacts,there is no analysis of the impact of the loss of this property for agricultural and/or recreational (equestrian)uses. These BCLT-26 impacts should be considered significant in light of the lack of available agricultural and recreational lands in the area and the cumulative loss of these land uses in the area. Mitigation measures should be proposed for these impacts. B. Aesthetic/Light and Glare This section fails to identify as significant and unavoidable the change in the project site from vacant, open space to intensive suburban development. The discussion states this impact is not significant because the site is planned for infill BCLT- 27 housing in the City's general plan. Environmental impacts must be weighed from the existing condition. There can be no disagreement of the stark visual impact from the conversion of vacant, "open space"to dense housing. This must be identified as a significant and unavoidable impact of the project. Moreover,the section does not evaluate the impacts of the project on views from proposed adjacent regional trails. Nor is there an adequate visual analysis in the form of photo montages or simulations from key public view points (including adjacent public trail routes). The section should be revised to analyze these impacts, or BCLT- 28 demonstrate why they are not significant and unavoidable. Photo montages, or simulations of the site before and after development should be included in the revised DEIR. 7 C. Earth Resources The following is a summary of major flaws in the DEIR's presentation of earth resource impacts. See also the comment letter submitted by Dr. Robert E. Winchell, incorporated herein by reference. The property is within the Bolsa Gap which is a flood plain. Alluvial deposits on the site consist of intertidal and tidal, and peat was encountered in the upper five feet in the vicinity of the borings. DEIR at 5-120. This section further describes the upper site soils as"typically moist to wet with perched water currently present at a depth of approximately six feet below existing grade." DEIR at 5-128. There is no explanation BCLT- 29 of how these soil types and hydrologic regime do or do not meet the Coastal Commission's definition of wetlands. Nor is there adequate information concerning the source of the high groundwater table. Information concerning the depth and distribution of groundwater is incomplete and contradictory. Groundwater distribution and depth on the site are important both to the geologist for geotechnical considerations(e.g. liquifaction),but also to the biologist for wetland and resource considerations. This critical information must be included in a revised DEIR. The section also fails to adequately describe the Bolsa Fairview fault that appears from the Bolsa Chica EIR to traverse the City parcel. The presence of this fault could explain the high water table and has implications for whether there should be large BCLT- 30 setback areas from the fault for development. This section should be revised to include this information and describe any new significant impacts as a result of this information. Related to this information, a discussion of past and expected earthquake magnitude(s)associated with this site needs to be included in the DEIR. Based on this information,the discussion of potential seismic event related impacts must be expanded BCLT- 31 to include potential earthquake intensity and its associated effects as related to the site. Mitigation measures to address these likely significant impacts must be specified in the DEIR and documentation provided that the measures will be sufficient to reduce impacts to less than significant. D. Drainage/Hydrology The DEIR states that"[e]xisting runoff from the site surface drains southwest; however,there are high points along the southwest boundary of the site which under a 100-year storm prevent flow from exiting the site." DEIR at 5-133. The section also states that the "East Garden Grove- Wintersburg Channel may experience overtopping in the area from Goldenwest Street westerly to Warner Avenue during a BCLT- 32 100-year storm event." DEIR at 5-136. Later in the section,the DEIR states that: "Due to the location of the project site within the A99 zone which is not subject to NFIP development standards and the results of the Hunsaker&Associates Channel Inundation Study, significant flooding impacts to the project are not anticipated." DEIR at 5-140. It 8 is not clear from the DEIR how much additional runoff from the site would flow into the BCLT-32 Channel. For example, does all Table W runoff go into the Channel? A clearer (cont) explanation of how project runoff will be handled is needed. Clear statements of project impact are difficult to find in this section(as with prior sections). However, it appears that the project could result in water quality impacts, if such impacts remain unmitigated. While the DEIR does not clearly explain the course of runoff from the project site to the ocean, it is clear that runoff would eventually be directed to the ocean from the Wintersburg Channel. Therefore, it is important that water quality be maintained. Mitigation measures in the DEIR all"defer" a statement of what mitigation will be implemented. The project does not appear to call for swales and other more environmentally sound means of controlling pollutants in runoff. Mitigation measures simply defer explanation of what will be required until later: 3. Prior to issuance of any grading permits,the applicant shall BCLT- 33 provide a Water Quality Management Plan showing conformance to the Orange County Drainage Area Management Plan and all NPDES requirements(enacted by EPA)for review and approval by the City Engineer. The plan shall reduce the discharge of pollutants to the maximum extent practical using management practices, control techniques and systems,design and engineering methods, and such other provisions which are appropriate." In other words,the DEIR does not disclose how water quality impacts will be mitigated or quantify water quality impacts before and after mitigation. This deferral of mitigation improperly leaves the public and the decision-makers out of the review loop and fails to demonstrate that impacts will be insignificant. The project calls for approval of a tentative map. This is the time for disclosure of what techniques—swales, grease traps, detention basins, etc. —will be used to mitigation impacts, and to analyze their efficacy in reducing water quality impacts. Finally,this section also needs to disclose the presence of the Bolsa (BCLT- 34 Fairview fault and explain how this fault may influence the site's hydrology. E. Biological Resources The DEIR fails in numerous respects to adequately address impacts to biological resources. See also Comment Letter from Connie Boardman,Professor of Biology, incorporated herein by reference. A summary of major defects in the DEIR's presentation of biological issues is set forth below. BCLT- 35 First,the DEIR fails to demonstrate that the County parcel and a large portion of the City parcel are not wetlands. Recent information indicates that a large portion of the City parcel,an arc extending from the proposed park-site to the Wintersburg-Channel, corresponds with historic tidal wetlands. See attached photos and 9 1873 U.S. Coast Survey maps. See also MWD sales information. The EPA wetlands BCLT-35 delineation map also shows wetlands on the County and City parcels. Indeed,the County (cost.) parcel appears to be covered almost entirely by wetlands. There is no quantification in the DEIR of wetland acres on the County parcel. The section also fails to explain how the soils types and hydrologic regime do not meet the Coastal Commission's definition of wetlands. For all these reasons,this section must be revised to include current,verified delineation of wetlands resources on the parcels. Based on the extent of wetlands, BCLT- 36 mitigation measures(avoidance and buffers)and alternatives (clustering and transferring units)must be identified to protect these areas consistent with City policies. The DEIR also fails to discuss the project's impact on wildlife habitat and migration in the regional setting. The project site is part of a larger wildlife habitat that connects with the Bolsa Chica. Migration and adequate habitat area is critical to wildlife for food, as well as for ensuring the species long-term viability. Since the Bolsa Chica is isolated from larger, inland habitat areas, all remaining surrounding open space areas may contribute to the area's long-term viability. The DEIR contains a brief discussion of the potential wildlife movement corridors and habitat linkages. In that discussion, BCLT- 37 there is a reference to the importance of protecting wildlife movement corridors and that while"[djefining corridor alignments and specific spatial and resource requirements may be somewhat conjectural,but simply-stated,the accepted basic rule in planning corridors or reserves is that 'bigger is better."' DEIR at 5-157. The DEIR goes on to describe linkages between the project site and the open marshland, and upland habitats to the west and service road linkages to the south. Perhaps a more important question than whether species of concern rely on the project site exclusively, is the extent to which the project site contributes to the long-term viability of the adjacent Bolsa Chica habitat. Moreover, the project site, particularly at its boundaries with the adjacent open space/habitat area, appears to be of considerable value as a buffer between those habitats and the existing tracts of houses. Since there is no aerial photograph beyond the immediate project area, nor an adequate discussion in the DEIR of the relationship of the project site to the adjacent marshlands and upland habitat areas,these concerns are not adequately BCLT- 38 addressed in the document. This site cannot be evaluated independently of these adjacent resource areas in terms of biological resource value. As such,the DEIR's conclusion with respect to cumulative impacts, is not supported by evidence concerning how the project site may contribute to the long-term viability of the adjacent habitat areas,particularly adjacent to the County parcel. The entire cumulative impact"analysis"is limited to the following: "The project, in conjunction with other past, present, and reasonably future projects,will incrementally contribute tot he cumulative loss of biological BCLT- 39 resources. The project's incremental contribution to this impact will be mitigated to a less than significant level." There is no discussion or summary of the impacts of cumulative projects on marsh and upland resources. This section must be revised to summarize such impacts and describe 10 mitigation measures for these significant cumulative impacts. Moreover, an analysis of the project site's value to the long-term viability of adjacent habitat areas must be BCLT- 9 provided. Specifically,to the extent homes are constructed immediately adjacent to (cost) these resources, what is the likely adjacent habitat area that would be impacted over the long-term? What size buffer or buffer treatment would prevent these impacts? The DEIR fails to adequately address cumulative impacts and fails to state whether cumulative impacts will be significant and unavoidable. Clearly,the cumulative loss of wetlands is significant. Moreover, no mitigation measures are included to address BCLT-40 cumulative impacts. Such a measure might include requiring a major portion(more than one/half) of the City parcel (including the 8.3 acre historical wetlands corresponding with the park-site,plus the area arcing to the Wintersburg-Channel and a 100 foot setback to homes)and the entire County parcel to be dedicated to offset the impacts of development on the remainder of the City parcel. Finally,the DEIR fails to adequately evaluate the likely significance of the eucalyptus trees on the project site and appears to improperly advocate for their removal. The discussion ignores the fact that the California Department of Fish and Game has designated the eucalyptus grove at Bolsa Chica an Environmentally Sensitive Habitat Area. Monarch butterflies, among other species,rely on eucalyptus trees for food and BCLT-41 habitat. A revised DEIR must provide additional evidence concerning the likely importance of these trees as habitat and describe appropriate mitigation measures to protect them over the long-term(e.g. buffers and enhancement measures). IV. MITIGATION MEASURES In numerous cases the DEIR finds that proposed mitigation measures will reduce significant impacts to less than significant where there is no demonstration of how the measure would do so. In other cases,mitigation measures are not identified because the DEIR fails to disclose all significant impacts(e.g. mitigation measures for the loss of wetlands; setbacks from the undisclosed Bolsa Fairview fault, etc.). Examples of measures that "defer"adequate mitigation include,but are not limited to,the following: Affordable Housing The DEIR concludes that the project may result in inconsistencies with the City's Affordable Housing Policy. DEIR at 5-36. Mitigation BCLT-42 measure 1 is found to reduce potential impacts to less than significant by requiring: a. Pay a fee to the City, if such a process is available. b. Participate with other developers or a non-profit organization to acquire and/or rehabilitate existing apartment units at any off-site location within a suitable area and provide for continued affordability; or 11 C. Provide the required affordable units at one of Shea Homes' future BCLT-42 multi-family projects within the City of Huntington Beach. (cont) The EIR process is the public's opportunity to scrutinize the proposed project and mitigation measures to ensure that all feasible measures have been imposed to reduce plan inconsistencies and environmental impacts. In this case,there is no reason to believe any of the proposed measures will result in the development of any affordable units. The fee, if available, may not be sufficient to produce 21 affordable units in Huntington Beach. Similarly,there is insufficient information about the other options to be able to conclude they would result in 21 units of affordable housing in the City. Nor does the discussion state what is considered to be an"affordable" unit or the length of BCLT-43 time a unit must remain affordable. Suffice it to say that the impact evaluation and analysis must be revised to provide additional detail concerning the City's policy and what the project must do in order to comply. A revised mitigation measure should clearly state how the 21 affordable units are going to be realized. Short of this,the DEIR must be revised to conclude that this impact,and the related impacts of a shortage of affordable housing in the region(e.g.jobs/housing imbalances,traffic, air quality impacts,etc.) is significant and unavoidable. Aesthetics: The DEIR states that the proposed project MAY result in impacts to County-proposed trails. It is not clear what"may"means in terms of potential impacts. That issue aside,the mitigation measure that purportedly reduces this impact to less than significant is as follows: "4. Prior to approval of building permits,the applicant shall submit to the City of Huntington Beach Planning Division proof of BCLT-44 County for approval of project consistency with the County Master Plan of Bicycle Trails." DEIR at 5-54 and 56. This is an example of deferred mitigation. Because the nature of the me measure is uncertain,the measure cannot be relied upon to reduce the impact to less than significant. Project consistency should be demonstrated in the DEIR, or, in the alternative, the impact identified as significant and unavoidable. Also in this section,the DEIR fails to explain how project consistency with the general plan for infill housing mitigates the significant and unavoidable loss of visual open space/agricultural land on the project site. The aesthetic change from vacant, BCLT-45 open space land to suburban housing must be identified as a significant and unavoidable land use and aesthetic change. DEIR at 5-57. Construction Traffic: The DEIR identifies this impact as potentially significant but mitigated by the requirement of a future truck and routing plan(including haul route for imported fill). There is no explanation how this future measure would BCLT- 46 mitigate this significant impact. The truck and routing plan should be provided as part of a revised project description and assessed as to its efficacy in reducing construction period impacts. Earth Resources: Similarly,to address potentially significant impacts BCLT-47 associated with high on-site water tables,the DEIR calls for the preparation of a I 12 dewatenng plan to be approved by the Department of Public Works. Again,this proposal improperly defers mitigation and circumvents the public's ability to review proposed BCLT-47 measures necessary to implement the project. Moreover,because there is insufficient (cont) information about the source of on-site groundwater,this measure may have significant secondary impacts(e.g. loss of wetlands,etc.). Additional information about the proposed measure and its potentially significant secondary impacts must be included in a revised DEIR. Drainagtly drology: Again,the DEIR discloses that the project may have water quality impacts. The mitigation measure proposed is a future Water Quality Management Plan. Thus,neither the project description, nor the mitigation measure BCLT-48 discloses the means through which the project will mitigate potentially significant water quality impacts on the Bolsa Chica wetland and ocean. Biological Resources: To the extent wetlands impacts are disclosed on the County parcel,the loss of wetlands are proposed to be mitigated at a ratio of 4:1 in the Bolsa Chica area. The Bolsa Chica area is an inappropriate location for wetlands mitigation, since the area is already being protected and already contains wetlands. Because the DEIR fails to identify the amount of wetlands that would be destroyed on the City and County parcels,the mitigation measure cannot describe appropriate mitigation. BCLT-49 The impact section should be revised to quantify wetlands to be destroyed and describe the quality and type of wetlands impacted The appropriate mitigation measure is that the project avoid destroying any wetlands and a minimum 100' buffer be provided between any development, including park uses,and the wetlands areas. Cumulative Impacts: The DEIR fails to describe any mitigation measures to address cumulative impacts. Such measures include creating a mitigation bank of BCLT- 50 some or all of the County and City properties to offset wetland destruction elsewhere in the region,among other feasible cumulative measures. V. PROBABLE UNAVOIDABLE ADVERSE IMPACTS The DEIR finds that there are no unavoidable adverse impacts; a remarkable conclusion given the lack of analysis of significant impacts and deferral of "measurable"mitigation measures. DEIR at 8-7. The list fails to acknowledge the numerous significant cumulative impacts identified in the DEIR for which no mitigation measures are proposed A revised list of unavoidable adverse impacts should be included in a recirculated DEIR including,but not limited to: BCLT-51 • Loss of agricultural, open space and habitat lands. • Cumulative water quality and flooding impacts. • Cumulative and localized impacts to wetlands. 13 • Air quality impacts. • Aesthetic impacts as a result of the conversion of open space to intensely suburbanized lands. • Impacts to County proposed trails. BCLT-51 • Impacts to the City's affordable housing policy-contribution to a (cost) lack of affordable housing and the related impacts on the region. • Construction-related traffic impacts. (See DEIR at 8-5;"Depending on the location of the haul route,traffic impacts along the selected routes may occur." • Cumulative traffic impacts. Unless additional mitigation measures are identified,these impacts must be identified as unavoidable adverse impacts of the project. The change of disposition of these impacts, and/or the identification of new mitigation measures,would require recirculation of a revised DEIR. VL ALTERNATIVES The DEIR must analyze a reasonable range of alternatives, as indicated in the DEIR's introductory discussion of this topic. This requirement is the"heart" of the EIR. In purporting to analyze a"reasonable range of alternatives,"the DEIR has not adequately focused on options which could substantially lessen or avoid the significant environmental effects associated with the proposed project. Instead,the various BCLT- 52 alternatives,viewed from an environmental perspective, differ in respects which do not address the project's significant impacts,with the possible exceptions of the no project/no development alternative and alternative location. Obvious alternatives which would substantially lessen or avoid project impacts include,but are not limited to the following: 1. An alternative which includes a landscaped buffer(more than 50') BCLT- 53 along the Wintersburg Channel to mitigate view impacts of the housing units from the trails along the Channel and provide additional recreational linkages. 2. An alternative that clusters the units on one/half of the City parcel and retains the County parcel as a wetland enhancement area or bank, if the latter is feasible. This would partially offset the BCLT-54 permanent loss of open space/habitat/agricultural lands on the City parcel and avoid wetlands impacts on the City and County parcels. 14 A minimum 100 foot buffer should be included in the alternative IBCLT- 4 -- to buffer development from the wetlands areas. (cont) 3. An alternative that includes 21 affordable units for low and very low income households on the City parcel to mitigate for the BCLT-55 project's inconsistency with the City's housing policy. 4. In the discussion of affordable housing, a mitigation measures is proposed which would locate the required affordable units on another"Shea"parcel. The alternative location alternative should be directed at transferring some or all of the units off of these parcels onto other Shea ownership's. Arguably this would result in a"feasible"project and provide equity to the owner in return for BCLT- 56 leaving some or all of these properties in open space uses. The DEIR should state what other Shea holdings there are in the City and immediate vicinity,the planned uses for those properties,the potential for accommodating additional"transferred" units,and the relative impacts if these properties were more intensively developed(either with the 27 units from the County parcel or all 208 units). In addition, the DEIR proposes alternative roadway alignment alternatives (Alternatives A,B and C)which call for various connections of B Street to Bolsa Chica Street. These alternatives would result in significant unavoidable impacts that are not adequately disclosed in the DEIR including,but not limited to, further inducement of growth in presently undeveloped areas and related impacts on air quality, noise and biological resources. The DEIR fails to mention the likely growth inducing implications BCLT-57 of these alternative and contains no additional analysis of biological or other impacts of these alternatives. While the DEIR mentions that Alternative alignments B and C would "result in greater impacts to biological resources due to the larger area that would be affected by implementation of this roadway,"there is no analysis or indication of the significance of these additional impacts. DEIR at 6-28. See also, 6-31. Analysis of the impacts of these alternatives must be included in a revised DEIR. VIL THE DEIR MUST BE REVISED AND RECIRCULATED The DEIR fails to provide evidence that all of the project and cumulative impacts would be reduced to less than significant A partial listing of significant impacts and unavoidable adverse impacts that must be identified in a revised DEIR is identified BCLT-58 above. In light of the DEIR's failure to disclose the complete list of likely significant impacts(e.g. to wetlands), coupled with its failure to adequately describe the whole of the project,the project setting, identify feasible mitigation measures and alternatives, it must be revised and recirculated. 15 CONCLUSION For all of the above-reasons,the Bolsa Chica Land Trust requests that the City require that a revised Draft EIR be prepared and recirculated if the project is to BCLT-59 receive any further consideration. 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I 7 �y :'f 1 1 1, 1 � � f r - - -- D MJETROFOUTAN WATER DISTRICT OF SOUTH ivy-C'•'-t -� �. 4. vs Rolsa Chica Residential Development Opportunity Approximately 45 Acres City of Huntington Beach PROJECT INFORMATION: For Information Contact: The Staubach Company • Zoning - R1-CZ-FP2 2010 Main St. Suite 620 Irvine, Califonua 92714 • Single Family Development ,� . ..„..... ?1t site g • Located in Established Residential Neighborhood BOIBA • Close proximity to the Bolsa Chica CHWA ""` State Beach ��' "` • Site on Graham Street near Warner Michael E. Smith Greg Thomas Avenue (714) 756-6400 53 June 14, 1998 TO: JAM BARNES, PROJECT PLANNER r_ FROM: KEN FELMMAN, 5411 GLENSTONE DAB= SUBJECT: CONCERNS & COMMENTS FOR SHEA PARKSIDE ESTATES/EIR I attended the NOP meeting for the Shea Homes Project on October 9,1997. In response to a request for our concerns and comments at that time, my neighbor and I prepared a two page letter listing some five major areas Impacting this development. I hand carried this letter to the Civic Center; had it date/time stamped; and left it for Julie Sakaguchi per the directions given for submittals. I have attached a copy of that letter to this one. After reveiwing the Shea EIR, I can' t see where anyone really satisfact- orily addressed our concerns. KFa-1 At the EIR meeting, my neighbors on both sides of the channel, expressed their concerns about the traffic problems, the impact on the wildlife, the flooding problems, possible increased earthquake destruction from build . Ing on compacted land, etc. KFa-2 I lived in Long Beach for a number of years, and as you are probably aware, a trmendous amount of oil was pumped out of Long Beach and some of the adjacent areas. The void left by the absence of this oil caused some sinking of the land and the homes. Terminal Island sank several inches before a solution to the problem was developed. The solution? Water was pumped back into the land to prevent any further KFa-3 sinking! The Shea Corporation wants to pump the water out. I would still like to know how the wildlife is going to be removed without any harm to these creatures. This question was never answered to my satisfaction. The Bolsa Chica Land Trust didn' t seem to like what they read in the EIR either. KFa-4 There has been a great .deal of talk alleging that a conflict of Interest exists between the Shea Corporation and the firm that prepared the EIR. That this firm has worked for Shea in the past and anticipates receiving more work in the future. If the charges should prove to be true, and the City of Huntington Beach hired this firm to do the EIR on Shea' s reccomendations, knowing of this alleged conflict of interest, then a charge of malfeasance cowl result causing some major problems for the City. KFa-5 Since this project is so controversial and objectionable to many, many people and there are questions regarding the reliability of the EIR, I believe that this EIR should be rejected and a company that never had any dealings with the Shea Corporation be hired to do an unbiased investigation of the land,and to prepare the EIR. Perhaps, a blue ribbo group of university/college professors (who are experts in their field) should be assigned this task. KFa-6 If the present EIR is accepted, I believe a lot of people are going to lose faith in the integrity of city government. If the EIR is rejected, the City Council, the City Planning Commission and the City Planning Department will send a clear message to the people of Huntington Beach that their city government does operate under ethical and legal guidelines, KFa-7 Very truly yours, 1 KENNETH FELDMAN October 13, 1997 2 To: Ms. Julie Sakaguchi, Associate Planner(Meeting of October 9, 1997)r Subject: Notice of Preparation(NOP) for the Shea Home Project This letter is to reiterate some of our concerns that were discussed at the October 9, 1997 meeting regarding the subject project. First major corn of those present at the meeting is the astronomical increase in the traffic on Graham. With the addition of another 208 homes in this area, and using a factor of 3 cars per ?some , an increase of at least 524 cars is expected to be added to the already current heavy traffic pattern. As several participants indicated at the meeting, the addition of all these cars to Graham, and the surrounding areas will create a major impact on the travel time, congestion in the area, and air pollution. As suggested by several of those present, your Environmental Impact Report (EIR) should at least cover a five mile radius emanating from the center of the project as its focal point. Perhaps in some areas, your EIR should be extended beyond the five mile radius. Second major concern is the flooding factor. It is a well known fact that this area tends to flood during a heavy downpour. Several of the residents of the area recall when boats were used as the mode of transportation during and after some of the more heavier rainstorms. One comment made during the meeting was that the entrance and exit to the Shea Project was in the lowest portion of that development. This piece of land will probably be impassable during even moderate rainstorms. Another comment was that during the heavier storms, about the only way the residents could leave that tract is by helicopter! This comment may prove to be a reality in the future and certainly should be investigated. Third major concern is the animals currently occupying the land owned by Shea. Some of these animals, such as skunks, are protected by various ordinances and laws. How are they going to be handled? Another well known fact is that when wild arur.:µls arc ;:;cteu from their naturai habitat, they take refuge in their surroundings nearest to them. We, the residents in the surrounding areas, fear that we will be invaded and overrun by the creatures being forced to flee from the onslaught of bulldozers, graders, and other heavy construction equipment. Since it is extremely difficult to obtain governmental services due to budgetary limitations by the County, many of the residents of the area will have to dip into their own pocketbooks to constrain, control and/or eliminate an additional problems (animal control). Fourth maj_pr concern is the removal of waste products, etc. Our channels, sewers, disposal units, etc. are already working at full capacity. It is obvious that the addition of another 208 homes will require the expenditures of large capital outlays by the city to cope with the increase demands and by the county to beef up the flood control channels. Do we really wish to take on additional capital outlay of moneys at this time? All these additional improvements must be in place before the first owners move into their homes not afterwards! Fifth major concern is the high density of homes with regards to the square footage to the lot sizes versus the city tax dollars achieved by this project. The long term effects to the environment do not outweigh the tax dollars achieve by the City! The key may be to the value of these homes and their lot sizes along with adequate streets, entrances, and exits which are needed to maintain the environment for this very valuable area. An alternative approach should be considered for this land other than the one proposed by the Shea Company. Perhaps an acceptable alternative would be to build a nine hole golf course with 50 to 75 luxury homes bordering the course. In any event, a public meeting should be held where the local citizens can offer proposals for the best utilization of the land, rather than just the one to develop a housing tract of an unusually high density of homes and its myriad of complex problems. The above concerns are just a few that we thought should be covered quite thoroughly in your EIR. Other concerns will be forthcoming sometime in the near future. Very truly yours, Kenneth Feldman Robert Schwarte 5411 Glenstone Dr. 5422 Glenstone Dr. Huntington Beach, Ca. 92649 Huntington Beach, Ca. 92649 54 . f JU;j 5411 Glenstone Dr. - ' Huntington Beach, CA c..,._., 92649-4705 June 17,1998 TO: JIM BARNES, PROJECT PLANNER SUBJECT: SHEA HOMES PARKSIDE ESTATES I attended the meeting last night regarding the EIR for the subject project. Prior to the meeting, I asked one of the members of The Planning Commission how I might give them some letters that I have written to various agencies. The response was to send you a copy of this correspondence, and that KFb-1 you would see to it that each member of the Planning Commission woul obtain a copy. Attached are copies of a letter to the California Coastal Commission to you regarding the EIR, and to Julie Sakaguchi in response to a request for comments and concerns at the October 9,1997 meeting. Very truly yours, KENNETH FELDMAN 5411 Glenstone Dr. Huntington Beach, CA 92649 June 14,1998 TO: MEMBERS OF THE CALIFORNIA COASTAL COMMISSION SUBJECT: PROPOSED SHEA HOMES IN HUNTINGTON BEACH My name is Ken Feldman, and I live in Huntington Beach. About 200 feet to the north of my home are 45 acres of vacant land often referred to as the "Beanfields". This land has served as a home to a variety of birds such as Egrets and migrating Canadian Snow Geese, as well as for other types of animals. The land was once part of the Bolas. Chica Wetlands and was classified as a wetland until very recently. It was reclassified to an agricultural zone when the Metropolitan Water District owned it. The MWD sold it to the Shea Corporation, who plans to build 208 homes on the site. It appears that the Huntington Beach City Council rezoned the land to "residential" during some top secret meeting, as no one in the immediate area of the property was notified or had any knowledge of this zoning change. In the June 11,1998 edition of The Orange County Register, pages Metro 1 & 2, an article dealing with the Hellman project in Seal Beach was discussed. The article quoted Ralph Faust, California Coastal Commiss- ion' s chief counsel, as saying "It's not really black and white. This is not the same as Bolas. Chica. " (Referring to the Hellman project. ) Well, Mr. Faust, the land 200 feet to the north of me IS Bolsa Chica Wetlands. If it is not Wetlands, then why does The Shea Corporation have to use 13 or so pumps to pump the water out of the land before they can start other activities such as removing dirt and replacing it with new dirt? Another part of the Register' s article said "Coastal commissioners are concerned about the destruction of natural wetlands." I was born and raised in Missouri, and as you know, it is called "The Show Me state." If the California Coastal Commission is really sincere and concerned about the Wetlands, then please restore this land to its trite Wetlands status: Some of the words from an old song go "not for just a day, not for just a week, not for just a month, not for just a year, but forever." If The Shea Corporation is allowed to build on this site, the damage to the birds, to the other wildlife and to the environment WILL BE FOREVER. Please, do not let this happen here! Sincerely yours, KENNETH FELEMAN June 14,1998 TO: JIM BARNES, PROJECT PLANNER FROM: KEN FELMIAN, 5411 GLENSTONE DR. ; H.B. 92649 SUBJECT: CONCERNS & COMMENTS FOR SHEA PARKSIDE ESTATES/EIR I attended the NOP meeting for the Shea Homes Project on October 9,1997, In response to a request for our concerns and comments at that time, my neighbor and I prepared a two page letter listing some five major areas Impacting this development. I hand carried this letter to the Civic Center; had it date/time stamped; and left it for Julie Sakaguchi per the directions given for submittals. I have attached a copy of that letter to this one. After reveiwing the Shea EIR, I can't see where anyone really satisfact- orily addressed our concerns. At the EIR meeting, my neighbors on both sides of the channel, expressed their concerns about the traffic problems, the impact on the wildlife, t flooding problems, possible increased earthquake destruction from build ing on compacted land, etc. I lived in Long Beach for a number of years, and as you are probably aware, a trmendous amount of oil was pumped out of Long Beach and some of the adjacent areas. The void left by the absence of this oil caused some sinking of the land and the homes. Terminal Island sank several inches before a solution to the problem was developed. The solution? Water was pumped back into the land to prevent any furt *r sinking'. The Shea Corporation wants to pump the water out. I would still like to know how the wildlife is going to be removed without any harm to these creatures. This question was never answered to my satisfaction. The Bolsa Chica Land Trust didn' t seem to like what the; read in the EIR either. There has been a great deal of talk alleging that a conflict of interest exists between the Shea Corporation and the firm that prepared the EIR. That this firm has worked for Shea in the past and anticipates receiving more work in the future. If the charges should prove to be true, and the City of Huntington Beach hired this firm to do the EIR on Shea' s reccomendations, knowing of this alleged conflict of interest, then a charge of malfeasance coult result causing some major problems for the City. Since this project is so controversial and objectionable to many, many people and there are questions regarding the reliability of the EIR, I believe that this EIR should be rejected and a company that never had any dealings with the Shea Corporation be hired to do an unbiased Investigation of the land,and to prepare the EIR. Perhaps, a blue ribbo: group of university/college professors (who are experts in their field should be assigned this task. If the present EIR is accepted, I believe a lot of people are going to lose faith in the integrity of city government. If the EIR is rejected, the City Council, the City Planning Commission and the City Planning Department will send a clear message to the people of Huntington Beach that their city government does operate under ethical and legal guidelines° Very truly yours, EENNETH FELDMAN October 13, 1997 To: Ms. Julie Sakaguchi, Associate Planner(Meeting of October 9, 1997) Subject: Notice of Preparation(NOP) for the Shea Home Project This letter is to reiterate some of our concerns that were discussed at the October 9, 1997 meeting regarding the subject project. First maj jor concern of those present at the meeting is the astronomical increase in the traffic on Graham. With the addition of another 208 homes in this area, and using a factor of 3 cars per home, an increase of at least 624 cars is expected to be added to the already current heavy traffic pattern. As several participants indicated at the meeting, the addition of all these cars to Graham, and the surrounding areas will create a major impact on the travel time, congestion in the area, and air pollution. As suggested by several of those present, your Environmental Impact Report (EIR) should at least cover a five mile radius emanating from the center of the project as its focal point. Perhaps in some areas, your EIR should be extended beyond the five mile radius. Second major concern is the flooding factor. It is a well known fact that this area tends to flood during a heavy downpour. Several of the residents of the area recall when boats were used as the mode of transportation during and after some of the more heavier rainstorms. One comment made during the meeting was that the entrance and exit to the Shea Project was in the lowest portion of that development. This piece of land will probably be impassable during even moderate rainstorms. Another comment was that during the heavier storms, about the only way the residents could leave that tract is by helicopter! This comment may prove to be a reality in the future and certainly should be investigated. Third major concern is the animals currently occupying the land owned by Shea. Some of these animals, such as skunks, are protected by various ordinances and laws. How are they going to be handled? Another well known fact is that when wild animals are evicted from their natural habitat, they take refuge in their surroundings nearest to them. We, the residents in the surrounding areas, fear that we will be invaded and overrun by the creatures being forced to flee from the onslaught of bulldozers, graders, and other heavy construction equipment. Since it is extremely difficult to obtain governmental services due to budgetary limitations by the County, many of the residents of the area will have to dip into their own pocketbooks to constrain, control and/or eliminate an additional problems(animal control). Fourth major concern is the removal of waste products, etc. Our channels, sewers, disposal units, etc. are already working at full capacity. It is obvious that the addition of another 208 homes will require the expenditures of large capital outlays by the city to cope with the increase demands and by the county to beef up the flood control channels. Do we really wish to take on additional capital outlay of moneys at this time? All these additional improvements must be in place before the first owners move into their homes not afterwards! Fifth maior concern is the high density of homes with regards to the square footage to the lot sizes versus the city tax dollars achieved by this project. The long term effects to the environment do not outweigh the tax dollars achieve by the City! The key may be to the value of these homes and their lot sizes along with adequate streets, entrances, and exits which are needed to maintain the environment for this very valuable area. An alternative approach should be considered for this land other than the one proposed by the Shea Company. Perhaps an acceptable alternative would be to build a nine hole golf course with 50 to 75 luxury homes bordering the course. In any event, a public meeting should be held where the local citizens can offer proposals for the best utilization of the land, rather than just the one to develop a housing tract of an unusually high density of homes and its myriad of complex problems. The above concerns are just a few that we thought should be covered quite thoroughly in your EIR. Other concerns will be forthcoming sometime in the near future. Very truly yours, �� Kenneth Feldman Robert Schwarte 5411 Glenstone Dr. 5422 Glenstone Dr. Huntington Beach, Ca. 92649 Huntington Beach, Ca. 92649 55 -J from . . . KEN FELDMAN cz �G KFc-1 zd- cv�- V T._ October 13, 1997 To: Ms. Julie Sakaguchi, Associate Planner(Meeting of October 9, 1997) Subject: Notice of Preparation(NOP) for the Shea Home Project This letter is to reiterate some of our concerns that were discussed at the October 9, 1997 meeting regarding the subject project. First moor concern of those present at the meeting is the astronomical increase in the traffic on Graham. With the addition of another 208 homes in this area, and using a factor of 3 cars per h.cme, an increase of at least 524 cars is expecied to ve added to the already current heavy traffic pattern. As several participants indicated at the meeting, the addition of all these cars to Graham, and the surrounding areas will create a major impact on the travel time, congestion in the area, and air pollution. As suggested by several of those present, your Environmental Impact Report (EIR) should at least cover a five mile radius emanating from the center of the project as its focal point. Perhaps in some areas, your EIR should be extended beyond the five mile radius. Second mayor concern is the flooding factor. It is a well known fact that this area tends to flood during a heavy downpour. Several of the residents of the area recall when boats were used as the mode of transportation during and after some of the more heavier rainstorms. One comment made during the meeting was that the entrance and exit to the Shea Project was in the lowest portion of that development. This piece of land will probably be impassable during even moderate rainstorms. Another comment was that during the heavier storms, about the only way the residents could leave that tract is by helicopter! This comment may prove to be a reality in the future and certainly should be investigated. Third major concern is the animals currently occupying the land owned by Shea. Some of these animals, such as skunks, are protected by various ordinances and laws. How are they going to be handled? Another well known_fact is that when illd ar4:::als are icted from their natural habitat, they take refuge in their surroundings nearest to them. We, the residents in the surrounding areas, fear that we will be invaded and overrun by the creatures being forced to flee from the onslaught of bulldozers, graders, and other heavy construction equipment. Since it is extremely difficult to obtain governmental services due to budgetary limitations by the County, many of the residents of the area will have to dip into their own pocketbooks to constrain, control and/or eliminate an additional problems (animal control). Fourth major concern is the removal of waste products, etc. Our channels, sewers, disposal units, etc. are already working at full capacity. It is obvious that the addition of another 208 homes will require the expenditures of large capital outlays by the city to cope with the increase demands and by the county to beef up the flood control channels. Do we really wish to take on additional capital outlay of moneys at this time? All these additional improvements must be in place before the first owners move into their homes not afterwards! Fifth major concern is the high density of homes with regards to the square footage to the lot sizes versus the city tax dollars achieved by this project. The long term effects to the environment do not outweigh the tax dollars achieve by the City! The key may be to the value of these homes and their lot sizes along with adequate streets, entrances, and exits which are needed to maintain the environment for this very valuable area. An alternative approach should be considered for this land other than the one proposed by the Shea Company. Perhaps an acceptable alternative would be to build a nine hole golf course with 50 to 75 luxury homes bordering the course. In any event, a public meeting should be held where the local citizens can offer proposals for the best utilization of the land, rather than just the one to develop 3 housing tract of an unusually high density of homes and its myriad of complex problems. The above concerns are just a few that we thought should be covered quite thoroughly in your EIR. Other concerns will be forthcoming sometime in the near future. Very truly yours, Kenneth Feldman Robert Schwarte 5411 Glenstone Dr. 5422 Glenstone Dr. Huntington Beach, Ca. 92649 Huntington Beach, Ca. 92649 56 J 6452 Oakcrest Ci. Huntington Beach, CA 92648 June 11, 1998 Mr. Jim Barnes ,'-' � City Planner 2000 Main St. Huntington Beach, CA 92648 t Wor Dear Mr. Barnes: I am writing to you regarding the poor and inadequate draft EIR for Shay's"Parkside Estates"project located off Graham Street. Although most of the sections seem to have been poorly addressed, my primary concerns are JR-1 the biology section of the EIR, as well as the conclusion that the property supposedly does not have any type of wetlands. The draft EIR gives the impression that it is just a vacant lot with little to no biological significance. The only impact they plan to mitigate are the active nesting sites for the birds of prey. And after the breeding season,they will remove the eucalyptus grove. That is not mitigation;what about forth-coming seasons? For one month,mid January through mid February, I visited the site on a daily basis,taking photographs and keeping a journal. This is what I observed in the city parcel: Canadian Geese almost 50% of the time, migratory ducks, great blue JR-2 herons, ground squirrels,jackrabbits, raptors, sand-pipers, monarch butterflies, shore-birds,black with brown speckled birds(possibly sparrows),black-necked stilts, snowy egret, and a coyote(observed by a friend). What is incredible is that Shay disked the property in December 97', and within a few months, the place sprang to life. Canadian geese do not forage anywhere in Bolsa Chica except for the Shay property. The biology section needs to be re-evaluated(prior to disking) and than mitigated accordingly. The draft EIR states that there are no wetlands, wetland vegetation, or natural surface water features. I have personally seen aerial photographs of the property showing ponding water on a seasonal basis, not to mention a natural meandering stream pattern flowing through the property(this is partially evident in exhibit 22-D of the JR-3 draft EIR). These features occurred in both so-called drought years and El Nino years. I have also documented over one month of consecutive ponding(mid-January to mid-February,which was prior to our major El Nino storms). According to EPA guidelines, a"farmed wetland"is classified as a body of water with over 14 days of consecutive ponding. This situation clearly qualifies the ponding water as a seasonal wetland that was once farmed. Another wetland delineation is the fact that there was no mustard seed present in the saturated areas, and that certain wetland vegetation actually began colonizing in the ponded areas. A determination of wetlands J R-4 is basically impossible if it is disked on a regular basis. Disking should be halted so that an accurate determination can be made, and of course, followed by appropriate actions. Aside from the aforementioned impacts,the majority of the community does not want this project or any project on Bolsa Chica to develop (no pun intended). The scope of the EIR is obviously one-sided and inadequate. JR-5 Therefore,the draft EIR needs to be re-done in an unbiased and scientific manner. I thank-you in advance. Si cerely� son Ruth! P.S. Please see reverse side of pictures for a description of the image. �y� r + '! � ,y'. Jhfi eta'(;�+ � • y .•yyu `Jl i. 1 .j T'tt • r � t J# 4 Aa,� � . ,�11 S , , I .� � f'. . . .1� 4. .il � r+: . s � f �!� i I�i�f � j.�.1 H I ., iG�7 '�. I 4 �4; � , �� , � � t , r ,� ; �.. '• �� 1. �'' � .t- JI � J i .e. •, ! {p ,�. f ,�� � (f 7t 4 1 '3 .. JJ '�i 1 ,�.I' � � 1 � � �' 1 , �� )I ) � i i ' 1 } ,me,µ �•� � �..,: .:' �.,. i 1 h t * 9 i i1 57 JUN 1 1998 Michael J. Lester 5096 Tortuga Dr., #211 Cvx.�'Y i�fviT'r: fyT Huntington Beach, CA 92649 (714)377-0102 June 9, 1998 Jim Barnes Planner City of H tington Beach 2000 Main t Huntington Beach, CA 92648 Dear Mr. Barnes: As you are aware Shea Homes is planning to develope 200 units on 49 acres on the Bolsa Chica lowlands area. Having been born in Huntington Beach and a current homeowner in this great city,I must vocalize my displeasure with this housing plan. The balcony of MJL-9 my condo overlooks the area that they are planning to build on. Hence,my wife and I have had the pleasure of seeing this area go through its transformation over the seasons and we would like to point out several items of interest that you must take seriously. First,this area is indeed a "wetlands" area. Unfortunately,the current owner continuously plows over the area, destroying what at times has been absolutely beautiful. This section of land is a continuation of the Bolsa Chica Mesa area and produces the same wonderful plant and animal life that you fmd on the Mesa. With the large amounts MJL-2 of rain we have seen over the past El Nino season,this area has at times been completely under several feet of water. The plant life and flowers grew to heights of over 7 feet! It amazes me that Shea is allowed to destroy this wetlands area by just plowing over the plant life time after time. As I am sure that you are aware,they have now plowed over MJL-3 the entire area and planted what looks like squash or grass. Unfortunately, you have already allowed them to destroy the natural habitat. Second,it seems that the EIR does not address the impact that the development would have on the wildlife in the Ecological Reserve area. If you are not familiar with the area, let me explain to you that all kinds of birds land and live in this area. We have seen MJL-4 snakes, coyotes, skunks and lots and lots of birds in and around this area. The thought of a cat or dog hunting out in the Ecological Reserve area is indeed frightening. It would be appalling to give cats and dogs from 200 units a free run at the beautiful birds of the wetlands. Having been a resident of Seal Beach, Sunset Beach and Huntington Beach, let me tell you that I have never met a single person who has been in favor of any further MJL-5 development on the Bolsa Chica. I urge you to pursue the path of a large, Regional Park of some kind that will save all remaining open space on this jewel belonging to North Orange County. Respectfull ichael J Le er cc: Ralph Bauer Shirley Detloff Dave Garafalo Tom Harman Dave Sullivan Peter Green Pam Julian 58 MF Lionel Okun 13801 El Dwado Of#11F xal Seam,CA 90740-3923 Tel : ( 562) 430 8668 June 98 Jim Barnes . Planner J u t' City of Huntington Beach 2000 Main St HB CA 92648 = tiiTY L �a✓;s ElVT Dear Sir re Shea Homes project, EIR no 97-2 The scope of the EIR is inadequate as it does not address the effects �LO-1 arising from this development on the wildlife in the Ecological Reserve and on the mesa The access plans are grossly inadequate as doubtless you are already �LO-2 aware The City does not have surplus water from wALCh to supply water needed for this project ILO-3 The E'IR statement that there are no wetlands on this land and insuffient wetland plants on the site is invalid because of the frequent plowing of the land. The site needs the opportunity to LO-4 recover from this plowing, before a wetland determination can be fairly made I hope the planning commissi©n will take these points into consideration when making their decision I 'm concerned about saving the whole Bolsa Chica wetlands-mesa entity for ecological and environmental reasons and also from the point of LO-5 view of adding to the traffic problems in the area spreading as far as Seal Beach Boulevard and adversely affecting the timely arrival of emergency health services and getting the people to hospital, for the over 9,000 seniors here in Leisure World as well as others , (the average daily emergency calls here in L.Wld last year was 3. 6 daily) Yours sincerely 59 RECCE JUl 1 s 1998 It PQP w AW-1 AW-2 AW.3 LJ MR ALAN L +vHITE r PO SGX 596 SAh CLEMENTE CA 92674—nSo<, 60 10 sv-1 77- O)f7 AJ LO Aj CD SV-2 cc 1� SV-3 61 r Neil Wagner 17241 Berlin Ln. Huntington Beach CA 926494505 J U N 15 1998 714-840-1205 June 10, 1998 ��=�r� !,i:_ COPI,a L:P,i 1{� 1 t Y Dc.v..``rJ'PiNENT Mr. Jim Barnes, Project Planner City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 SUBJECT: Draft EIR 97-2 Shea Homes Parkside Estates Dear Mr. Barnes, Having now read the subject draft EIR, I am able to comment on several failings I perceive to exist in the document,one that I consider to be quite significant. Comments follow. I NW-1 Most significant.- During the public discussion meeting in May it was quite apparent that the majority of residents surrounding the proposed project want the project to have a second access road in order to minimize the increase in traffic volume on Graham Street expected to result from the project. NW-2 Since my home is immediately east of the proposed single entrance at"A"Street, I wholeheartedly support these feelings. The draft EIR evaluates three proposed connections to Bolsa Chica,Street. I generally agree that the three alternatives presented are not feasible nor would they be desirable for Shea due to the elimination of several of their proposed homes. However,the attached sketch shows another routing that would not have any of the disadvantages of the three routings that were analyzed: no homes would be lost the existing comer from ,r,Street to"M"Street is already planned to be cut into the NW-3 hillside by running along the side of the hill instead of going directly up it,the grade considerations discussed for the other routings can be minimized no private land would have to be purchased the size of the usable open land space within the tract would not be reduced This fourth option for connecting the tract to Bolsa Chica Street definitely should be considered. Less significant: During the discussion of the three proposed connections to Bolsa Chica Street,the routings were analyzed for their likely grades with actual numerical data Comparison was then made to the NW-4 grade of Vineland(?Greentree?)to the north,but no numbers were given. What is the grade of Greentree? While I know that in previous public discussion meetings it was made clear that any road connecting the proposed tract with Greenleaf to the north would be very undesirable to the local I NW-5 residents,the draft EIR didn't even mention this possibility as a way of minimizing the traffic impact on Graham Street. Additionally,the draft EIR discusses the proposed traffic signal at"A" Street,but I don't recall seeing any mention of the(possible)need for"signal ahead"lights and/or NW-6 signs as was mentioned during the project's scoping meeting. There was mention in the draft EIR of a prohibition on left turns from"A" Street to Graham. As this would be especially beneficial to me, I would like to see this idea discussed more fully and NW-7 considered for inclusion in the proposed project. I very much like the idea of restriping Graham for a center turn lane and bona fide bike lanes. This would improve access to and from the side streets tremendously while increasing safety. It would also essentially end forever any possibility of making Graham four lanes--something I NW-8 definitely don't want. These improvements should be accomplished regardless of the outcome of the Shea project. I wouldn't mind a lower speed limit on Graham as well. Several mentions were made of the proposed bike trail along the Wintersburg channel,but I saw NW-9 no mention of how that trail would be accessed either from within or outside the proposed tract. It seems likely this project will have some impact on the values of the surrounding homes. I'm not sure if it will raise or lower the value of my house. I'd like to see some general discussion NW-10 about this in the EIR,including any likely variation in impact for the different surrounding tracts to the north, east, and south of the project. Finally, I think more analysis should be done on the project alternative of not developing the Iand at all. I am not alone in hoping this land remains open space as it is. I have a direct line of sight NW-11 to the ocean, direct sea breezes,and a dark night sky to the southwest of my home as a result, and I would like to keep it that way. Any discussion of the option to not develop should include a detailed review of the proposed Koll development on the Bolsa Chica.Mesa,the local effort to stop that project, and the overall regional ecological impact if the Koll project does or doesn't happen in conjunction with whether NW-12 the subject Shea project does or doesn't happen. I don't think the draft EIR considers seriously enough the overall benefit to the community of keeping both projects undeveloped. I am realistic enough to recognize the Shea property ultimately is likely to be developed. The one thing that absolutely must happen to satisfy the existing local residents is the addition of a road NW-13 connection to Bolsa Chica Street. My proposal seems the best way to do that. Thank you for the opportunity to participate in the process. Sincerel , VV IRAW s �r � I11 10 10 OF r i . •. F � it �,. � , ! 04 ill l /i'�: ► !' Phi s`-Not ff 62 Pp"Os CO(�6 FOUNY0 1956 ?Y CERRITOS COMMUNITY COLLEGE DISTRICT 11110 ALONDRA BLVD. • NORWALK, CALIFORNIA 90650-6298 • (310) 860-2451• FAX (310)467-5005 F`r WINGS'O June 15, 1998 1 5 Mr. Jim Barnes J U M 1998 City of Huntington Beach DER'RT�Y-::.T OF 2000 Main Street CGPV1,'Vj;L;N1TY DE ELOJPMEVT Huntington Beach, CA 92648 Dear Mr. Barnes: The following comments address the draft EIR (DEIR) for the proposed Shea Homes project for the development of 208 units on approximately 49 acres of land. I C13-1 This DEIR is both biased and fails in properly addressing the scope of the impacts this project may cause. CEQA requires that the setting be described for the local area and the REGION. This DEIR fails to do that. The DEIR should be revised and recirculated C13-2 to adequately address the impacts this project will have in an unbiased manner. In the following paragraphs I will elaborate and give examples of the lack of scope and biases in the DEIR. I am puzzled by the following statement on page 2-1 of the DEIR " The anticipated 50 to 75 year life span of structures represents a short-term use of the environment. Nevertheless, implementation of the project would represent a relatively long term commitment to urbanization. It is logical to assume that the proposed uses will in turn be replaced by another productive activity as the development and redevelopment of CB-3 the land progresses through time in response to human needs." First of all it seems to me that if the builder only expects their houses to last 50-75 years they must be building rather poor.quality.housing., Is the next sentence.saying in_fact the applicant is proposing to permanently change this land from open space to create urban J structures, and the open space most likely will never return? If so clearer language should be used in the revised and recirculated DEIR to express this. The DEIR recognizes the problem of the City of Huntington Beach providing water to the 27 units in the 4.5 acre County section. Since the City currently does not have a surplus of water it is unable to provide water outside of its limits. The mitigation suggested for this problem is to annex the County land into the City of Huntington Beach. This obviously solves the applicant's problem of a water supply for the 27 units CB-4 but how does this mitigation address the underlying problem of a lack of surplus water? It simply does not and assumes the problem will just go away as soon as these units are included in the City limits. In reality this mitigation is not mitigation at all, but only a solution to a problem faced by the applicant. A real solution to finding surplus Ont.) -4 water should be presented in the revised and recirculated DEIR. Appendix G the Biology Report (which is not numbered and thereby makes it difficult for the reader to refer to pages in the document) states on the third page paragraph 2 "there are no seasonal ponds or channels on the site, but aerial photographs frequently show a shallow accumulation of surface water in the northwest corner of the C13-5 city property'. Also on the third page of the biology report is the statement "On several survey dates soils had been saturated by recent rains and water was standing in low areas." Please address this contradiction in the DEIR. There are no seasonal ponds, but there is standing water? What is your definition of a seasonal pond if not a shallow accumulation of water? Why are the areas described in the aerial photographs not called seasonal ponds? Why were visits not made to the site toward the end of the rainy season in Feb.-April rather than only in the months of November, December, January and June? Seasonal C13-6 ponds, vernal pools, ephemeral pools or what ever word one uses are often shallow accumulations of surface water. By admitting these pools exist and yet at the same time trying to deny their existence the DEIR shows a bias toward reducing the importance of the biological resources on the site. The recirculated revised DEIR should address this. Also refer to the photocopies of photographs( 1 A-C ) of grading covering an obvious pond or wetland area in April 1998. This is more evidence that seasonal ponds did exist on the site until the applicant ordered them filled. I realize the applicant claims they did this to plant crops. However, by examining photographs numbered 2 A-F you can see that the crops first planted in April 1998 are now dead. It is obvious that while CB-7 seeds of a grain crop were planted the crop was not cared for and has died. There is also evidence in the photographs of a second crop of a type of bean which is growing only in part of the area. This leads me to believe the applicant planted the grain crop in a hurry in order to cover the ponds with fill to conceal their existence. As l_am.sure-you.are aware, Mr. Scott Harris.of-the California Department of.Fish and A -, Game (CDFG) indicated that based on new information CDFG was reconsidering their statement that the site lacked wetland values. Their original finding had been based on the report submitted by the consultant hired by EDAW. However, when presented with new information CDFG decided to revisit their decision. In light of this the City CB-8 Council had requested the applicant wait two weeks before discing the property. Within two days of this request the land was not only disced but graded as well. Despite the fact the applicant had no approvals for grading. Does not unauthorized grading violate CEQA guidelines and if so what sanctions will be imposed on the applicant? On the third page of the resources assessment this statement is made "Geographically the Shea Home site is almost entirely isolated from other similar open space" This CB-9 statement is false and again is a way to try to reduce the importance of the site. As you can see from photograph 3 the Shea property is connected directly to over 200 acres of open space on the Bolsa Chica mesa. It is also connected to wetlands in the "pocket" area of Bolsa Chica, as well as to land owned by the Land Trust. The land CB-9 owned by the Trust has had conservation easements placed on it to prevent any development of the land. It will remain as open space in perpetuity. While the Koll (or California Coastal Communities inc. ) has plans to develop their land these plans are being challenged in court by the Bolsa Chica Land Trust. Approvals Koll or CCCI may have had have been voided pending appeal. Koll or CB-10 CCCI also has no water for the project as the City of Huntington Beach remains reluctant to provide water for a development outside of the City. The Bolsa Chica Lan Trust is working to bring about the preservation of this 215 acres of land and this woui connect as open space to the Shea property. The last paragraph of the eighth page states "there are no tidal inflows to the Shea area and because the Wintersburg Channel bottom is lower than land forms on the site there is little possibility of sub surface accretion of water from the Bolsa Chica wetlands". Please refer to the color photocopy of photograph 4 showing a test pit dug CB-11 on the property. The water you see in the photograph is salt water and is less than 3 feet underground. This contradicts claims made elsewhere in the DEIR that the ground water is 10 feet or more below the surface, as well as the statement quoted above. Please explain the contradiction in the recirculated draft EIR. How can one explain the presence of salt water less than three feet under ground if indeed it is not flowing under or through Wintersburg Flood Control Channel from the wetlands or tidal action from the ocean? Wintersburg Flood Control Channel is not a CB-12 completely cemented structure. Was this known to the preparers of the DEIR? The presence of water at such a shallow depth may also explain the statement on the 7th page of the biological report admitting that as late as 1994 "vegetation patches were easily detectable by the characteristic rusty coloration of pickleweed". There was pickleweed on the site until it was disced over or graded. It is not surprising that ruderal vegetation.is_found..on.site given its history.of-discing...That pickleweed C1343 vegetation survives at all should indicate that there is some salt water intrusion onto the site yet this is never even mentioned as a possibility. If given a chance this vegetation may very well return, yet this kind of an altemative is not even explored in the DEIR, another example of bias toward the development of the site. Another example of the bias of this DEIR is in the section dealing with the eucalyptus trees. The DEIR is clearly biased toward their removal. The DEIR completely ignores the fact that the California Department of Fish and Game has designated the eucalyptus grove at Bolsa Chica an Environmentally Sensitive Habitat Area (ESHA). CB-14 Even though they are non native trees their importance to the birds of prey at Bolsa Chica has given them this special designation. It is true that some of the trees on the Shea property are dying, but even dead and dying trees provide important habitat for wildlife. Why was this not mentioned in the DEIR? One can only imagine this has occurred because the drafters of the DEIR fail to recognize any connection this property has to Bolsa Chica Was the CDFG consulted as to the size of the ESHA on Shea's property?. An ESHA is afforded special protection, and it is to be buffered from impacts by nearby development. Again the DEIR completely ignores this and instead lobbies for the tree's removal. What kind of buffers and protection will be given to the CB-14 ESHA on the Shea Property? While the EIR for the Koll Company's Bolsa Chica (Cont) project claims the ESHA has shrunk from 20 acres to as little as 4, the CDFG has made no such determination. This issue must be clarified in the recirculated draft EIR. The DEIR claims that these trees are non native and this is justification for removing them. I might buy that if they were going to be replaced with native trees, but the plan is to replace them with equally non native housing. And what type of trees are people most likely to plant in their yards? Non-native trees. There is also an argument made CB-15 that it is un-natural to have trees bordering a salt marsh. Is it any more natural to have houses bordering a salt marsh? These arguments once again point to the biased nature of the DEIR. At the bottom of the eleventh page of the biological resources report mention is made of two intact pickleweed patches "sufficient for low numbers of animals not larger than songbirds". Why were these patches allowed to be removed when the Belding's savanna sparrow, a State endangered species is know to nest at Bolsa Chica in pickleweed? Prior to the removal of these patches was a surrey done to determine if CB-16 the sparrows were present? The DEIR is unclear on this point it appears that one observation of the area turned up golden-crowned sparrows and white-crowned sparrows. How many visits were made before assuming that the Belding's savanna sparrow was not present in this area ? Much is made of the presence of the red fox on the site, yet no mention is made of the presence of coyotes and the role they play in the control of the red fox and feral cats on the site. The Naval Weapons Station at Seal Beach is given as an example of the damage the red fox can do to native bird populations. It is important to point out CB-17 however, the fox population at the weapons station exploded when the coyote was exterminated at the site._ After all the coyotes.were_removed from the area by shooting,. the red foxes became a problem predator on the least tem, clapper rail and other ground nesting birds. If this site is developed and the Bolsa Chica mesa is developed, where will the red fox go? Into the remaining available open space at Bolsa Chica. This will only push the foxes closer to the least tem and Belding's savanna sparrow habitat and nesting CB-18 habitat of shorebirds and waterfowl. Why was this possible impact of the development not addressed? This needs to be addressed in the revised and recirculated DEIR. On page 19 of the biological resources report mention is made of the monarch butterfly. This butterfly uses the eucalyptus tress along the California coast for food and CB-19 to form night-time aggregations. The report mentions seeing them feed in the eucalyptus trees but not finding any aggregations. What time of day were these observations made? If the monarchs were already actively feeding the visits by the biologists were probably too late in the day to find any aggregations. When the temperature reaches about 55 F the butterflies become warm enough to fly and leave CB-19 the aggregation in search of food. Trees in which aggregations form are given (Cont.) protection by CDFG and more effort should be made to determine if the butterflies are using the trees on the site as aggregation sites or not. Please address this in the revised and recirculated DEIR. The Bolsa Chica is one ecosystem and the Shea property is part of this ecosystem. The DEIR fails to adequately address the scope of the project by analyzing only expected impacts the development has on the 49 acres of the Shea property. Why is it assumed that what happens on this property will have no affect on the wetlands and mesa at Bolsa Chica? It does not make sense to propose the construction of over 200 CB-20 units at Bolsa Chica and not even mention impacts this development will have on wildlife there. Its almost as if the project is being planned for another city instead of on the Bolsa Chica lowlands. The DEIR limits itself to what impacts the development will have only to 49 acre site. Despite what the preparers of the DEIR seem to think, the Shea property does not exist in a vacuum. Appendix G states "Project implementation would generate no direct significant adverse impacts to native wildlife populations or sensitive species locally or regionally." As a Biologist 1 strongly disagree with that statement. The biological resources section of the DEIR is lacking in that it does not adequately examine the impacts of the project CB-21 to the Bolsa Chica Ecological Reserve and other areas of Bolsa Chica along with the wildlife found in these areas. Let me give you an example of one obvious impact. All of the endangered birds which nest at Bolsa Chica and the other waterfowl and shorebirds nesting at Bolsa Chica are ground nesting birds. Those that are not, such as birds of prey like the white tailed kite red-tailed hawk, as well as the great blue herons nest in the eucalyptus trees. I can find no mention in the DEIR of the impact that domestic pets of the new residents will have on the wildlife in the wetlands. Why was this obvious impact not mentioned, analyzed and._attempts.made.to.suggest_mitigation?.Instead.there..are statements CB-22 about how dangerous eucalyptus trees are to birds. The DEIR cites a study published in the Point Reyes Bird Observatory newsletter which suggests eucalyptus may suffocate birds because of the sticky nectar clogging nasal passages. I examined this cited article myself and found that the sample size of birds allegedly killed this way was 2. Two birds found years apart. A sample size of two birds is hardly enough to draw any significant conclusions from which is why this type of data would not be found in a scientific journal. Anecdotal data such as this has no place in an EIR which is supposed to be based in science and be unbiased. Why was a newsletter article with a sample size of two included as a reference in the r DEIR when articles published in scientific journals which document the loss of millions CB-23 of birds to cat predation were not cited ? (See Coleman, J.S. and S.A. Temple. (1995) How many birds do cats kill ? Wildlife Control Technology. 44. ; Dunn,E.H. and D.L. Tessaglia. (1994) Predation of birds at feeders in winter. Journal of Field Ornithology 65 (1): 8-1 6.; Mitchell, J. and R.A. Beck. 1992 Free ranging domestic cat predation on native vertebrates in rural and urban Virginia. Virginia Journal of Science 43: 197- 206.) The DEIR is biased toward the removal of the eucalyptus trees, yet ignores CB-23 obvious impacts residential development will have on the surrounding area. Much (Cont.) time is spent justifying the removal of the trees, yet no time is spent in discussion of the impacts this development will have on the Bolsa Chica as a whole. This must be corrected in the revised and recirculated DEIR. Since the newsletters of organizations seem acceptable as scientific sources for this DEIR let me share one of my own. The Natural History Museum of San Diego Newsletter (see attached) documents in one San Diego least tern colony 60 of 120 chicks were killed by cats in a single night. There is a colony of endangered least tems on the south island at Bolsa Chica which at low tide is accessible to cats and other CB-24 terrestrial predators. Yet this obvious impact was not even mentioned in the DEIR. Instead cutting down the eucalyptus trees- roosting and perching habitat for birds of prey was justified as a way of reducing the impact of predation by raptors on the birds in the wetlands, when there is no evidence that the predation is significant. This again points to the biased nature of the DEIR and its limited scope. The DEIR even seems to blame the presence of crows at Bolsa Chica on the eucalyptus trees, when it is urbanization which attracts crows into an area. Crows can be an important predator on the least tem: I have personally observed crows eating eggs and chicks at a colony on Terminal Island. Also this summer (June 1998) crows have been a major source of predation on the elegant tern nesting colony on the north CB-26 nesting island at Bolsa Chica. They raided nests of the elegant tems consuming most of the eggs from the first nesting attempt (pers. comm. Dr. Charles Collins). The construction of 200 units on this site will only attract more crows into the wetland area both during construction and after. Why was this impact not mentioned ? The impacts of crows and attraction of crows into the area by the trash generated during construction and the use of the area for residential housing must be addressed in the revised recirculated DEIR. The DEIR does admit that the removal of active nesting sites for birds of prey would be a significant impact. To mitigate for this the trees which have active nests will be removed during the non breeding season only. And the DEIR suggests that because there are eucalyptus trees on the Bolsa Chica Mesa there does not need to be any replacement of the lost nest sites. It should be evident to any biologist that in an area like urbanized Orange county competition for nesting areas among birds of prey would be great. The birds displaced by the removal of the trees on the Shea property can not CB-26 just elbow their way into existing nesting territories of other birds on the mesa. They will be instead forced out of the area or in turn force other birds out of existing territories. Why was this impact not mentioned or analyzed? Also while the Land Trust currently has a legal case on appeal which if won would prevent the destruction of the eucalyptus grove on the mesa, a loss in the case could result in the destruction of the trees. So there goes the habitat which the DEIR implies could be used by the birds displaced by the destruction of the trees on the Shea property. This impact needs to I(Cont) CB-26 be addressed in the revised and recirculated DER The DER also claims replacement trees are not needed because the birds are not "sensitive species" . However, the DER admits that in June of 1997 a pair of white tailed kites was seen roosting and foraging in the eucalyptus trees on the northern margin of the Orange County area. The bird's behavior may have indicated a local territory. Last year there were at least three active nests of white tailed kites in the eucalyptus grove at Bolsa Chica. White tailed kites are a sensitive species. If these CB-27 birds are nesting on the Shea property then mitigation for a sensitive species would be required. One cursory examination for nests as mentioned in the DER is not enough when obvious evidence exists that the white tailed kites are present and nesting the area. Why does the DER does not address this? This needs to be addressed in the revised and recirculated DER. Besides cats and other domestic pets having significant impacts on the wildlife of the ecological reserve, lighting also can affect wildlife. The DER discusses mitigation of light impacts to surrounding neighborhoods, but does not address the issue of how the CB-28 lighting from this development will affect wildlife in the wetlands and on the Bolsa Chica mesa. This also should be addressed in the revised and recirculated DER The twenty sixth page of the biological resources states "No sensitive plant , invertebrate, fish, amphibian, or mammal species are known or expected to reside within or occur in a resource dependent relationship with any portion of the overall 49 CB-29 acres". This statement is contradicted by the presence of the white tailed kites on the site and the monarch butterfly. Please address this contradiction in the revised and recirculated DEIR. The DIER also discusses improvements which will need to be made to the Wintersburg Flood Control Channel, yet no mention is made of the impacts these improvements will have to the sensitive species which forage in the channel. The California least tem, California Brown Pelican, (both endangered species) elegant tern, common loon double crested cormorant, long-billed curlew,_California.gull, .black.skimmer (all ._... .� --..-. species of special concern) are only some of the sensitive species I have observed hunting in the channel. In addition I have seen migratory waterfowl such as American wigeon, cinnamon teal, green wing teal, northern shoveler, pintail, scaup, bufflehead, and mergansers in the channel feeding. Also commonly seen in the channel during CB-30 the winter are eared and pied billed grebes. Migratory shorebirds such as dowitchers, western and least sandpipers, marbled godwits, willet, black-necked stilts, killdeer, and avocets forage along the channel. Belted kingfishers forage in the channel as well. I have included the latest Christmas bird count done by members of the National Audubon Society. This demonstrates the number of birds seen at Bolsa Chica, including those seen from the Wintersburg flood control channel during one survey on January 4, 1998. 1 have added this to my comments because it demonstrates the importance of this site to migratory birds. The Shea property is part of the larger Bolsa Chica ecosystem and the revised recirculated DER should recognize this. How will these birds be impacted by the changes to the flood control channel and the construction activity on the Shea site during housing construction? This is not CB-30 addressed in the DEIR and is another example of its inadequate scope. Please (Cont.) address this issue in the revised and recirculated DEIR. The DEIR also mistakenly claims that no migratory birds use the seasonal ponds on the Shea property. I have personally seen American wigeon, cinnamon teal, ruddy ducks, Canada geese, black necked stilts, dowitchers and western sandpipers utilizing these ponds along with mallard ducks and killdeer. These observations were based on only a few visits to the site during the winter of 1997-1998. The erroneous CB-31 conclusion in the DIER that migratory birds do not use the ponds may be as a result of not visiting the site at the right time of day or with enough frequency to make these observations. Please correct this statement in the revised and recirculated DEIR and address impacts this development will have on these species. There are plans to move over 200,000 yards of soil from the Bolsa Chica mesa to the Shea site. The road from one of the "borrow sites" will pass right by the eucalyptus grove ESHA on the Bolsa Chica mesa yet there is no mention of the impact this will CB-32 have on the peregrine falcon and the white-tailed kites which use the area. Both of these birds are sensitive species. Please address this in the revised and recirculated DEIR. The eucalyptus ESHA depending on the outcome of the Bolsa Chica Land Trust's lawsuit may be retained in its current location and will need buffers around it. How will CB-33 the movement of this amount of dirt affect this ESHA ? Also-the Koll Company (CCCI) can not get any grading permits for their land until they donate land to the County of Orange for the Linear Park. Yet the County is refusing to CB-34 accept the land since it has active oil.leases on it and is contaminated. How will this affect Shea's ability to get permits to take soil from this site? Since I am a biologist, I have mainly limited my examination of the DEIR to the biological resources-section. However.there-is an obvious dangerous situation -- - - regarding the traffic flow that must be corrected. In the current plan there is only one way in and out of the planned development via Graham Ave. An accident at the intersection of Graham and the street leading into the development could prevent the residents from entering or exiting the area. Also in an emergency such as an CB-35 earthquake, flood or fire if many of the 200 households wished to exit the area at the same time there would be a huge bottleneck at this site. The suggested alternatives of an opening to Greenleaf, or a road up on the Bolsa Chica mesa to Bolsa Chica Street are also unacceptable. Greenleaf is a street in a residential neighborhood and the traffic impacts to the residents are unacceptable. Bolsa Chica Street also from Warner to its end at the mesa passes through a residential area. Also the environmental impacts of a street onto the mesa have not been adequately analyzed in this DEIR. This DER is inadequate in that it does not evaluate the impact of over 200 units with at least 500 additional people living virtually within the Bolsa Chica ecosystem. The scope of the DER is not appropriate since it ignores the impacts this development will CB-35 have on the Bolsa Chica wetlands and mesa. As I have pointed out numerous times it (Cont) is biased and does not adequately assess the impacts this development will have on the adjacent areas. Finally, there is an alternative that has not been explored which would result in the preservation of the land, while still allowing the applicant fair market value for the land. I would like to see an alternative of an land exchange for the Shea property seriously addressed in the revised recirculated DEIR. In the LA Times recently there have been CB-36 reports of the consideration of an exchange for the property Koll owns for land at the El Toro Air Base. Serious consideration should be afforded this alternative since it will result in the environmentally superior alternative while compensating the applicant fairly for their land. I request that the City Council require that a revised Draft EIR be prepared and recirculated if the project is to receive any more consideration. If the City Council votes CB-37 to deny the project then of course a revised document would not need to be completed. Sincerely, &"'Xd�j Connie Boardman Professor of Biology cc: Mayor Shirley Dettloff and the Huntington Beach City Council (without attachments) SDNHM Domestic Cats 4/28/98 7:50 PM CAT31 l San Diego Natural History Museum Killer Cats in Our County There's a little bit of wildness in every cat.Loveable,cuddly house cats, stray and abandoned cats, and feral cats are all instinctive hunters, and they are decimating small wildlife. Domestic cats are abundant, and their numbers are growing. Their population density is higher than that of any natural predator. It is estimated that the average well-cared for pet cat kills over 100 small animals every year.With 6.5 million pet cats and 3.5 million stray and feral cats statewide,the carnage is adding up. A Case in Point San Diego is a lovely place to call-home.Beautiful vistas,mild climate,beaches that are among the best in the world. People love it here too; our population continues to swell. It's a bittersweet story. As we colonize the land,its earlier inhabitants are often forced out. Pushed to the brink of extinction is the Least Tem. This deftly flying fishing bird makes its nest on sandy beaches. The beaches are now filled with people and - z dogs. If the birds are lucky enough to mate successfully, the eggs and chicks are easily trampled. Habitat loss is the greatest threat to wildlife. Predation is the second greatest threat to many species, and domestic cats are highly effective _ predators. In one Least Tem nesting colony, 60 of 120 tern chicks were killed by cats in a single night. Squeezed by a shrinking habitat,the Least Tem may always be on the list of endangered species. The good news is their population is rebounding. During the 1970s, 600 breeding pairs were counted in San Diego County. Now, the county boasts 3000 pairs. Protecting habitat and controlling predators, such as cats, are the key to preserving the Least Tem. A Win-Win Solution • Keep cats indoors. The best way to protect wildlife from cats, and the best way to protect cats from the danger of disease, cars, and coyotes is to keep them indoors.Collar bells do not protect wildlife from cat attacks. (In fact,pet owners are legally responsible for damage to endangered species done by their pets.) The American Bird Conservancy has some excellent suggestions on how to make your http://www.sdnhm.org/exhibits/cats/hunters.html Page 1 of 2 �R� N The 1997 Coastal CBC - Jan. 4, 1998 e sections of the Coastal CBC are listed below with their Count Leaders: (2) Westminster Mom. Park, Golden West & Corner SeoI Beach NWR - Vic Lei[5) zig. (3) Huntington Central Park, Wi Carr Park - Loren Hays. (4) Bolso Ch, _g_ Terry Graham Hill. Mile: Square Park - Mark Singer. SA River Mouth, HB Pier, 19th St. Willows, Lyn. ?oorrc, Golf Course - Jim Pie. (7) Older Areas in Santa Ana - Lois Lou hran. (8/9) Centennial ?ark, MCAS Blimp Base Dick Purvis. (10/11) West Side of Upper Newport Bay - Susan Sheakley. (gll/14) - Brian Daniels. (12) East Side of Upper lewport Bay - Dick Kust. 13 UCI, San Joaquin Marsh, SJWS - John Bradley. (14) Mason Park, UCI Foothills, Corona del Mar - Doug Willick. (15) Newport Harbor & Beaches - Phil Swan. (16) Pelagic Areas - Jerry Tolman.. Rick Derevan dealt with the legal aspects of obtaining ent �n pr i s Is in ve c of the d Buda ..Observed 2 7 .. >;>8 0' i.f 1: 1 >:: .. . . k 15:: ...7 Total loon,Red-throated - T 12 I 2 2 4 2 Loon, Pacific _------- 1 ��-11 — i t 1 2 11 8 _ 331 Looms Common __ T j i - 1 4 1 24 30': Grebe,Pied-billed__ - 4i 10i 6-1 10 9 1 - 8t 81 3 12 4 17 11 160, Grebe, Horned 4 1 11 I 4 1 1 1 3 2 16 jGrebe, Red-necked Grebe, Eared 11 41 5 2 5 5 13 31 14 18 147 Grebe, Western 81 61 19 - 472 239 48 25 310 500 5883 Grebe Clark's 1, 1 11 7 21 7 18. Shearwater,Sooty1 1 Shea_rwater,Short-tailed 1 1 Shearwater,Black-vented 22 1 410 4001 832 Pelican Brown 1 11 7 58 13 15 45i 270 100 520 Cormorant,Double-crested t 101 290 38 282,, 22 9+ 6 21 231 17. 28 13 1084 Co mrorant Brandt's 1 60 i 19 59 —ndrl- 25 Cormorant, Pelagic 2 1 4 2 2 10 1 HECaffle at Blue 3 9 20 1 4 4 13 12 9 1 76 I Et 2 47 17 8 2 2 8 2 1 6 9 6 128' ;Egret, Snowy 9 38 4 8 11 5 8 20 1 13 4 6 14 185': Holored 1 j I 3 3 Heron,Green 21 1 1 1 1 1 7 Ni ht-heron,Black-crowned 1 3 28 2 6 5 1 20 1 101 Ibis White-faced 15 15 Goose, Ross' If Goase, Canada 5051 i i 10 8 221 545 `Neal,Green-winged 51 i 2! 112 201 159 33 , 1031 778: 'Mallard 108 32 1021 221 130 60 111 153 20 148 11 50 8 1442 Pintail,Northern 150 156 81 96 ! 1941 201 3 2040 Teal, Blue-winged 6' 1 131 7 141 40 'Teal, Cinnamon 2 41 121 1 12 I 28 1 531 61 3 120 Shy oveler, Northern 1 201 450 131 4 601 40 11 141 4391 180 1225 Gadwall 12! 79r 1 21 11 i 6 i 351 1 165 i i eon, Eurasian 1 2 Wi 1 i 1 4 1 Wi eon, American 521 1871 494 3301 103 52 2081 237 78 18 100 1859 Canvasback 1: 2 24 9 44 40 Redhead Duck_ Ring-necked 2: 3i 1 - 6 Scaup, Greater 1 `-j Scaup, lesser 2: 65 34 5, 1 88i i 1551 1 60 i 1076 Scoter,Black _ 1 Scoter, Surf -�� 3 199 ! 10 37 63 100 984 Scoter,White-winged Bufflehead i 231 8,1 209 32 351 06 32 21 3 101 460 Mer ,anser Hooded t 1 1 Merganser, Common t 1 1 Merganser. Red-breasted i 10' i 14 6 30 .Duck Ruddy`_ 9 94 66 241 451 231. 2101 121 147 1581 78 2 147.1 V�!Lure,__� y_ 3: 8i 4 1 13 5! 22 15 31 48 1 123 :ite White-tailed 2 2' 4;. _ 4 Harrier,Northern 1 1 9 1; 5; 6' 61 1 30 -+---�-- Hawk, Sharp shinned - --- 4t 3: 11T--_2-- - 1 4 2; 2 1' '- -21 --�-- - r- —-- �---� _31 4� i 1. 3. 2 _ 2 1 1 2 1 _ 20` Hawk,Red-shouldered 21 5 i 2,i 1 _ 1 2 i 2 2, 8 _ 26 Hawk, Red-tailed_- -- 18! 14t 22 61 14 1 6 15 3 7 10 17 1 134 - i -- . Eagle,_Golden_ _ -- � ' _' _ i �-i--- � i _ _ _ 1 Kestrel, American �- 7T-7r _112 -6�_ 1 _7 - Z�~rt` 3 1 5 1 - 6_2 Merlin -- - - - -t --- 1 2 - 1 6 Quail, California -- - --- -- ----- - -—; - ----- 37 3 7 51 4 _9 -om 524 i.SRIHer e •�uj uburlis - - _ page 8 -'X- /nd%Ca#eS r0 QCe- luiR% Ae �ert vzL.ider:Ns ' -Nh�h /998 Cou,.,# &C tA41- 4joea'es The 1997 Coastal CBC - Jan. 4, 1998 o participated on this count: Kimberly Abe, Libby Applegate, Charlie Austin, Doris Banks, Helen Bellinger, Betty Bob Brotherton, Sean Burns, Lynn Chapman, Barbara Chidester, Deana Collins, Carolyn Cooper, Jean Drum, Fresia Judi Fritts, Virginia Gochenour, Marcia Griesser, Bob &Marcia Holcomb, Martha Hunt, Sarah Jayne, Lois Jones, Nancy Kenyon, Pdy, xfield, Dick& Lee McDowell,Anna MacLean, LaRae Parry, Betty Purdy, Carolyn Rapp, Barbara Reber,Jim &Jennifer Robins,John ary Lee & Doug Smith, Bev Spring, Alice Verano,Twila Walker, Cat Waters, Ann Zemer. seen during count week but not on count day: Wood Duck, Eurasien Teal Red Knot, Great Homed Owl, Gray , Summer Tanager, Rhinoceros uklet. 4U R OF SPECIES 196. U F V UA I 7 . E-y4 BEII ,C, B E RS 87 moorhen, Common INV 1 1 1 31 1 7 Coot, American 136 270 147 666 80 3 735 623 250 560 269 851 15 5930 'lover, Black-bellied 15 12 204 121 7 1799 'lover, Snowy 3 ' I 9 'lover, Semipalmated j 1' 44 15 64 ! 341 295; Uldeer 50! 7 161 7 21 i 151 �8 _ 190 Stilt,Black-necked 1 90 i 18: 33 l: 19'2 4; 121 606 4vocet, American 5' 23• 1 4` 95 1331C 17 1 278 Yellowlegs, Greater 1 6 3' st 1 5i 3 71 1 1 6 39 Yellowlegs, Lesser 1 1 4 I 5 fillet 45 13 41 2 99 781 5 33 440 rattler,Wandering2 3 5 Sandpiper,Spotted 21 3 5i 2 291 ir 1 44 Whimbrel 1 21 1• 1 2 16 Curlew Long-billed 1 51 2 29 161 2 54 Godwit,Marbled 63 751 751 1 43 118 190pr 5 6 16 592 Turnstone Rudd 4 2 6 Turnstone Black 5 1 0 Surfbird 8 1 26 Sanderling_ 3; 76; 4 76 159. Sand iper, Western 171' 368 6: 100 630: 60: 2242 i Sandier, Least 19� I i 24: 4' 155 7' 14 1 225` Dunlin 21 38i i 26 71 73 Dowitcher, Short-billed 1 1 1 3 Dowitcher, Lon -billed 1 4 5 11 1 5 5 20 Snipe, Common 81 1 30 4 1 43 Jaeger, Pombrine I 1 1 2 Gull,Laughing1 1 Gull Bona arte's F1 1 36 311 2; 641 800 1792 Gull Heermann's 193, 35 264 500 992 Gull, Mew I 51 4191 3 1 1 3 2 434 Gull Ring-billed 3131 3351 308 64 1231 35 199 77 173� 17 104 81 f 2414 Gull Califomia 117 210; 6: 281 : 16151 2, 1I 39 i 14 48 370 50 3: Gull,Herring 3! i 1 9i 13: Gull,Western 1 27 2 8 216! 1 4 43 1 75 41 2001 9931 Gull Glaucous-win ed 1 6' 2: 11 10 Kittiwake,Block-legged 1 1 2 Tern, Caspian 1 31 1 31 7 26: 4 1 1 46 Tern Royal ' I 1 1 , Tern, Forster's 1; 16 171 381 10 29; 2 25 1 11 10 266 Skimmer, Black 1 14 25. 39; Dover Rock 257E 136 341 4541 1221 4531 2141 299 10 49: 50 77 1 21551- Dove, Spotted 8. 71 6i 3 4 2 30• Dove,White-winged Dove, Mourning 1121 69; 1191 1 95i 45' 161 96 301 98; 101 1381 35 ! 013' Ground-dove, Common J_ 19 +_ ' 171 136' Roadrunner,Greater 5. 5: Owl�Common Barn 1 Owl,Burrowing1 1 Swifts White-throated i 33 22 55 Humr s 43' 341 35 35 100 27 251 57 601 80 20 141 57 Hummingbird,Costa's _ 1 I i 1 Hummingbird,Allen's 8' 8 71. 1 6 11 14� 27 e67 Kin fisher, Belted 1 31 31 6 _ 3� 2 3: 20, Woodpecker,Acorn 7 7 Sapsucker,Yellow-bellied Sapsucker, Red-Hoped _ 1` Z' Sapsucker, Red-breasted Woodpecker,Nuttall 2� ''s_ 1 1 __ _ Woodpecker Downy —r-1; 2' 1 1?— 1' 1 1 2 7 13'• Flicker, No. Red-shafted 91 2 1 4 ill 1 2 3 3 41 120 52 Flycatcher Hommond's 11 1 Flycatcher, Dusky Flycatcher, Western/ ac- PSI I i 1 2 3, 15 W,i4e_r51oL r9) \A-C•P+-Carr (park -page 9- A./ r, A * tih 04 E r� _ 1 i WS ,.T fib fe - , -- _ y"• �� N'. f e . 1 1 TRES • 6i % y. VIOLATORS SUBJECT TO ARREST 1 PLANTED FIELD KEEP_OUT ! REWARD LWMF _ FARM BUREAU t .A. J.Yh w.'♦ �x � `'-/�.-r,. s:" ��•���'u•.F'T...�7I!��,".;I4�� i !. I[ fhb _ �` p,r r 1 ♦ . ;{ ?�["i':,5. r .•'. • .. '/Ma§..r?�.-�.�/ • / Ire 1 r I • • 1 ♦ • I / / I ♦ ♦ • r / r f • % �I-OAJA1 r i � cze c. fI_ � Shea. iTro-e f-- -�o-ken -�-ow\ —e-)er m W i n-)ers bu f-j F(oc1 6ct461 Cnannr.) Slnowrny -Fle )d o "Crods (9-12 98 cD }r t Shed �ro n �ro✓h Si�ble ar2i� {pWnrd Flood C&fltoQ C-� Shou�in�( d,ea I g�oirzoin crops. -��� _ .,� _ �� + �_ � - ii� � ,- _ _ '�. � f �� f � . OvIarYmoC, V,eL() -bp� Shy Pro" 1ookitq nof4+ard_ eaS . This g 6w,; V l�� P��tn ot� 2 5ct�J �tR FCeAA 5 SDmR lC r�l I„ 41'sc� a n� 0� Ledo. �.ess 'f'�D.r z D � � acres Of�� i vl ���ded C-P(�ear ( �vz crops t• r 1 !tr . �; y � •r .p � 4 .. • ;, < r � f }Y , ' fl �'J ,i•� 1 �� � F 1 1' • � R - • 1I /�/ / 1 1 63 To: Jim Barnes, Project Planner City of Huntington Bea JU From: JohnE. Scandura, C CGT '' T Environmental Boaz Subject: ENVIRONMENTAL ACT REPORT (EIR)NO. 97-2 Date: June 12, 1998 The Environmental Board is pleased to present its comments and findings on the Environmental Impact Report (No. 97-2)for the proposed Parkside Estates Development. The project entails the building of 208 homes on an approximately 50-acre site located west of Graham Street and south JES-1 of Warner Avenue. About 4.5 acres of this site is within unincorporated land where 27 of the homes would be built. The project envisions that the City would annex this unincorporated land. Approximately eight acres of the project site would be set aside for park and natural open space. It is the position of the Environmental Board that deficiencies in this project exist that have not been addressed by the EIR. These deficiencies include: • adverse impacts upon the restoration of the adjacent Bolsa Chica Wetlands and a JES-2 greenway associated with the proposed development on the Bolsa Chica Mesa. The new homes would block the greenway and preclude habitat conservation or restoration opportunities that would augment this greenway and restored wetlands. • development on the 4.5 acres of unincorporated land will destroy an existing wetland and a portion of a significant archeological site. The homes on this unincorporated parcel are JES-3 most likely to conflict with the planned wetlands restoration and proposed greenway. As such, no development should be allowed within the unincorporated portion of the site. • removal of 470,000 cubic yards of fill from the adjacent Mesa for recompaction during site grading will adversely impact natural habitat. As the Mesa development is the subject of litigation, must receive Coastal Commission approval, and has been proposed for land JES-4 swaps in order to preserve its natural state, the Mesa may ultimately not be developed. The borrow pits created by the fill removal would adversely impact habitat on the Mesa and create problems for plants and wildlife should the Mesa be preserved. • The 208-home development has only one traffic outlet onto Graham Street. This outlet will require a signal to prevent traffic accidents and will be in close proximity to several JES-5 other streets that intersect Graham. A second outlet is necessary to relieve traffic congestion at the Graham Street outlet and reduce traffic impacts on Graham. Because of these deficiencies, the Environmental Board takes the position that the City should not certify the EIR and approve the Parkside Estates Development until these issues are resolved. 1JES-6 The Board also offers the following comments that should be addressed in the EIR: JES-6 Cont.) Transportation/Circulation- Although the EIR states that traffic impacts can be mitigated, there was no discussion of the effect of traffic going into and coming out of the fully developed tract during morning and afternoon peak traffic hours. A somewhat smaller tract located south of the project site and identified as "Area 4" on page 5-5 of the EIR also has a single outlet onto Graham Street. The EIR should discuss any access issues associated with this tract's single outlet and JES-7 determine if such problems would arise in the proposed project. There was also no discussion of traffic problems associated with vehicles trying to exit the tract onto Graham Street in the event of a natural disaster. Given the large number of homes and immediate proximity of the primary outlet to other streets that intersect with Graham Street, the Board believes that a second outlet should be constructed to reduce traffic impacts along Graham Street. Aesthetics- As homes would abut Graham Street, a wall is necessary to provide privacy to the back yards. This wall would obstruct the current view of the hillside and nearby wetlands. Although it has been suggested that relocating the proposed park next to Graham would mitigate JES-8 this impact, other problems may arise for children using this park if it is located next to a significant thoroughfare like Graham Street. The Board suggests that other mitigation measures be considered to eliminate the wall's aesthetic impact. Earth Resources-Because of the adverse impacts mentioned previously, the City should not allow the import of fill from the adjacent Mesa unless associated litigation has ended and final regulatory agency approvals have been secured. If an alternate source of fill is identified, JES-9 mitigation measures will be necessary to reduce the traffic, noise, dust and air quality impacts from trucks arriving and leaving the site. Biological Resources-the portion of the site located on the unincorporated property is believed to be a remnant of the historic wetland. Areas of pickleweed and other wetlands associated vegetation were noted in the biological survey of this parcel. The U.S. Fish and Wildlife Service commented that homes proposed for the unincorporated portion would intrude houses into the JES-10 lowland, block a greenway connection between the proposed park and flood control channel, and preclude habitat conservation and restoration opportunities along the greenway surrounding the California Coastal Communities Development and adjacent wetlands restoration. The EIR did not address this comment. There may be disagreement between state agencies as to whether wetlands exist on the City portion of the project site. The United States Environmental Protection Agency(USEPA) delineated 8.3 acres of a lowland area on the City parcel as jurisdictional wetlands in 1989, but the United States Army Corps of Engineers made the opposite determination in 1992. However, California Coastal Commission staff has raised the issue of whether wetlands are present while JES-11 the California Department of Fish and Game has concurred with the developer's biologist assessment that wetlands no longer exist on this parcel. It is advisable for the City to seek resolution from these agencies on whether the 8.3 acre area delineated by USEPA as a wetland is a state jurisdictional wetland before allowing development in this area. Cultural Resources- as stated previously, the portion of the site on unincorporated land is within a major archeological site, CA-ORA-83, also known as the Cogstone Site. The archeologist performing the assessment believed that "preservation of those portions CA-ORA-83 on the Shea Homes Property through complete avoidance would still be the most appropriate mitigation option for this site." This archeologist also stated that this option "is likely to be the best in the long run from an archeological standpoint." However, the EIR cited another study that concluded JES-12 that the portion of CA-ORA-83 on the project site is heavily disturbed and has a low potential for containing intact and undisturbed artifacts in any abundance. The Environmental Board believes that the archeologist's opinion is correct and that no matter how much disturbance has occurred in the past, a major archeological find such as the Cogstone Site should not be developed since it may still yield significant artifacts in areas not yet excavated. The Environmental Board thanks you for the opportunity to comment on this very important EHL JES-13 if you have any questions, please do not hesitate to contact me. 64 DR ROBERT E. WINCHELL DEPARTMENT OF GEOLOGICAL SCIENCES CALIFORNIA STATE UNIVERSITY LONG BEACH 6411 WEBER CIRCLE HUNTINGTON BEACH, CA 92647 ID June 12, 1998 FIE Mr. Jim Dames Project Director,Parkside Estates .�_ ��, ,3 L jpN[ENT 2000 Main Street L�Pi.�� Huntington Beach,CA 92648 coet„�iujT� Dear Mr. Dames. I have been asked by citizens and citizens'groups in Huntington Beach to comment on the and content, especially the geological quality and content o the Parlmde Estates E1R#97-2 REW-1 Environmental Impact Report (DEIR)prepared for the city of Huntington Beach by EDAW, Inc and dated April, 1998. The comments which follow represent my response, as time has allowed, to those requests. As you may be aware, I am also a resident of Huntington Beach and, therefore, supply the following comments on that basis as well. As the comments, questions and statements which follow REW-2 indicate,I am not only very concerned about this project as a professional geologist and a resident but as a taxpayer who will uuhimately wind up paying the bias for continued development projects in areas lice this. In addition to being a professional geologist, I served on the Huntington Beach Environmental Council for several years in the early 1970's. In that capacity I had the opportunity to review a large number of environmental impact reports, statements and negative declarations. I have also, REW-3 in the interim, periodically reviewed environmental documents and reports for the Bolsa Chica area. The comments below reflect, therefore, both my profi+sdonal experience and the experience developed from the review of documents like this EIR. GENERAL CQMM ENTS 1. The letter and spirit of CEQA require that an EIR statement be a fun disclosure planning. and decision-oriented document. In contrast to a negative declaration, an EIR is meant to provide both the public and all decision making bodies with a clear, impartial, concise statement of the potentialenvironmental impacts, potential imp assessment of the via and level of � � � these acts and as viability mitigation attainable for potentially adverse impacts The document is meant to inform the public and decision makers in the fid km t possible manner so that appropriate decisions which protect the public's interest to the fullest can be made. As sudy the docua>ent must be based on completed work, not on work to be done in the future, and mast REW-4 provide the fidest technical and nontechnical evaluation of impact and mitigation measures possible, couched in terms that can be understood fiully by the public and decision makers who may not be conversant with all the technical aspects involved In my opinion, an opinion based on the cotes I have made below and other observations which I do not have time to put dawn on paper, this document does not accomplish these ends Consequently, it is, in my opinion, not acceptable in its present form and should be rejected until it does meet the accepted standards of such a work and the letter and intent of CEQA. 2. Further, since this document will be reviewed by both technically and nontechnically oriented individuals,it should be written and should include appropriate material to meet the needs of both REW-5 in so far as possible. As is both indicated and implied in the comments below, this document fails to meet these needs. 3. The project and associated alternatives which are the subject of this E1R involve incredibly important decisions concerning the safety, health and economic welfare of the projected residents REW-6 and may or will have associated repercussions, some of which may well be irreversible. 4. The EIR should have been set in a format such that the lines are numbered on a page so that comments and questions may be more easily related to the information supplied. Because of the scattering and mixture of topics this has not always been possible to relate comments and questions to a given topic and the related discussion. An attempt has be made,therefore,to relate REW-7 the following comments and questions to at least one item in the body(first volume)of the report to which the item is relevant. Responses should, therefore, be taken as applying to any and all places where a given matter is considered and the response is appropriate. 5. The information which is presented in this report is, in my opinion, disorganized, incomplete and unnecessarily repetitious. A reviewer is left to synthesize the material for himself or herself having to go back and forth between and within the volumes in an attempt to be sure that a REW-8 coherent body of material is available for both specific and overall evaluations. The result is unnecessarily bme-consuming and fivstrating not only is terms of trying to trying to make an evaluation but especially so when one tries to make comments. SPECIFIC COhPdENTS Section 5.6 Earth Resources This section is mistitled. What is supposed to be being dealt with here are not earth resources but a geological assessment or evaluation of the site as part of an environmental evaluation of the REW-9 project. Such an assessment or evaluation, most often these days, is referred to as a geotl assessment (or evaluation), as PSE has referred to this kind of information (Appendix E) and is said to have prepared. EXISTING CONDITIONS 1. P. 5-119. paragraph 3: The comment " a few feet above sea level" is insufficient to provide a feel for the flood potential of this site, as the reviewer attempts to get a picture of the potential on this site as the geologic REW-10 evaluation proceeds. Numbers need to be used. Why have they not been used? 2. Ibid.: Fill soil site(s) need to be delineated on the maps provided in this section and &wwhere, since they are important in the assessment of the relevancy and necessity associated with such things as the site preparation, e.g. earthwork specifications including grading (Appendix E, Appendix V) and earthquake wave amplification(not considered: see comments elsewhere). Only two areas of REW-11 fill are shown on the exhibits (Exhibit 38 and 41) and these are not in the area discussed in the text. What is the relationship of the fill areas discussed to the lots and associated projected houses that would be involved in the development? '&ad aphy/Subsurface Soils 1. Ibid.,paragraph 5: The channel deposits referred to are apparently,if properly referred to, stream deposits and would include not only stream channel deposits but flood plain. deposits. Is that not correct? Of what REW-1'. significance are the different kinds of sods and their interfaces? 2. Ibid. and P. 5-120,paragraph 1: There is insufficient information and lack of the necessary associated discussion for a reviewer to get a picture and make an assessment of the inhomogeneity of the surficial material on this site. Why have aerial photographs and a relevant discussion of these photographs not been provided to show this inhomogeneity, distribution of deposit types and location of such things as ancient channels been provided, especially since photographs were available and have been discussed for REW-13 historic use purposes in Appendix E? Why have fence diagrams not been provided to show the subsurface distribution of the sediments? Where is a discussion of the inhomogeneity of the sediments on this site and its relationship to the development of this site? Photographs and diagrams would make sediment distribution relatively clear to anyone interested in determining the level of knowledge and possible constraints of the proposed residential constriction on this property. 3. P. 5-120, paragraph 1: Groundwater distribution and depth on the site are important, not only to the geologist for geotech6cal considerations, e.g. liquefaction considerations, but to the biologist for wetland considerations. Yet, outside of very general comments such as those on this page and the REW-14 individual water depths indicated in the boring information in Appendix E, there is no summary information on the groundwater distribution, such as a map (or maps) of groundwater distribution, including surface water. WhY has such information not been included? Why have fence diagrams for groundwater distribution, scaled to show where information is known and what information has to be inferred for water distribution,not been provided? 4. Ibid.,paragraphs 2 and 3: What does "in the vicinity of borings B-2, ..." mean with respect to peat and peat distribution laterally and how was this determined? What is the lateral extent of the peat and what surface sampling controls lead to this determination? The answers to this and other questions of hike nature are important from a remediation standpoint and vitally important to a homeowner who will occupy the lots where no testing has been done. How is the homeowner to be assured REW-15 there is not a pocket of peat under the lot or that a peat layer does not extend under that lot? Or is the site to be excavated to a uniform level across the site to remove the peat or possible peat and, if so, to what depth will that excavation occur(see item 7 below)? Who will be responsible for problems associated with any undetected peat deposits? 5. Ibid.. paragraph 3: Where is the evidence, e.g. logs,, etc., to support the statement that peat layers are two to three feet thick in the upper five feet of the site? No thicknesses for the peat are shown on the pictorial REW-16 logs presented and the peat and organics are not broken out from the other sediments as separate thicknesses in the pictorial or text presentations. 6. Ibid.: Considering the thickness of these deposits, the word "could" in the context of the residential development is incorrect. The phrase "would unless appropriately mitigated" is the correct REW-17 description of the situation. 7. Ibid.: In view of the previous comment and question and the statement that significant deposits of peat have not been observed below minus 5 feet,what does"significant"mean and what about the peat observed at depths below five feet in the LeRoy Crandall and Associates(LC)borings 5 and 10 in which peat was observed? Further,from the PSE report, it would appear that the peat can extend to at least six feet, not just five feet (PSE trenches 1 and 6, for instance). What about the "rootlets which are cited as abundant in trench 12 the PSE trench, where they could apparently extend to depths of eight feet?If organics are being equated to peat, organics have been observed to greater depths, e.g. LC boring 5. Stoney--Miller routinely did not sample between REW-18 approximately five to six feet and approximately nine to ten feet. What evidence exists that there is not organics (including rootlets?) or peat in these intervals and would it not be necessary to know the extent of these organics to have a proper evaluation of potential settlement and to recommend excavation depths for mitigation purposes? Also, LC found organic matter at depths significantly greater than five feet, e.g. Boring 1. In this same context, see also PSE borings, e.g. HS-1. What is expected to be the impact of such material and what would be the remediation necessary for any impacts, such as settlement? SdNgP#Y 1. Ibid. and P. 5-121: Together with potential flooding of this site, the presence of the Newport-Inglewood Fault and Fault Zone, in which the Bolsa-Fairview Fault should be included, and the associated hazards are the single most important factors which bear on the proposed development of this site. As indicated by the following comments and questions, one brief paragraph in the body of the EIR is REW-19 totally inadequate to provide the reviewer with the information, and, therefore, the full disclosure necessary to evaluate the fauh- and earthquake-related hazards and their effects associated with the proposed development of this site. This situation is not remedied adequately by referring to the PSE report. 2. Ibid.: A reviewer should be provided with a good map of the N I fault zone and recognized and 'inferred fault limes in the main body of the report or, at the very least, referred to the map (which itself requires amendment) in PSE report in order to be provided a good idea of the relationship of the fault zone to the site. Further, the Bolsa-Fairview Fault, which is, or would be, part of this zone REW-20 and bisects, or would bisect, the site is not shown on the PSE map or on any other map in this report. Such a map would have to show the proposed housing and be at a proper scale for a reviewer to be able to determine the potential effects of fault displacement and associated activity on the homes proposed for this site. Why has all of this information not been provided? 3 Ibid.: A reviewer should be apprised of the fact that the near surface manifestation of this fault zone in weak, unconsolidated sediments, such as those found in the Bolsa Chica proper and on this site, can be expected to be a series of en echelon shears like those possible in a deck of cards on its side, so that localized shearing and associated ground displacement may occur at any place in this zone. It should also be pointed out that the dotted lines commonly used in this zone to delineate fault segments are extrapolations of places where the fault segment displacements have come to the surface in more consolidated and better cemented materials, e.g. the bluff areas, REW-21 and/or other areas where trenching, borings and drilling have encountered more consolidated materials capable of preserving fault displacements and allowed some degree of extrapolation to the surface. The point should be made here that, as long as there is some evidence for subsurface faulting, the unconsolidated materials like those found in the Bolsa Chica, including the Parkside site do not necessarily, and often do not, preserve direct evidence of the presence of a fault or its recent activity and that these considerations are particularly important in considering the potential for activity along, and adjacent to, the Bolsa-Fairview Fault associated with the Parkside property. Why has this information been provided? 4. Ibid: To what does"two" apply? This sentence seems garbled I REW-22 5. Ibid.: The N I Fault within the fault zone is considered by most geologists to be the single most dangerous fault in California. The reason is that housing lice that proposed for the Parkside REW-23 Estates site has been bunt all along this fault on sediments like that present on this site. Why has this information and a relevant discussion of this information not been included in the general consideration of the geology and seismicity of the site? Potential for Ground Rupture 1. P. 5-121,paragraph 2(See also P. 5-126 to which these same comments apply): Perhaps active faults, as defined for statute purposes by the Alquist-Priolo Act, have not been reported within the project site. One fault has,however,been reported within this site and has not yet been shown not to exist. In point of fact, there is compelling evidence that this fault is present. Only the activity level within the last 11,000 years is currently in question and, although it may not conform to strict statute criteria in the opinion of Bryant(1985)and has been removed from coverage by the Aiquist-Paolo Act,this does not mean that it does not exist,that it does not have to be considered in a geologic and seismic evaluation of the site and that site inv=mcued REW-24 should not be done to determine whether it is present or absent, especially since it is more than once in this report that such work has not been done. Just as the risk and potential effects associated with an earthquake along the N I Fault Zone have to be dealt with so do the risk and potential effects of the possible presence of the Bolsa-Fairview Fault on the Parkside site have to be dealt with. The E13L is inadequate and incomplete without this information. Why has the appropriate information on and discussion of this matter not been provided, including reference, at least,to the summary provided by PSE in Appendix E? That summary belongs in the body of the report,not in an appendix. 2. Ibid. (See also P. 5-126 to which these same comments apply): In view of the evidence cited in the geologic literature and summarized, for instance, by PSE in Appendix E, the last statement in this paragraph is, at the very least, unsupported, unwarranted REW-25 and misleading to anyone trying to evaluate the seismic hazard level from surface offset and ground rupture on this site. Instead, one would have to say that, if the Bolsa-Fairview Fault traverses this site, the potential for ground rupture would exist and that, in such a case, structural damage and even personal injury or worse could result. Why has this information and an associated discussion been included? Strong Ground Motion Potential A discussion of the past and expected earthquake magnitude(s) associated with this site and they relationship and relevancy to this project needs to be included in the body of this FIR, not leg to the reviewer to synthesize. There might at least be a reference made to Appendix E for magmuittude values to be expected and those that have been used for ground motion and shalcing considerations. Only one aspect of ground shaking has been included here, ie. ground REW-26 acceleration and its calculation. Where,for instance,is all the information on earthquake intensity and its associated effects as related to this site, both past and projected, e.g. a table relating intensity to its effects and a discussion of earthquake intensity, both historic and projected, and their relevancy to this site? It is common practice to include this latter information in an acceptable EIR. IMPACTS/MITIGATION/LEVEL OF SIGNIFICANCE 1. P. 5-125,paragraphs 2 and 3: The implication is that, design with reasonable construction and/or maintenance will overcome significant impacts of liquefaction and apparently reduce them, as subsequent discussion terms it, to less than significant. Is one to conclude from this discussion and what follows, therefore, that people and structures will no longer be exposed to major geologic hazards and health hazards with the construction of this project as mitigated? For this to be tree it would be necessary to REW-27 show that with the use of the mitigation, remediation, etc. recommended here that projects like this, located on similar foundation material; with simiar proximity to an active fault zone; and with the possibility of a splay of this fault zone or another fault through the center of the project, have survived project design-level earthquake related problems with "less than significant" levels of impacts. What are some examples of such projects and what are the impacts and levels thereof on such projects? 2. Ibid.,paragraph 5 ff and P. 5-131-132 LEVEL OF SIGNIFICANCE: The phrase "less than significant" is used in a number of places in this EIR When the term is coupled with the concept of reduction to less than significant, use of the term implies that the matter being considered has or can be expected to have a significant impact. In order to determine whether or not the term less than significant applies, one needs to know what that term means in actual practice, i e. the real world; by whom it is being defined, and on what basis relevant to actual practice and to those who will be subject to any impacts this term is being REW-28 applied What does"less than significant"mean in actual practice, e.g. kind and level of impact to structures, humans, etc. after completion of the project; by whom would it be defined, e.g. the developer, the future resident and homeowner, city and other government agencies, the general taxpayer, aH of whom have a stake in the outcome of this project; and what are the bases for the application of this assessment? More specifically, what kind and level of damage can be expected to residential and public structures,including infrastructure?re? Also specifically,what kind and level of injury can be expected to be associated with this level of significance? 3. P. 5-122, last paragraph: 1 to 4 inches of settlement can be expected from the assumed design earthquake even after mitigation(p. 5-122). What does this mean in terms of structural damage? How much such movement can the structures proposed for this develop me i undergo without beginning to break up? What level and kind of damagelmjury would be result from such breakup, REW-29 e.g. with respect to a residential structure, streets and water and sewer pipes? What is the mitigation for this that the project or project proponent will provide? Are we to assume, for instance, that the property owner will consider any breakup that might occur to be less than significant,if repairs must be performed? 4. P. 5-125: paragraph 5: To what depth is excavation for peat (and liquefiable) materials expected to be necessary, especially in the context ofthe comments and questions raised above on REW-30 peat and its location? 5. P. 5-126, paragraph 2: Where man-made fills have been used over natural materials like those found on this site, the area involved has generally been shown to suffer the greatest damage in a damaging earthquake, when compared with adjacent areas where these natural materials are not present. Apparently, this increase in damage occurs because of wave amplification (shaking REW-31 increase) at the interface between the fills and the natural materials. Fills are proposed as part of the mitigation for this site. What is the expected effect of wave amplification and associated shaking from the use of these fills? What examples,relevant to this site, can be cited to show that the use of man-made fins can be or have been used without producing negative shaking effects? 6.P. 5-127,Liquefaction and Seismic Settlement: The contention here is that the effects of liquefaction, including settlement, can be reduced to an acceptable level of risk(become less than significant)through design and that liquefaction below the compaction layer will not be a problem. What are examples, relevant to this site, that can be cited to support this contention? What does an acceptable level of risk mean in actual practice, e.g, what type and level of damage, injury, etc. can be expected within such a level of risk? For REW-32 instance, what damage will occur to residential structures, piping, streets, and curbs and guttering? Why has 2 inches of differential settlement been chosen? Is it, as implied, true that within 2 inches there will be no damage, etc.? If not, what will be the effects, for instance, on structures, including infrastructure? What will be the effects of settlement,if settlement is greater than 2 inches? 7. The same considerations and questions raised above in comment/question 2 for "less than significant" apply to risk and application of the term "acceptable level of risk". What are the REW-33 answers for risk and acceptable level of risk to the same questions raised for less than significant above? OTHER COMMENTS 1.What is the potential for landsliding on or in association with this project? I REW-34 2. On or about May 28, 1998,there was a meeting in Huntington Beach City Hall during which a volume containing aerial photographs and water data was introduced into the discussion by a representative of EDAW, Inc. Nearly all of the discussion centered around the presence or absence of wetlands on this site. The material in the volume indicated was used for, pertinent to and necessary for evaluation of wetlands on the property but has not been included in the EIR. In view of what I heard at this meeting and the use of this volume of material, it should have be REW-35 part of the EIR so that the public would have had access to this material for purposes of making general and specific comments on the EM especially with regard to the presence or absence of these wetlands on the property. In my opinion the EIR is deficient in this regard, should be revised and amended to include this material and should be recirculated for public review and comment on the matter involved. 3. In addition to the comment just made, I believe the EIR needs to be revised, amended and recirculated on the basis of the geotechnical questions and comments made. The most notable of these bases is the lack of treatment of the Bolse-Fairview Fault, the lack of discussion of the REW-36 earthquake intensity for the site and the inadequate treatment of the peat deposits on the site, together with the associated considerations of impact,remediation and mitigation. i . Robert E. mcheIl Department of Geological Sciences 6411 Weber Circle C lif State University Long Bead Huntington Beach, CA 92647 1250 Bellflower Blvd. (714)8464M3 Long Beach,CA 90840 (310)985-4920 65 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 June 14, 1998 Jim Barnes, Project Planner City of Huntington Beach Department of Community Development P, y 2000 Main Street Huntington Beach, CA 92648 J U t' 1, 1998 Re: Draft EIR No. 97-2 DEPAR-i r;ENT OE Shea Homes Parkside Estates Subdivision COMMUNITY DEVELOPMENT Dear Mr. Barnes, Enclosed are my comments on the Draft EIR 97-2, Shea Homes Parkside Estates Subdivision: Biologic Resources, section 5.8 This section is inadequate because it does not contain a proper wetland analysis of the area within the City of Huntington Beach and it does not address impacts to these wetlands. It omits the existence of wetlands on the property, it does not JDV-1 address the question of whether the project violates Section 30233 of the Coastal Act because it places homes on wetlands, and it does not address mitigation measures for these wetlands, including an alternative that avoids the wetlands with a proper 100 foot buffer. The City parcel contains approximately 12 acres of wetlands that are not included in the EIR. In 1989, the EPA concluded that there were 8.3 acres of wetlands on the City area, in an area at the northern edge of the property. The EPA's report should be in the EIR, but is not. In 1987, Sanders, under the employ of Signal Landmark, owners of most of the Bolsa Chica area, concluded the the area to be wetlands, based on Billhorn's 1987 hydrology study and the presence of indicators of hydric soils. However, Sanders, under the request of Beveridge and Diamond, attorneys for the developer, not an "independent study" as termed by Lisa Kegarice for Tom Dodson and Associates, revisited the site on August 18, 1991. He concluded, without doing JDV-2 a formal analysis of wetland functions and values, and relying on watershed analysis, rainfall, evapotransporation rates, and alteration of upslope areas, that the area qualified as "prior converted cropland". The owner applied to the Army Corps of Engineers to remove Clean Water Act, Section 404 jurisdiction of this area, due to a "prior converted cropland" designation, and on May 20, 1992, the Army Corps, because of lack of information to the contrary, determined that 8.1 acres were not jurisdictional. Sanders never disproved the existence of wetland indicators on the property, as he never tested it. He did find cattails on the south side of the property. 4 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 On July 24, 1997, Hunsaker&Associates prepared a "Report of Historical Site Usage", a binder presented before a City staff meeting on April 28, 1998. It should be part of the EIR, but is not, because it is necessary for decision makers to see the aerial photographs within the document for themselves and to read the individual reports within the binder. For example, although the EIR denies the existence of wetlands in the City parcel, many of the aerial photographs show evidence of water on the property, not only in the EPA area, but also in areas at the south end of the property next to the flood control channel, and in the area where the arena used to be. Frank Hovore, who analyzed the photographs, also mentioned the existence of water in the photos dated 3/24/59, 1/31/70, 1/31/81, 2/19183, 3/19/86, 1126/95, 1/28/95, and 3/27/95 (the 1995 photos showing water on the property for 2 months). Moreover, examination of the 6/28/70, 10/26/73, 2/17/75, 2/25/80, 1/9/87, 1/24/88, JDV-3 1/30,89, 3/15/90, 1/3/93 photos all show evidence of probable water in the same locations as the EPA area, as well as ponds next to the flood control channel and in the arena area. This report also contains a letter from Bob Feldmeth, Ecological Research Services, August 5, 1991, in which he finds the facultative wetland plant Bassia Hyssopifolia in a 3.3 acre area next to the flood control channel, roughly corresponding to the area showing up as ponding water in the aerial photographs near the flood control channel. This 3.3 acre area, as well as approximately 1 acre of ponding water in the arena area, added to the EPA delineated area, all add up to approximately 12 acres of wetlands in the City area. It should be noted that the test pit locations for ground water in this report ( #39) do not include testing in the ponding water areas, and one of them is at the very edge of the EPA area. The wetlands assessment report in the DEIR by Tom Dodson (L.Kegarice, Dec. 1997) is also deficient because it does not provide data or maps adequate to support her conclusions. Filled out forms containing data should be provided on JDV-4 which she based her conclusions. For example, are the test pits in the areas where the ponding water occurs? Enclosed is a series of color photographs and aerial photographs compiled by the Bolsa Chica Land Trust and concemed citizens, in order to show the presence of water and facultative wetlands vegetation such as brass buttons in the year 1998 within 6 months of discing in late 1997, the existence of ponding water on the site through the years, rainfall data showing that ponding water occurs in normal rainfall years, pictures showing the test pits and the high ground water table in the pits, wildlife usage including shore birds, great blue heron, ducks and teals, discing JDV-5 and bulldozing of the wetland areas in April, 1998, and the recurrence of ponding water in May of 1998, even after the discing, in the same ponding areas as before. Also included is a biology letter report from Scott White as well as his qualifications. All this points to our recommendation that a formal wetlands delineation should be performed in a revised Draft EIR, hydric soil analysis should be done in the proper 2 0 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 areas, including the EPA area, the ponding area next to the flood control channel, proper Coastal Act policies regarding wetlands should be followed, consultation from the Army Corps of Engineers regarding revising their "prior converted cropland" designation to a "farmed wetland" designation, and consultation with the JDV-5 USDA Natural Resources Conservation Service regarding wetlends delineation on (Cont.) the site. In addition, comment from the EPA should be solicited, since they did the original delineation in 1989, and no one has done the same kind of soil analysis to disprove the 1989 report. The list of photographs follows. Note that these photos are in color and to be properly interpreted by decision makers, should be reproduced in color: 1. Ponding water in the City area from December 7, 1997 to December 22, 1997, before the el nino season, showing water ponding more than two weeks, putting it into the "farmed wetland" category (8 pages). 2. Ponding water in the County area from 12/7/97 to 12/20/97, showing more than 0.2 acres of wetland in the County area. (1 page) 3. Ponding water in the City and County areas from 1/06/98 to 4/18/98, showing persistence of water for over 3 months (17 pages) 4. Wetland vegetation including brass buttons and (?)hyssops loosestrife 3-29-98, JDV-6 in City area (2 pages) 5. Bulldozer pushing dirt into ponded areas in City area 4-22-98 (1 page) 6. Disced and graded areas in City area and fill in County area, but persistence of brass buttons and pickleweed missed by the equipment operator 4/25/98 (3 pages) 7. Reoccurrence of ponding water on City area after discing and brass buttons, 5/6/98 and 5/14/98 (4 pages) 8. Wildlife usage of City area, including Canada Geese, shorebirds, ducks, and Great Blue Heron, (3 pages) 9. Test pits showing high ground water, 3/16/97 (1 page) The list of aerial photographs follows. Note that they should be reproduced in color for proper interpretation. Note the EPA delineated area and the ponding areas next to the flood control channel in the City parcel. Note, also, the drainage swale JOV-7 tending east to west corresponding to the historic tidal channel seen on the 1873 ` 3 1 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 Coast Survey map (excerpt enclosed, as well as EPA area delineated in 1989). Aerial photos: 5/1/67, 1/31/70, 1/24/78, 2/25/80, 1/31/81, 3/15/81, 3/19/82, 2/19/83, +JDV-7 4/14/83, 1/9/87, 1/21/87, 7/87, 1/24/88, 1/30/89, 10/27/89, 1/27/90, 3/15/90, , 1/14/91, 1/9/92, 3/4/92, 2/10/93, 3/14/94, 1/28/95, 3-95, 3/19/96, 1/29/97, 2/14/97, (cont.) 3/10/98 (28 pages) It should also be noted that exhibit 4 of the DEIR shows the ponding areas next to the flood control channel and the arena areas, as well as the EPA area. Moreover, JDV-8 the MWD sales flyer, enclosed, shows the wetland area as a swath extending from the EPA area to the flood control channel. Next is rainfall data from the National Climatic Data Center from 1984 to 1996 (Newport Beach Harbor). All years except 92, 93, 95 show rainfall at or below normal levels. These data should be correlated with the ponding seen on the aerial photos. The rainfall data is not included in the DEIR, but should be. This illustrates JDV-9 ponding in typical years of rainfall, confirming existence of jurisdictional wetlands. Rainfall data from Huntington Beach showing the rainfall compared to aerial ponding of water should be in the DEIR. Next is the Scott White Biology Report, 5 April 1998, who noted potential agency jurisdiction and the presence of the wetland plants Lythrum hyssopifolium ("hyssop loosestrife") and pickleweed in the City area. Following that is Scott White's JDV-10 qualifications. The DEIR does not reflect this plant, nor the brass buttons common on the property, probably because the EIR biologists did not examine the property at the right time of year. Another biology report at the proper time of year after the rains should be a part of a revised DEIR. Next is the email letter from Tom Yocom at EPA to Nancy Donaven, 5/19/98, regarding jurisdictional matters involving the Corps of Engineers and the Natural Resources Conservation Service, and the Rivers and Harbors Act jurisdiction. JDV-11 These jurisdictional matters should be addressed in the EIR. Next is the 1986 Coastal Commission certified LCP for Bolsa Chica, showing the Shea parcel as Wetlands. Since the amended LCP has been heretofore JDV-12 successfully challenged in Superior Court by the Land Trust, the official LCP map shows this area to be wetlands, which should be documented in the DEIR. Next is the Aerial Geology Map, Figure 4.4 from the 1993 Revised Draft EIR for Bolsa Chica, showing the Bolsa-Fairview earthquake fault bisecting the Shea property. Same document, Figure 4.4-1, shows Existing Condition Drainage Pattern JDV-13 Map, with water draining away from the earthquake fault line. Figure D2 Bolsa Chica On-Site Surface Flow, shows on-site drainage into the EPA area. This shows 4 0 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 how water can appear on the property, with a high ground water table creating wetlands. Water may be coming up from the earthquake fault area in an artesian manner similar to the artesian wells and springs present historically in the area. The DER needs to account for the high groundwater levels mentioned in the DER (p.5- JDV-13 128 'The upper site soils are typically moist to wet ..") (p.5-129 "excavation of the (Cont.) site soil will be hindered by the presence of perched water and high moisture content soils"). This soil moisture probably explains how wetlands can recover rapidly if the site is not disturbed. Presence of ESHA's not included in DER. The Department of Fish and Game has concluded that the Eucalyptus grove along the Bolsa Chica mesa is an ESHA because of raptor habitat. This ESHA has been delineated as approximately 20 JDV-14 acres. Is the Shea Eucalyptus grove included in this ESHA? If so, it should be preserved under the appropriate section of the Coastal Act. Because this grove is supposed to be incorporated into the open space area, it is unclear what the rationale for removing it is. Other comments on the DER: p. 3-21 The borrow site is proposed to be from the Bolsa Chica mesa, i.e. 210,000 cu. ft. However, the Bolsa Chica LCP has to go back to the Coastal Commission, JDV-15 which may act to preserve the bluff faces and limit mass grading. What is the other local source of borrow and the ramifications of trucking it should be in the DER. p.5-32. The Bolsa Chica LCP has a cap of 1235 homes, including the 25 homes in the County parcel, leaving 1210 homes for the California Coastal Communities (ex- JDV-16 Koll) group. Have these people been notified of this? Do they agree? p. 5-28. A fiscal analysis for this residential project should be performed, since purely residential projects don't pay for themselves in terms of public services such JDV-17 as fire, police, schools, and libraries. What about the libraries? No library impacts in the DER. p. 5-36 What kind of fee will be paid for affordable housing? What is meant by "if such a process is available?" Is it available or not? Specifics should be identified. JDV-18 Mitigations too vague. p. 5-121 "Faults have not been reported within the project site" and p.5-126 and p. 5-131 "No active or potentially active faults are known to exist on the site" However, JDV-19 the Bolsa-Fairview fault, a potentially active fault, has been mapped on the site (see above). Identification, and ramifications, of this fault should be in the DER. p 5-141 What are the specific BMP's for the NPDES? Consideration of the USFWS I JDV-20 5 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 recommendation to provide a vegetated detention basin should be considered to handle excess flood flows as well as to preserve the wetland charachteristics of the JDV-20 site. I (Cont) p.5-144 The wetland delineation focused on the 8.3 EPA area. What about the other areas of ponding as mentioned above?There are about 3 acres of wetlands JDV-21 outside the EPA area that are not mentioned in the EIR, but which are readily apparent on the photos and aerial photos provided herein. p.5-149 General Habitats, City Parcel. This is incorrect. There are natural habitats I JDV-22 which form if the area is not disturbed as shown by included photographs. p.5-160 City Parcel - Impacts to wetlands. There are approximately 12 acres of wetlands on the property as explained above. A new, formal delineation, with proper JDV-23 testing in the proper areas at the proper times should be performed. p. 5-162. The Bolsa Chica lowlands is not a proper site for mitigation, because the ports of Long Beach and Los Angeles have committed to fund the entire restoration. The proper amount of wetlands on the County site should be calculated minus the JDV-24 fill which has occured as recently as April, 1998. Onsite mitigation in terms of a detention basin should be considered, as suggested by USFWS. p. 5-176 and p. 5-181. Huntington Beach High School will be fully occupied by existing homes. Exactly how will the new students be accommodated? What about the cumulative effect from students from the Bolsa Chica mesa development? JDV-25 Where will everyone go when existing facilities are overcrowded? Specific mitigations, fees, new high school, etc. should be identified. What is the Mitigation Agreement between the Huntington Beach Union High School District? p. 5-179 and p. 5-187 Fire Service. Potentially one additional fire company will be required and response time will be greater than 5 minutes. Will Shea pay for this JDV-26 fire company or fire station? Consultation with the Fire Department or more sprinklers is hardly adequate mitigation. p. 5-188 Water. Where will the water come from for the County parcel? I JDV-27 p. 5-189 Annexation. Should be approved by City Council, not just City Planning I JDV-28 and Public Works Departments. p.6-1 and 6-2 An alternative which avoids impacts to the wetlands on the City parcel should be presented in the DER, along with adequate setbacks. This alternative JDV-29 could contain a detention basin as suggested by USFWS, and retain the wetland 6 0 JAN D. VANDERSLOOT, M.D. 2221 East 16th Street Newport Beach, CA 92663 (714) 548-6326 FAX (714) 848-6643 and biologic resources of the site, as well as improve aesthetics and view shed of the site. This altemative is financially feasible because Shea paid such a low price JDV-29 for the land from MWD (approximately $11 million for 49 acres). (Cont.) p. 8-2 Impacts to the Bolsa Chica LCP could occur because the borrow site is JDV-30 proposed to be from the mesa. p8-3 Potentially active fault (Bolsa-Fairview) traverses site. JDV-31 p. 8-9 Land Use affordable housing. Is fee process available? Is this a viable (JDV-32 mitigation? All mitigation proposals are vague, uncertain, infeasible. l p. 8-16 Public Services and Utilities. Fire Sevice mitigations are not mitigations JDV-33 because standard fire code requirements are standard. Deficiencies in fire company and service times remain and are significant. Thank you for the opportunity to comment on this Draft EIR. It is my JDV-34 recommendation that a new DER be circulated, including the suggestions and points made above. Sincerely, Jan D. Vandersloot, M.D. Enclosures Total pages: 7 r Y 1• LL. _ X ., Y -Y i• � ^ is - ` a•o �. r+ w r ., ,.mac-�-i- �\ �.l �•��®�,- 1 5 `� /fi/ Aw 1 1 f � � �/ f'{ � T•��r ! 4�r � Rv;.r.+! is r!•r.KM r __,r�. 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'� 1 '4' ¢GC4n_._ sra j"y�" Y!- ' � :✓� !1 � j jam: r. � M, .�'., ��4d.♦ I • ilY . 1l5 �,y r r ��` � r�.✓.r � 'iTJi•"'� _ I . <�! L P � .' �� � . ^' y � ♦!. � '-tea{-. � '. r " � .. -. � ._'raw•. .. �- Ir'— f R ' ' ♦ i . y . . -i. .,,".,..w..�.. • . - _.. - ^:,tom' . _ r-t,! - •�: r ocu rt� .'fK to � � x 1 ,s JL T �.. :,,- ,- ,�, ,. . -::- ,_ . - , ,� _ . . _ _;fir' - ZF �� � ��'� :., �.. iw. L� E ':0. �=�t� �" �y aNl t'. < �' t�lt +rM �4r yyyy.--�� .. . S �� . --. ... t .. y. t.. �. --._. __ - .. ,. I \ I`_ � � I h .1 y n r Y ,art 9 yy \ yeti �\ W -OV ^ `. ���+ e • r B 7 � e �,,22 d _ ' • 1 •r � 1 fr, 5 1p Y 3y1 1 ZO 54 �a A tiw In a . `y. o� w 1!� s y a` 1 ` � /� � :Y_ �TrV•z.ti _ I n P y" \ J.L.. N•J l y. y' P - 4111C rY � 2 a.�♦ V _ 1 yyp A' . k✓dk. Y• 7 r ly A V m U.S. OfPARIMENT OF t6NNENCE NiIIIC11AL ClIt1ATIC OASA tENtER ro NAtIONAI OCEANIC AND A11t0$PHEAEt Alaf11NISTRA710N ANNUAL CLIMATOLOGICAL SUMMARY ASHEVILLE:.ILfl011tN CltiOUNR 07 2 MI m STA71ON IDENTIFICATION 0406617r. IIEYPORI SEACK RARSOR CALIiORNIA ELEVATION t0 FT. ABOVE SEA LLVEL LAT. 33 36M LONS.117 531 a 0 ATE TEMPERATURE ( " F1 PRECIPITATION ( INCHES1 NUMBER Or DAYS SNON, SLEET N0. flr DA v IDESIA 1. Mu11AG MOM DEPART, tAEAIEST MEAN Koh MEAN VON at"" DEGNEt volt saw MIN M1At TOTAL TApN owAvL0 OAK TOTAL NAIL 1111K j �R. HO. HAVIMUH MI11tMUM 1dMA1 OATS OATS MIGCSt 00.T[ 4-owt1 OAT[ > !0� a �e Sao i �e NOI OAv CALL DEPIN •,10 11 11 O > t14j t 68.5 •i0.6 59,6 S.4 177 16 84 2: 44 17 0 0 0 0 .22 -2. 74 .19 16 .0 0 1 0 84 ? 66.5 49,6 58.2 2.9 191 0 75 2 • 43 18 0 O O 0 .01 -2.06 .01 14 ,0 0 O 0 84 3 67', 1 5). 1 60,4 4.4 136 0 75 S a9 74 O 0 0 0 _IS -1.54. .TO 14 .0 0 1 0 1 e4 4 67, 1 54.2 60. 7 2.9 s26 2 75 14 48 28* O 0 0 0 .01 -. 34 .4S 6 .0 0 3 0 04 5 7.2_4 S9.5 66,0 5.4 21 58 79 2Q S2 1 0 0 0 0 ,00 - .20 .00 $19 .0 O 0 0 04 61 72.S 62.9 67.7 6. 1 0 Be 75 30• S8 8 0 O 0 0 -00 -.06 .00 300 .0 O 0 0 t 84 76.6 66.4 71 ,5 4_0 O 207 90 27• 63 25• O 0 0 0 .00 -,01 .00 31• o O O 0 64 78 .3 63.5 73.4 5.2 0 247 02 17 65 7 0 0 0 0 .71 . 13 . 19 I5 .0 O 1 0 84 4 a1 ,0 69.4 75,6 8.5 0 32S 91 9 61 25 3 O O O . 11 -.18 . 11 11 .0 0 1 O 04 1 74 , 1 58, 7 6b.11 2.5 20 71 92 264 S2 28• O 0 0 O . 13 - .02 _ 10 17 .0 O 1 0 N a0 1t b6.3 51_0 59. 1 .0 169 0 72 11 39 26 0 O 0 O 1 .59 . 27 .72 24 .O t1 4 2 W 1 k; 12 62. 1 47. 7 54 .9 - ,4 305 O 70 6 39 17 O 0 0 0 4 ,47 2.96 .8e 21 . 0 0 9 5 71 .? �i7,7 bd_5 3,6 1145 f034 9t EP 39 SiG•�3 O O O 7.T0 -3r39 Be. DEC -�O O 21 7 LL �. U) M NISSIN6 DA1A. APPEARS•(ION HDNIK I OCCURRED ON OE OR MDRC PAIVIOUS 5 ADAPSILO MONIHIV OR ANNUAL VALVE W1A W CN LESS IMAM 10 OATS ARE DAMS OVAING FHE 110NTN, tOIAL CONTAINS ESItMATEO VAtULISI HISSING. AND IS APAEARS ALONE if TOA HISSING OAIA, 10 OR"DRE OATS ARE HISIM. 19 APAtARS N11N ANNUAL &&u. NHEN T TRACE A AMOUNT PALCIPIIA1104 MAT INCLIOE 03 KRIVE0 IROrt N0 t"S• 1#4 MtsstNG PRCCICl141IoN 1HAT t1GCURRIO4"14ND OAII. V INCLUDES TOIAL TOR PAEV&O%Ny1TN, IIE PAEVIOUS HRM HS. I Rl I Z U.S. OEPAIIIMENT Of COWKE NATIONAL CLIMATIC DATA CEMTEN NATIONALNAt Oafullc ANp A1laStwopst ADMTMtSiR61=ON ANNUAL CLIMATOLOGICAL S!1!' NARY ; E„1 u i IMATIC C11ROlIN4 . 2pp1 STATION IDENTIFICATION 0406617S REMPORT BEACH HARBOR CJILZPo"NIA ELEVATION 10 FT. ABOVE SEA LEVEL LAY. 33 36M LONG-ti7 •531t ATE TEMPERATURE OF ) PRECIPITATION ( INCHES ) NUMER OF DAYS SNOW. SLEET NO. Of DAYS WART, #"To& EokINS OE►AMT. 4RE+11 O 1[AN MEAN 1KA11 rw orm 01&Xt MI<11 Wf Mi" ISM Tt01AL FF M OW440 GATE MAL, MAt GATE iA. MD, w1TtMM MIM1 1f kowk OAVS OATS 4110C T OAK LOW DATE NORMAL CA1 TALL WIN !.IO L.•JO Mo 03 1 63.6 41. 1 SS.S 1 ,i 206 0 74 2 39 31 O 0 0 0 .22 -2.34 .12 211 .0 0 1 O O 0 2 63.4 46.6 55.0 -.3 27S 1 10 14 30 1 0 0 0 0 1.07 -1.00 .70 9 -0 0 3 1 0 8 3 62.4 47.7 SS. 1 -.9 103 0 71 23 42 29• 0 O 0 O .33, -1.16 .12 27 .0 0 2 0 0 95 4 66.0 54-1 60.5 2.6 t31 4 et 2• SO 13 0 O 0 0 .04 -1 . 11 .03 21 .0 O O 0 O as 5 66.1 57.2 61.7 1. 1 9i 0 70 3 S4 18" 0 0 O 0 .06 -. 14 .06 9 .0 0 0 0 0 85 & 70.4 60.S 65.S 1 .9 11 33 a? 30 S7 4• O O 0 0 .00 -.06 .00 304 .0 0 0 0 0 85 7 73.0 64.4 61%.4 2.3, 0 144 88 90 62 30 O 0 0 0 .00 -.01 .00 310 .0 O 0 0 0 85 t 71 .5 62.9 67.2 - 1.0 3 7S 61 30 SO 21 0 0 0 0 .00 -.0E1 .00 310 .0 0 0 0 0 85 9 75.0 62.2 66.6 1.5 O 117 61 24 55 12 O 0 0 0 .21 - .02 .20 4 .0 0 1 0 O 85 1 C 74.0 60.4 67.2 3.1 14 99 as 3 54 23 0 0 0 0 .07 - .00 .03 21 .O 0 D 0 O e5 t! 65.6 Sf .6 50.6 - .5 107 1 76 2 42 14• 0 0 O 0 2.99 1 .66 1 _26 29 .0 O 4 3 1 85 1 66. 2 49.5 57.4 2.2 231 1 00 17 30 13 0 0 O O _43 -1 .09 .38 2 .0 0 1 O O ' 66,2 55.3 61 .0 1.2 iSJA a66 88 CT• 36 EC• O 0 O O 5.47 -5.62 A ,26 OV 0 0 - 12 4 1 N POSTING 041A. AWAIK 1111H MDNINLV • OE+WWO atom D11 100K FKVIDUS •AoxnttO "W1,61Lr OR MWAL VALUE OAT&Mtl1 LESS f1A►M ID OATS ARE OA1L`S DADS THE"M94. TOTAL CONTAINS ILf1MA110 YALUEISI MISSEW, AID IT AOK*AS ALOE &T FOR MISS140L DATA, s0 OA Am DAIS AAE NISSLNTl. 11 MFEAi1S Ni1H Aww DATA.- AH[M 1 144" A AMOU/T PWC311TAIION 1M1 INCLUDE E(AIVED FROM MONfNS 141N WIS144 PALETrITA1300 THAT 9C(AJWI[O"ING DATA, Y 1NELtKs TOTAL TOA A rVMK MDKTH. IK P$YIOAIS MONTHS. 1. 31A .NALAGU ; °�°& CLIMATOLOGICAL ", 9010 28801 ER NANCS�a;C DIINISIRA110N � 111%1U L 51� RY_ STATION IDENTIFICATION 04066175 NENPOR7 BEACH "ARBOR CIILIFORIIIA ELEVATION 10 FT. ABOVE SEA LEVEL LAT. 33 36k LONG• 117 5311 DATE TEMPERATURE ( OF ) PRECIPITATION CINCHES ? NUMBER OF DAYS SNOW, SLEET NO. OF !}AYS J OENRI, 1EATINS COKING OErmt. OOEAtESI MEAN WAN •PLAN FOOM OCOREE FE IIA% MAX No MIN 101AL FROM OW41KO MTt IOTAI MW CASE TR. ND, NA111NI,N OtNIPANT NORMAL OATS OATS NIOMESI OAIE LONCST col[ � �0° � u� a �� < 0� NORMAL DAY FALL KPIN •,10 !.SO !8.0 - - - 96; 1 67.9 S1 ,0 59.S 5.3 1 162 0 79 11 44 11• 0 0 0 0 1 .3S -1 .21 .59 30 .0 0 3 2 0 s 86� Z 64.8 S1 .8 S8.3 3.0 193 Z 78 24 44? 10 0 O 0 0 3.09 1 .01 2.10 15 .0 0 6 3 1 0b 3 64.9 S2.6 56.9 2-8 167 0 75 21 44 17 0 0 0 O 2.01 1 . 12 1.07 16 .0 0 L 2 1 86 4 67.2 S3.6 60.4 2.S 137 6 78 28+ 49 18 0 0 0 0 . 77 -.36 _S6 6 .O 0 2 1 O O6 5 67.7 S6.4 62.4 1.5 04 2 72 27+ 50 7 0 0 0 0 .00 -.20 .00 314 .0 0 0 0 0 86 6 68.9 60.5 64.7 1 .1 18 14 74 26 5B 184 0 0 O 0 .00 - . 06 .00 30• .0 0 0 O 0 86 7 71.6 62.0 66.8 . 1 0 6S 74 31• 59 314 0 0 O 0 .07 .06 .07 23 .0 O 0 0 0 86 8 73. 0 62.S 6i.8 -.4 1 93 02 19 58 2 0 0 O 0 .00 -109 . 00 31+ .0 O 0 O 0 86 9 70. 2 60. 1 65.2 -1 .9 28 39 73 IS 55 29 0 0 0 0 .84 SS .44 25 .0 0 2 0 0 Ob 10 70.4 57.0 63.7 - .2 S5 21 91 5 52 16• 1 0 O 0 .15 .00 15 10 .0 0 1 0 0 06 11 72. 1 53.9 63.0 3.9 67 14 84 2 48 30 0 0 0 O .4% -.91 40 18 .0 0 1 0 O 86 12 65.0 49.5 57.3 2.0 232 0 73 2 46 28♦ 0 0 0 0 .86 - .65 .46 7 O O 2 O O - "' 6R.6 55. 9 ^62.3 1 .6 II54 236 91 C1 42 E6 1 0 0 0 11 . 14 1 .05 2. 10 FED .O 0 23 8 ? M MISSING 01114. APPEARS YIIN NOalkV • OCLURREO ON ONE d1 N40t PRIVI" .a ADJU,,.LQ PIDNTHLT OR ANNUX VALUE DATA 6WW LESS 1w1N 10 OATS ARE VAX&OI1II46 INE PIONTN. TOTAL tWTAINS ff/1MAlt6 VALVEISI MISSM. ANO IT APPEARS AL011E IC FOR KISSING 004. 10 OR"ORE OATS ARE 11ISSIN6. It A"AAS WIN A*WL 041A, 1AEN T IRACE A AMOLNL PACU MAISON MAT INCLUDE OTAIKV iAOM MOR1H5 NP1N. NISSIN& WC101TATION TMT OLWROED O0II3 MIA. V IM1.W[S 1OIAL FOR MVIOn MONTH. THE vwv IOU&150MMS. ' N N���o �a �wr� o A Q p1C It01Ti11IS1RA11fl11 ANNUAL CLIMATOLOGICAL S�1MNARY �IMDIITN LA010LIIIIINIEA 241004 STATION IOENTIFICATION 04066175. WERPORT OEACN HARBOR CAt1FORNIA ELEVATION 10 FT. ABOVE SEA LEVEL LAT. 33 36N LONG.It7 S3M DATE TEMPERATURE t ° F ) PRECIPITATION ( INCHES )NUMBER OF DAYS SNOW. SLEET NO. Of ()AYS1 KOMI. 69MM A COOLING MOT. 001951 K/w wo TEAM IOON OEORK am" MAt IItD NIN Nlw Valk Iftn Or1U 40 $an 101AL i INt 0411. rA. NO Iw1NUM •IRIIwT1 MOO, OArS OAII Mli**fl 0+11E lOKtti dlt[ • p< < u� a O� IIOIrIRC *AT 14tt pEPTN •_t0 ',s0 •t.0 Q7 1 61.6 �6.9 55.3 1 .1 479S 0 73 26 36 16 O 0 0 0 1 .55 -1 .01 .S2 7 .0 0 2 0 A! 2 66.4 50. 3 SR.4 3. 1 19• . : 46 6 40 26 0 . 0 0 0 2.36 .29 .72 24 .0 0 6 2 0 07 3 63. 1 50.9 57.0 1.0 241 0 12 4 44 22 0 0 O 0 .50 -1 .11 .31 6 .0 0 2 0 0 87 4 67.6 55.2 61 .4 3.5 113 12 06 20 50 S• O 0 O 0 .O3 -1 .12 .03 3 .0 0 0 0 O 85 66. 1 59-0 62.6 2.0 72 3 73 S 64 290 0 0 0 0 .20 .00 .20 27 .10- 0 1 0 0 87 6 66.0 S9.3 63.1 •.S S2 0 49 20+ 56 1S O 0 O 0 .00 N .00 219 Om 0 0 0 0 07 1 69 .4 60.9 $4 . 7 -2 .0 17 14 73 31 S7 /9 0 0 0 0 . 10 .09 .10 t0 .0 0 1 0 0 87 0 71 .5 62_5 67.0 -1.2 2 71 71 1 S9 264 0 0 0 0 .21 _13 .21 14 .0 0 1 0 0 0 7 9 N K M K N N M IIIIT M 67 to 73 .9 61 .6 67 .9 3.9 10 %03 92 4 57 310 2 0 0 0 1 .81 1 .66 .64 is .0 0 3 3 0 9) 11 67.4 53.6 60.5 1 .4 Ill 4 77 10 46 304 0 0 0 0 1 .29 -.Of .46 6 .O 0 4 0 0 07 12 59.2 46.2 52. 7 -2.6 375 0 67 10 35 26 0 0 0 O .7. il .60 .98 5 10 0 4 1 0 Aw. N N 35 £CH 0 ON ON ,90N EC .ON OM 26 9 0 N NISSIkS OA/A. AMAAS Y11M roNTKT • CCOLPREO, ON ONE 00 MORE PKVIOMS •ADPXfrO NON114Y OR AN10^ VALUE DATA WIN t[TS THAN IQ DRYS ARE OhM OLMINS THE MMA w. TOTAL 00IIIAINS Ef11MATEO VALVEISI HISSING. AID IT Mot&" ALONE IF TON Rr1SSIMQ PA11k. 10 0R rKm DAIS'ARE MISSING. IT ATM{AAS NIT/{ANIUAI OAT,. WHEN T TRACE A AM"I 111Et1►ITATION N,f IOKJVK DEAIVEO ►RON IgM1111 NITN ws1w6 -ME{t1'tIATICw TINE 00MOKO OWING DATA. V IAGLVOES 1OVAL FOR PXVIOVS MONTH, T44 oKVIOIIS NONTIQ. U.S. COWRCE NATIONALA OCEANIC OJ<ND MOSPHERIC A0111A11SIAATSBM ANNUAL CLIMATOLOGICAL SUMMARY EDEARL UILE. �lG uROLINAN1[R 2a80t STATION.' IDENTIFICA710N 04066117S NCUPORt1 BEACH MAP008 ZACIFORNtA ELEVATION 30 FT. ABOVE SEA LEVEL LAT. 33 36f1 LUNG.117 53m LATE TEMPERATURE ( DE ) PRECIPITATION ( INCHES )_ NUMBER OF DAYS SNOW. SL,CEl NO. -OF OAYS- { WART. 1KA11% COOLING OtPART, W[Ai(ST elm KAN MEAN rmt W&W OEGREt 1M71 MAY MIN W401 TO?AL FIION Otl&"" 0"" 101AL MAX OAll rot. no. M79"ul1 NIN11RA1 NONPK OILY& (MATS NIONEfi1 OATE tA)tIST Oi11E s 70� • 320 t �� • Oe NOMIAL OAT CALL DEPTN -08� 1I 61 , 7 I7,8 51,8 .6 311 0 72 26• i9 19 0 O O 0 1 . 33 -1 .?3 .75 17 .0 O 3 i 0 BAD 2J 67,0 50.0 50.9 3.6 $62 f0 95 f0 44 3 0 0 0 0 .05 -1 .2.7 .02 ? .0 0 1 1 O 0 a 66.2 51 .9 59.0 3.0 153 14 82 25 44 144 0 0 O 0 .20 - 1 .411 . 19 1 .0 0 1 0 O 3 4 b3.6 54.6 S9.1 1 .2 167 0 t7 1 49 1S 0 0 O 0 2.08 .93 . 70 15 .0 O 5 2 OI 6 5 64.4 56.0 60.2 " -.1 341 0 70 11 SO 2 0 0 0 O . 02 -.18 .02 29 ,0 0 0 0 O � 6a 6 63.9 57.6 60.8 -2.8 120 0 68 27 SI 0 0 0 0 0 .00 -.06 .00 30• .0 0 0 O O i ) 06 7 69.1 64.6 66.9 .2 )S 67 75 21 60 46 0 0 O 0 .00 -.01 .00 310 ,0 O 0 0 O E!0• it 60.7 63.0 65.9 -2. 3 9 44 74 27+ 59 304 O 0 0 O .00 -.08 .00 310 .0 O 0 0 0 e 9 69.0 61 .2 65.5 -1 .6 30 54 91 5 56 22 1 0 0 0 .00 - ,21 .07 20 .0 0 0 0 0 E)8 fC 67. 1 60.6 63.9 .O 39 12 76 10• ss 31• 0 0 0 0 .00 - . 15 .00 31• .0 0 0 0 0 0D t1 1 1 63.9 52.2 59.1 -1 .0 20S 5 03 29 42 20 0 0 0 0 1 .20 -.12 . 43 25 .0 0 4 0 Q , ' OO 1 61 .4 47 .3 54.4 - .9 330 0 19 9 38 21• 0 0 O 0 2. 93 1 .42 1 ,20 16 .0 0 6 3 1 '� b•i.6 55_,6 60.b .0 1732 214 9t EP 38 EC I 1 0 -0 0 8_69 -2.40 .4 .20 EC O 0 ' 20 7 ! Jy NISSIN6��-AMA, APKMS NF1N 1CONTNI" .000~0 ON ONE 4R KK VKVIUUt a ADJUSTLO NOTCDA_T OR ANNUAL VALUE (JATA WN LESS TNAN tO OATS ARE WKS"?NO lit MONTH. TOTAL CONIAO06 ESTIMATED VALUECS) NISSIN,S, 4ND S At JIM06 ALONE iF FOR MISSING DATA. f0 OR 1101E D"l AIIE MISS)W. AT AnPFARS NITIt ANIMAL. DATA. rtE)1 T TRACE A RMOAl PRECIPICAt10M NOT IYCtvm (KR)Vt0 ffm "INS NI TN NISS/NG PR[t1►1TATION tWlf OCtlAt11E0 CYM[MD 4.TN• Y facctTIKS MIA) F0A PTKVIOU1 NEIt11TN. TN( PREVIOUS MONINS. I- U.S. DEPARINFRY NATIONAL OCCATNICDANO�MOSMOIC AM1N1STOA71M ANNUAL CL IMAIGLOG j f 81 SUMARY r�luml��r��I� TEA ri V �I 1bflL (lit J �} STATION IDENIM CATION 0406617S 11EN0011iT BEACH Maltoon CALff0l1/i111 ELEVATION !0 FT. ABOVE SEA LEVEL LAT. 33 3611 LONG.117 33M DAT TEMPERATURE OF ) PRECIPITATION ( INCHES ) NUMBER OF DAYS SNOAf SLEET INO. OF DAYS 1 OT ItltM . WASM C41UMG pENVtT, liWATES1 1(AN ArAN HIM ►m" OEME OIGME m MA1t Hill 111111 talc s1tIH aullvto "it TOTAL HAIL aft TR. LID. 1tA11NUR MINIMRI • • e e �A< DAYS HATS NifiNESf 4AT( COMES( OTt1E s� < � < � ! O Ti01M1AL nA1 TALI (t;ItN •,lO 09 1 61 .9 45.4 S3.7 -.S 347 0 72 21 36 a 0 0 0 0 .45 •2. 11 .21 1 .0 0 2 O O 89 2 59. t 47.0 S3.5 -1 .6 318 D 71 22 39 6 0 0 O 0 .14 -1 .33 .42 9 .0 0 2 0 0 89 1 60. 9 61 .6 Si-3 .3 241 0 74 21 45 4 0 0 0 O .62 -1.07 .44 2S .O 0 2 0 0 84i 4 67. 1 ' 56.6 61.4 4.0 132 43 90 S 50 274 1 0 0 0 .00 -1 .1S .00 30 .0 0 a 0 0 8 t 5 63.5 S6.9 60:2 - .4 143 0 6S 31• S4 2S• 0 0 0 0 ,OOT - .20 .00 3114 .O 0 0 0 0 89 6 65.0 59.3 62.2 -1 .4 77 1 70 20 S7 29• 0 0 0 0 .OS -.01 .05 10 .0 0 0 0 0 89 7 M K M M N N M 89 8 68.6 62.9 65.9 -2.4 3 37 71 134 60 314 0 O D O .00 -.06 .00 31• .O 0 O O 0 89 9 70.4 60.8 65.6 -1 ,S 2S 50 9f 25 SS 1S O 0 O 0 -66 .37 .65 19 .0 0 1 1 0 89 10 67.0 $8.2 62.6 •1 . 3 71 3 12 29 49 28 0 0 O 0 .35 .20 .30 21 .0 O 1 D 0 Dg 11 69.4M $4. 1 61 .8N 2.7 1018 t68 89 19 45 30 0 0 0 O .09 -1 .24 .00 26 .0 0 0 0 0 89 I 65.8 46.2 5?.O 1.7 I ?42 0 74 7 44 17 0 0 C1 0 .00 -1 .131 .00 31• .0 O 0 0 O 36 1Af4 1 M ON OM OM H .65M f P .ON OM 6M :M ON n rtISSING OAT1. &"CARS MIN#MfwT • OCLUItl1LD ON QNE OR HORS onvlovi ! ADJUSItD ROWNLY OR AATAIRL VALUE OITA 1K% tESS TMAN 10 OA1S ARE Milt D/11N6 THE TIONIM, 101AL CONTAINS tSTIOATC0 YALtgc&t KISSIAd. AND TT AWSAS ALONE IT FOR RAISING DATA. 10 OA "m DAWS AM t!'SfING. I1 IAP:ARi M1tft&%%k t ORM. lKs! T TRAu A A?kw4T PRECIPI1R110N AN► IN[LNOE OFAIVED I' M MNtwS Mutt MISSING _ ARECIPIfATIOM W*kt C(COW0 01*JWP OATA• r [NELWFS TOTAL f(Al^WWI"NOTf1N. tNE PAEYlovs 4041MS, W 11A7TOHAL OC[AN1t AID>4TITaA$gERTC ADI11101SfRA11011 ANNUAL CLIMATOLOGICAL SUMMARY AFIKRKISKVILLE.I`/1 *10 CARKINA "R ' 2a80t STATION IDENTIFICATION D4066175 NENPORI SE11CN HARBOR CAL1i0A11E11 ELEVATION 10 FT, ABOVE SEA LEVEL. LAI. 33 36N LONG.117 sap DATE TEMPERATURE ( 4F } PRECIPITATION ( INCNESI NUMBER OF OATS SNOW. SLEET NO. OF BAYS D "Al. 1[It11ND 4DOGI.t11G DEPART, AREAIEST lEAll mm ICAH BR014 O�Ei11Et OEIDf1EE ku ON HAN f11M 10141, rem O/SEftW DATE TOTAL 1tIHE DATE YR. MD. MAxIMUK M14fIN1N NDRMAL DAMS DAMS HIGHEST DAZE L%ol PATE >Ile 19 72e �3 e e � kvwk DAY FAtt DEPIM !,To .so >s.0 90 1 63,8 41,3 55.6 1 ,4 283 0 79 2S+ 42 70• 0 0 d O 11 ,79 -.77 .53 2 ,O 0 5 1 O 90 2 58.9 46.9 S2.9 -2.4 333 0 69 24 34 15 0 0 D 0 1.99 - .18 1 ,2S 17 ,0 O 3 1 1 901 31 51.6 50,6 65,1 -.9 290 0 70 17+ 40 03 0 0 0 O .07 -1 .62 .0S it .0 0 0 0 0 1910 63.0 56.0 S9,5 1 ,6 ISO 0 71 4 52 9 0 0 0 O .77 - .39 ,53 4 .0 0 2 t 0 90 64.7 57. 3 41 .0 .4 124 Y 76 5 53 1 0 0 0 0 .51 .3% ,St 28 .0 0 1 1 0 190 69.4 60,5 64.5 .9 34 25 82 27 S5 1 0 0 0 0 .001 -.06 .00 30 .0 0 0 0 0 90 7 71 . 3 65. 2 60.3 1 .6 1 112 78 13 60 3 0 0 0 0 .00 -.04 .00 314 .0 0 O O 0 9 0 70.0 64.6 67.3 - .9 0 79 73 29 61 27 0 0 0 0 .001 - .08 .00 3t+ .0 0 0 0 0 9D 9 72.0 63.4 618.0 .9 O 96 70 1:*1 61 24 0 0 O 0 .00 -.29 .00 30• .0 0 0 0 0 90 1 71 . 1 60.2 65.7 1 . 9 17 42 04 9 55 26 0 0 0 0 .00 - .IS .60 31• .0 0 0 0 0 9 T1 1a9.5 53 . 3 61 .4 2. 3 112 11 80 22+ 45 28• 0 0 0 0 ,12 -1 .20 . 12 26 .0 0 1 0 0 4 rt2 61 , 11 45.4 53.6 1 -1 .7 343 0 78 1 6 1 34 23• O O 0 0 .OB -1 .43 .06 1 20 .0 O V 0 O Ate' 66.2 55.9 6i .1 , 4 t703 372 64 Ct 34 EC+ 0 0 O 0 5,23 -S.8f> 1 .25 ED .V 0 12 4 1 M MISSING OAIA. Awtal"saw WNTHLT .oEc4wA" ON OK OA MM w1li uS B ADJUSTEO R%IML( OR 140f^ VALUE D11A MEN LESS THAN 16 DAYS ARE WKS DURING lHE 11041H. TOTAL ODNIAWS ESTIMATED VkUE411 MISSING. AHD IT APPEARS ACONE it (OA MISSING DATA. 1? OR OOK D4T6 ARE N)SS1NG. If O^VAAS WITH AWJAL DATA, MEN T TRACE A ANbiAt'T PKCTPNTATIDN MAY :ICt= NONE&FFOM MOKINS YITK MISSING WCOPITATIOM THAI OEctmo DURIIa O/TA. V IIKLUDES TOTAL fOR PRAM I"TN. - fME PREVIOUS M"IHS. DEPARTMENT S"EVULC 6"p NA110NGL0CEAFt{ , D 11pSDHER1t A01K�S1RAl10H NMTsANNUAL CLIMATOLOGICAL SUMMARY A E. �; 2001 STATION l0£TITIFICA1I0N o 0406131IS NEWPORT "EACH HKR81R CAL1F011111A ELEVATION to FT. ABOVE SEA LEVEL LAT. 33 16" LUNG.111 53H ;1ATE TEMPERATURE 10F ) PRECIPITATION ( INCHES ) •1 - NumBER OF DAYS SNO14, SLEET NO. OF OAYt X3 OIOMII, 694di 16 LOKM 910"1. GREATEST NJ MEAN lLAN REAN F1bK atom MIME mK ILAII .KIM Rik TOIAL FOW _ MEMYEO DME (Ofµ IWI 00.1E KA11M1RI NMI"" NWAAL call VIVS NIEKV VAIC CAIE 3. A FAL& EPIN , Tt.OS � 1gt 91 1 61 , 3 49.4 55.4 1.2 295 ? 75 17 43 31• 0 O O O 1 .26 -1.30 .52 4 .0 O 1 .1 1 0 ': 9f 2 62.2 51 .3 56.8 1.5 225 0 70 16• 46 1 0 O O O 2.62 ,ss 2.06 20 .0 O 2 2 1 3r L 91 3 59. 4 49,2 54. J -1.7 324 0 66 4 41 9 0 O O O 4.65 2.96 1.25 1 .O O 9 3 2 ( 9t 41 62.8 57,A S8. 1 .2 204 0 71 4 4B 12 0 O O O .20 - .95 .16 1 .0 O 14 0 0 4i 61 .4 54 .5 58.0 -2.6 217 4 76 5 50 2 0 0 O O .00 - .20 .00 31+ .0 0 0 0 0 91 b3-4 57.9 60. 7 -2.9 121 0 66 30• S4 34 0 0 0 O .00 - .06 .00 304 .0 0 0 0 0 91 7 66.5 61 .4 64.0 -2.7 2B 3 69 6 59 11• 0 0 0 0 .05 .04 .04 B .O 0 0 O O 41 0 68-0 62 .5 65. 7 -2.S 12 4t 94 13 56 29 2 O 0 O .00 - .09 .00 31• .O 0 � 0 0 O `31 9 67. 7 61 . 9 64,0 -2. 3 20 23 75 24 $8 11 0 0 O 0 . 13 - . 16 . 1t 5 .O 0 1 O 0 9` 10 n N H H N M H H H ti IN H K Id. b 91 11 67.6 52 . 2 59.E B 154 7 O2 12 44 30 O 0 O 0 12 - 1 .20 . 17 18 .0 O 1 0 O j91 12 6?.6 49. 3 5L.0 . 7 275 1 O 72 20 1 43 1 13 0 O 0 0 1 .21 - . 30 , 41 le . 0 O r 4i 0 0 --1-.rH 2Oi 0 O OK M 7,06l1 £B ON O � ! 21 611 3 M "IS;FNG DATA. J 001S k11r.MONINLT IIL�J• p��O ..W...RED ON ONE OR MIRE PREVIOUS 8 AOJUSIEO KONFK1 OR 4444AL VALOA DA10.WHEN LESS INAM 10 tAIS ARE DATES OVRINO ONE MOM. TOTAL COMIRIVS ESTIKAIEO VALtANS1 MIS4iMG, AND 11 ACFEARS ALONE IF FOR MISSING 041A, V 10 OR MORE DAYS ARE MISSING. II -+ APPEARS NIT" ANNUAL 00.Iw, NMLN I IAA:[ A AAMJyI PRECIPITATION KAI INUMOE �f DERIVED FRDM MDNINS N(IN MISSING PAM PtTATTON MT OCCURAFO OURIW. DMTA. V 1HCtUDES IDIAt- FOR PAEVIOLTS 1KME1K_ 1N[ PREVEOUS I0F146. 33 I tl I �0 OhU RA110NALAOCEANICOIMO.ItIMORCS"dolC AVmIN1STRAIIOH ANNUAL CLIMATOLOGICAL SUMMARY FlOt ASHEYILLGUILE. 0RiOG11u.s. NATIONALCCARDlI11Q CENTEA 28801 STATION IDEN71FICATION OR066T7S NE11Poftt OEACH HARBOR CALIFORNIA ELEVATION - 10 F'Z. ABOVE SEA LEVEL iAIF. 33 36" LBNS•117 53H DATE TEMPERATURE CO F ) PRECIPITATION ( INCHES ) NUMBER OF DAYS SNOW. SLEET NO. OF JOYS f1V1N11. K$1T111G "kits NUMBER GItCAtEif '- i re AN TiAM WAR i110M KWE Otmt MAX ma 111116 lull ID/AL FROK ORSEA110 O111E TOTAL Ma OAtE TR. T10. "TINA MINIM" N3RR*L 9ATS OM 4 t 1"61 001E LOWEST OI1TE ► qe < 3f < 720 < ao 41001 04V FAtt DEMN *.S6 *1,0 92 1 64 .4 1 47.2 SS.8 1 .16 20o 2 91 29 42 11 0 0 O 0 4 ,37 -1.19 . 14 5 .0 0 4 1 O 9? 2 66. 3 52- 7 59.5 4.2 168 s4 86 24 40 IS* 0 0 0 O 6.16 4.09 1.91 11 .O O 8 t 1 92 3 62,5 33.9 58.2 2.2 203 0 71 26 49 240 0 O 0 O S.64 3.95 1 .48 21 .0 0 9 5 S 42 4 67.5 50.4 611.0 5.1 67 12 75 26 S2 1 O 0 0 0 .OS -1 .10 .05 1 .0 0 a 0 1 a 94 66, 9 61 .2 64. 1 3.5 23 21 70 2 59 240 0 O O O .00 -.20 .00 314 .O O O 0 0 92; b 66. 1 59.8 63.0 -.6 54 0 68 304 57 244 0 0 0 0 .00 - .O6 .00 30+ .0 0 0 0 0 1 '12 7 71 ,0 64 . 7 67.9 1 .2 4 100 77 a 60 3* O 0 O 0 .24 .25 . 11 8 .0 0 2 0 0 92 0 72. 7 64. 7 69. 7 1 .5 0 1S3 77 14 61 31 0 O 0 0 .00 -.00 .00 314 _0 0 O 0 O 92 9 71 . s 63.2 67.2 , 1 0 73 79 23 51 120 0 0 0 0 .00 - .29 .00 304 . 0 . 0 0 0 0 92 t0 69,2 61 . 3 65. 31 1 .4 t4 31 77 1 S46 31+ 0 0 0 0 .42 .Z7 .20 31 _0 O 2 0 t 92 Is 68.9 53. 0 61 ,4 2. 3 ts5 S2 81 3 48 2S* J 0 0 0 .00 -1 . 32 .00 30+ .0 0 0 0 C 9? 12 62.4 47.2 54.0 - .5 310 O 77 Z4-1 38 20 0 0 0 0 3.82 2. 31 2.50 7 .0 0 4 1 1 t B 57,5 62� 1 .0 1238 399 86 CEO 38 Et 0 O 0 O 17, 72 6.63 2.50 OEC 0 29 13 M MISSING DATA. APK ARS m[TN OiO MLY • OCCURRED ON ONE OR MOK PREVI&A S AOJUSIED IWfLT OR ANIIUAL VALUC DATA UK" LESS fNLN 10 DAIS ARC VALES DURING T1f 100-t, TOIAt CONTAINS ES11114tED YALUEISI 1t1SS11ks. AND Il P-PA=I1*5 1f 90 "ISS04 DATA. 10 OR Mft. OAFS AM y .. A►PEAAS 1Ct't ANAJAt val. w�N 1 TRAtt A A""T PRECIPITATION 11AT INCLUDE DErli rcO s.i'Pi t MMT"S MIN; IS .4 PRECIPI1AT10N$WIT OCCURIIED DURING DL1A. Y 1NClUE(S TOTAL!OR PXvIom MON11i. THE P11EY1OUS►ONTHS. V TL O � NT£p NAIONA OCEANICMDwoSPAERiC AMINIS'1A110M FEDERAL CLIMATOLOGICAL SUMMARY ELt WILDING UROINA awl STATION IDENTIFICATION 04066075 NEWPORT BEACH KANBOA CALIFORNIA ELEVATION 10 FT. ABOVE SEA LEVEL LAT. S3 Jbp LONG.117 S314 ATE _ TEMPERATURE (Of ) PRECIPITATION ( INCHES ) NUMBER OF DAYS SNON, SLEET NO. OF GAYS 0[PART. 1EATPNp "Kan NUMBER 411GRTESf MEAN NTJIN NUN Ff", KCKC Kan IIAX itA71 KIM W118 TOTAL. fft* OOSEIKO DATE 161AL Ill( Oil'£ TA. MD. MA><1NUN MINIMUM MOM MK OMMIiAEfI OAfE E01[ST late >10� t »� <uo s tt� NOR1U11 OAT fAlt DLP1N >•.» >,y0 y4.0 ` 93 1 60.4 49.2 55.1 •, 1 300 O i3 26r 37 4 0 1 0 0 O 9,49 7.41 1.38 16 .0 0 12 9 4 93 ? 61 . 1 51 .3 56.2 .1 241 0 69 7 43 28 0 0 0 O S.01 2.96 1.S1 8 .0 0 10 3 2 93 3 63.9 54.3 S9.1 2.5 179 0 73 0r 48 2 0 O 0 O 1 .31 - .53 1.0? 26 .0 O 2 1 1 43 4 6S.7 55.4 60.6 1 .9 124 0 72 21r SO 7 ID - 0 I 0 0 .00 -.90 .00 304 .0 0 0 0 0 93 S ".4 59.9 62. 7 1 .5 70 5 76 10 53 13 0 0 0 0 .00 -.17 .00 914 .0 O 0 0 0 93 6 68.0 61.9 65.4 1 .5 21 37 74 10 $1 6 0 0 0 0 .1l2 .77 .02 5 .0 0 1 1 0 93 69.5 64. 7 67. 1 .0 O 71 71 244 61 30 O 0 0 O .00 -.01 .00 314 .0 0 0 0 0 93 8 69.7 64. 1 64.9 -1 .7 0 6S 73 26 60 2 0 0 0 0 .00 •.09 .00 314 _0 O 0 O 0 93 9 69.2 62.0 6S.6 -2.2 12 37 73 30 57 ?7r O 0 O 0 .00 -.36 .00 304 .0 0 0 0 0 93 10 70.4 59.7 65.1 .3 23 33 80 27- 55 270 0 0 O 0 . 12 -.06 .07 17 .0 0 0 " 0 0 133 11 67.4 52.8 66.1 .5 152 14 87 2 46 16 0' O 0 0 .77 -.78 .40 11 .0 0 2 0 0 93 12 66.0 48.7 57.4 2.0 234 6 63 2 43 23• 0 0 0 O .00 - .77 .31 11 .0 O 4 O 0 ' 66.6 56.9 51.8 .5 1356 260 08 0C1 37 AN 0 0 O O 18.32 7.4i 1,5i EB O 0 31 lA T M nISSIW,DATA. APPEARS Hilt"NOHOW • OCCIr`.v0 ON ONE an MORE MVI U5 0 ADJUSTED WNfKV OR ANN01 VALUE 06 1A"" LESS THAN 10 DAVS ART GATES OIIRINS TIIE"am. 101AL OWIAINS ESIIM4TED VAIVIISI HI, S/N,. AMD IT APPEARS ALONE IE tOR fAls ING DATA. 10 OR MDRE DAIS ARE MISSING. 11 APPEARS MIT"ANNUAL DATA, MON 1 OWE A ANDMI PAMPSIA1104 MY MODE OERIYI6 TMON NONINS "ITN NISSINS PM"I"TAT14M TOAS OCCURRED DURING DATA. V INCLUDES TOTAL i0R VKVIDUS NONT". JK OAEYIOVS MONRNS. v MfIOMate I�C AD,> s Tj l ANNUAL CLIMATOLOGICAL SUMMARY ��;��c ,�;,�R 28501 STATION IDENTIFICATION 04066175 NENOORT BEACH "ARGON CALIFORNIA ELEVATION 10 F_• ABOVE SEA LEVEL LILT. 3$ =6p LOffG.117 sal: ATE TEMPERATURE (OF ) PRECIPITATION (-INCHES) NUMBER OF DAYS SINON•-SLEET NO. OF DAYS OEPMm, MAIN* COOLIIO OIRSST- MI"Kst ' Kam Im mm nm ODIAiE OEM INtf 101K no "IN TOTAL Mo GOMM1D DATE TOTAL MAK 0111E tR1, tt}, TW111AA1 RIKINIM NOMML oIAT! tIA1! Nia"T wt 1Q+m alt s le w 3e a~ NMAK aT FAM G" t.10 :.SO Me V 94 1 64,8 49,0 S6.9 1.7 244 0 TO 12 43 29• O 0 O 0 .63 -1.45 .33 25 .0 O 2 0 0 194 2 61 .2 49. 1 55.2 -.9 268 0 71 12 44 2 O 0 O O 3.09 l.94 1 .10 17 .0 0 6 4 1 N 61 .9 54.5 59.2 -.5 197 O 74 12 SO 124 0 0 O 0 .60 -.42 .22 26 .0 O 2 0 0 94 S 62,3 56.3 59.3 -1.9 169 0 67 30 $a 194 O 0 O O .10 --.07 .Os 7 .0 O 0 O 0 94 6 67.9 61. 1 64.S .6 32 23 74 27 S6 1 O 0 O 0 .00 -.OS .00 30 .0 0 0 0 - 0 94 7 60.6 63.4 66.0 -t . 1 2 42 72 1 60 SS4 O 0 0 0 .00 -.01 .00 31• .O 0 0 0 0 94 0 73.4 66.5 70.0 1 .4 O !6O 81 1i• 62 4• 0 0 0 0 .00 -.09 .00 3t+ .O 0 0 O O 94 9 72.7 63.3 69.0 -2 1 96 85 27 S7 14 O 0 0 O .00 •.36 .00 1 30• .0 0 0 0 0 94 10 69.4 56.0 63.7 -1 . 1 70 30 94 a 51 19 1 0 O 0 .32 . 14 .31 S .0 0 1 0 0 94 11 63.0 47.9 55.5 -4. 1 292 O 76 23• 38 19 0 0 0 O ,S6 -.99 .33 10 .0 0 2 0 0 94 1 62. 1 40.7 SS-4 .0 209 0 72 20 30 9 a 0 0 O .63 - .94 .42 25 .0 0 2 a 0 AAN>j 94 C1' / OM 04 old1. .O 0 15 4 11 r N NISS1M1►Wit- APPEAK;:,N MMTW'f as O&to um NIZNIWS 0 O0.OAKII IK11mv Olt AMAAL VALM DATA"" MU TWA 10 DATS 1111E SATES OAt11N4 TIE MOW. TOTAR COM1A1NS 01111ATtV IIAUStsI NMwk Alp 1T Aw"As ALONE Ir i0A 111SS1110*ATA, 10 Olt NW DAMS ARE 14S31N . 1t yr APPEAR: NI TN ANNUAL DATA. IOU T TRAM A saw mcfP1TAT1011 ANT )NOIDA[ U OEAIMLO mw IKwmg wrw I11SS1N0 PRMT11TATIOI 1MlT OGOAVW OURM DATO. 11 11 mvmt TOTAL PTM1 mvi011S MOM. TIE MEVIVA 110 nmL O n v 1 :��<��=tl C_ "[AT�?L081Cfil. Stii�aRY I_PR ii�E,ti'RR((1Fq NATIONALCL1iIC DATA CENTER kMP11E IC k-MWIS n4TItN MEAL MUM ASPIVILLE, WRTH CARMIA4 2880i-5001 B.-ATION IW4E: E:a E LA?, L3#: ELEV. . :65i?5 ze`iaa w ae�C;+ �it�.Cs?� CktiFi;�t:�:Q 3z33�„7$3 ;Q ;` `c'K?;Rk3�3ReSif' ?�i£CIF3TRT,�{INCliES1 iEP+? ITS "c NW FA OF DAYS DEFART SRTST M. 3i.£f; 99. OF DAYS '�€4►i :BEAN MEAN FRL'F, a:& .7ES Ngs' DAt LRS T ?AT MAX NX KIN NIN TOTL FRom 08W DDT GTL G" T OAT 'SAX N4X WAL D4'S DAYS >90 <32 0.2 0 RORt4Ai. DAY FALL DEPH M M ?1. 59.. 50.5 5.2 :io v 67 31! 41 17 0 0 C, 0 11,Or MY 2,00 4 .0 0 17 B Z 64.: 3,: 4.:E 1,4 i72 10 83 20 4? iv""+ 0 O 4 0 1 �?,a0 �,65 ;.0i :4 . 0 3 I i S 63.G 53.0 56.3 1.7 206 3 7S 30 43 75 0 0 0 0 4,79 2,95 1.93 11 .0 0 5 3 2 4 64.4 32,9 55.7 .0 i:7 10 9 :4f 48 164 0 0 0 0 1,13 .23 .73 !S ,0 0 2 6s,5 55,7 5$,6 -2.6 192 ^ 6z 52 iS= 0 4 ^ 0 ,OE -.ii .(►6 it .0 0 0 0 0 A 64.8 5B,2 61." -2,4 12 5$ 9+ A 0 .82 .71 .65 It .0 0 2 1 0 )� 7 68:` 4:.7 65,1 -2,0 I3 3f 77 16 58 13 0 0 0 0 .06 .05 .06 16 .0 0 0 0 0 75 8 69,7 �?>4 66,* -2.? b 4, 76 29 58 26 t 0 0 0 .Of -.09 .00 31} .0 0 0 0 0 6v 77 2 58 30 0 0 n 0 .OD -.36 .41 30: .0 0 0 0 0 ?5 10 68,6 b(�.Q 44,3 -.5 2E 13 7$ 2 54 26+ C 0 0 0 .00 -.13 .00 31+ .0 0 0 0 ) ?5 11 65.3 5511 60.2 16 135 C 75 217 51 22 0 0 0 0 ,05 -1.50 .0S 1 .0 0 0 0 ( 45 i2 63.7 =0,3 51,10 1.0 241 0 69 1 43 17 0 0 0 0 1,;8 .11 .66 13 .0 0 3 2 11) AIN 65.4 5;,3 4v,9 -.4 1559 i71 83 AP,+ 41 044 0 0 0 0 21,06 0.21 2.00 ZAN .0 0 28 16 8 YISSFRS DATA. APPEARS WITH 4SW-;Y DATA P1.1 < iu DAYS ARE MISS + 0C�r#tR'.ED OR C.ZE OR MORE PREVICUR DATES D€i INS Tf E MONTH 4RP, iT APPEARS ALONE IF ? 9 SAYS ARE SISS. IT APPEWS kITA AN40L T TRACE `!4iA. RrEH DERIVED fR[fM MNNTH8 1WN MSC NTA, V Ir-LURES MAL F9R. PREVIOUS X0�i 4 AwnJ4 TED yONTRLY!ANNUAL T51AL CIONTA14q. ES MD VALUES FOR AT3G DATA A FRCP A#t NT lAY i�LURE PREr THAT MCURGD IM PREVI3US ACNTt .i ER ST.DV.BT5 "s D147T is :?i:9qq rh St^uC - -------------------------- - - ---------- _ �Q ,)) h! C -wA"DLO lu; suYINARY 4 1 •v NATt AL CL Iyq TIL DATA KW T R -. c y� nC_skl:C Ak7 :±?uUt�P En+ AD I�I3`YATIti'I I:EDERAL BUILDiNs AMILLE. NOPTI N CAirCUNA 5?FTIh�: �4A#£: �- - 28501-50D1 a:W E LAT, .OM. ELEV. CA.; 7pn.R 333b-l17�Sa ii► T Eq°CRQTu.°„5!F i PiREC 1 P I T AT 1 a.N:1 NC RES I DEPRT 47s LL5 W MRER DF DAYS DEPART SR~ST $PON. SLEET #0, OF DAYS 2"Ea "=Ati KAN FROIN 4£S YES {SST DAT LMST DAT FAX MAX Nlk MIN TO FRGM OBSVD DAT TSTL STST DA" rc xAr myylk k5«AL yAYS ;: Y5 :>f., Q 02� CO MAIL 04{7, FAJli�. p(E'F?i 7,i >.5 gL.E1a YYr Yak.Vx 4.2 .�6 :.". 77 yi 4a 23 v 4 O � 1.59 .47� a'C, YS .Q V S 0 L' .. .t. 4 11 i2# 37 Z, 0 0 0 0 .,.50 3,40 20 ,0 o 7 z 3 61 50.7 ai 2a7 4 713 44 S 0 4 0 0 103 .9i .37 13 .0 0 5 0 t! 4 :7. ,. 53.^ ..Z i.5 4 -'4Y ..b7 = 49 19 y k' 0 0 .33 .57 ?� k .0 0 v 0 0 V 5 67." 5p.2 61.5 2.7 54 15 74 12;- 5! 26 0 00 31+ .0 0 s, i x �F p A r] n �a =n n p� a 6117 � ai �,L si i` 7b 30 S7 i<$ •{ Q I •i .OV -,QS .tit 3�4 .Q 4 C. ti 12 fic 16 1 51 8 a 0 0 0 a02 .01 .,2 27 10 0 0 0 01 7:.. 64.3 5&>1 0 :0 "b 30+ 59 29+ 0 0 0 0 .00 -.09 .00 31+ .0 11 0 0 0 'r ? iL.-> 54.2 67.6 n85 75 9+ 60 14 0 0 0 .00 -.36 .00 30+ ,0 0 0 0 0 ?b 10 67.: 57.3 12,2 -2.� 32 3 73 22+ 50 h 0 0 0 Y 1:13 .?5 1.12 50 .0 0 1 1 ! }6 11 E717 53-3 016+ 1.0 140 15 52 ? 46 30 0 0 0 0 2,71 1.18 1.41 12 .0 0 i '. 2 12 54.0 51a2 5'7.5 2.2 __. 1 78 17+ 42 25 0 0 0 0 2.12 .55 1.02 11 .0 0 4 1 ANN ��.7►E 53.1? 6119!' 16 1Y€7$ Lot E7 ARR 37 FES 0 0 0 4 12.50 1.35 1.4emwv 10 0 24 ! 5 !.. . DAT• APPEARS �oITFi K-.tTiiLY DATA 4HcW � 3 DAYS RRE RISE �' DCCkIRE-u r Ok£ DR #EA4-s PnE'lIOJS DATES IM#RIN6 THE tlZMTN ��z ;T AFPcAPS E IA i 9 0Rj5 ARE xI £, iT A al rH ANN'Al . T TeZACE DATA. �41: ikRIYED FROG ;'UT-S !114 006 3i,T4, V INCUDES T07AL FOR PREFVIi US MERTH MO`ITHi.Yl�'AnSAE TOTAL CO3iin's?�y ESTi!) VALUES =3R FIS9 DATA A FRCP A. UNT FAY iNCLUM PROF THAT aCCORE7 !I PREVIO;.'S xiVj1 \!C4 .T+rt.Cil S DIBI T '"D `T/ TOT '_ P.27 S _, Or1_qT BIOLOGICAL. CONSULTING 5 April 1998 Nancy Donoven BOLSA CHICA LAND TRUST 4831 Los Patos Ave. Huntington Beach, CA 92649 Re: Potential agency jurisdictional wetlands on Shea Homes property Dear Ms. Donoven, During my visit to the Bolsa Chica area with you and Dr. Jan Vandersloot on 17 March 1998, I observed three areas on lowlands adjacent to the mesa that may come under state or federal jurisdiction as wetlands. I understand that these areas are on land belonging to Shea Homes. They are: (1) agricultural lands east of the mesa and northwest of the East Garden Grove Wintersburg Channel, (2) a ponded area east of these agricultural lands, immediately adjacent to the Channel, and(3) low-lying land southeast of the mesa and north of the Channel, adjacent to a Southern California Gas pipeline. As you may be aware, wetlands are formally delineated based on three criteria: hydrology, vegetation, and soils. I did not conduct a formal wetland delineation, but I did note the presence of ponded water and/or fully saturated soils at all three areas. This water would appear to meet the first(hydrology) delineation criterion. The second criterion, vegetation, is determined by identifying dominant plant species and determining whether they are considered "obligate wetlands," 'obligate uplands," or "facultative" species. While I did not collect formal vegetation data, I did note that one or more plant species at each site is generally associated with wetlands. More precise vegetation data could be collected in a few weeks, when more species can be identified. Finally, I did not dig soil pits to check for indicators of hydric soils; I did, however,note a sulfurous smell and heavy accumulation of black organic material in one area and ponding or soil saturation in all three areas. These observations are consistent with the hydric soils criterion. The area east of the mesa is lowland at sea level elevation; presumably, it was historically part of the tidal wetlands at Bolsa Chica, though it probably has little or no tidal influence now because of the flood control channel. It has been recently disced and I understand that the site once was delineated as a wetlands,but was re-classified as "converted cropland." I did not note physical evidence of drainage structures or ditches which would drain the former wetlands, resulting in "conversion." Instead, soil throughout most of the area was fully saturated. I noted Lythrum hyssopifolium ("hyssop 99 l;ast C: Strcct No. 200 l upland, CA 1)1786 (909) 949-3686 Fax (909) 949-8337 e?rnn;l ev.F±,le!olcyt>Crq$tCnm loosestrife"; a"facultative wetlands"plant) and Salicornia sp. ("pickleweed"; an "obligate wetlands" species) in this area. More detailed work will be necessary to determine whether the area meets state or federal wetland criteria,but I believe that there is good reason to follow up with a formal delineation. It is not clear to me that current or historic agricultural practices have actually"converted" the area from its former wetlands status. The second area is directly east of the "converted cropland"area. This area has evidently never been delineated as a wetland. I observed pooled water over fairly wide area immediately adjacent to the flood control channel. I did not observe plants there because the deep mud made it inaccessible. I understand from Dr. Vandersloot that the area has been ponded since last December. Again, more detailed work will be necessary to determine whether the area meets state or federal wetland criteria,but I believe that there is good reason to do so. The third area is also between the mesa and the flood control channel, adjacent to a Southern California Gas Company pipeline, and west of the"converted cropland" area. I noted Salicornia growing in this area, scattered areas of ponded water, and fully saturated, heavy black sulfurous-smelling soil throughout. This smell and the accumulated organic material is an indication of little or no oxygen in the soil,which results in reducing chemical conditions characteristic of wetland soils. Once again, I believe there is good reason to verify whether or not this area meets state or federal wetland criteria. In general,all three of these potential wetland areas have been degraded by current and former land uses. I believe, however, that they have strong potential for restoration to higher quality natural habitat, since they have suitable soils and adequate water supply to support wetlands vegetation. If salt water enters the site by infrequent extreme high rides or by subsurface intrusion, then the area may be suited for restoration as coastal salt marsh habitat. Otherwise, it would likely be better suited to support freshwater riparian habitats. The land's potential value as wildlife habitat is particularly enhanced by its proximity to the extensive Bolsa Chica wetlands area, and future land use planning should note that the flood control channel does not isolate the area from bird use or reduce its habitat value for birds. Sincerely, cc. Dr. Jan Vandersloot Doug Stewart 93 CONSI TL U-T.G BI©LO,GIST Humboldt State University, Arcata, Californa Bachelor of Arts. Biology, 1981 Secondary Teaching Credential, Life Science. 1982 Master of Arts, Biology, 1992. Thesis title:Quercus wislizenii forest and shrubland in the San Bernardino Mountains, California. c', OFESS�ON L E. 'ERIE! CornsuUing Biologist.'Tierra Madre CowWtants 1989-1995;Psomas and Associates, 1995-1998. Primarily responsible for biological surveys, report preparation, client contact, and agency coordination. Specialties inohde rare plant surveys, wetlands delineations, vegetation description,habitat characterization (e.g., suitability for sensitive species), revegeta*n planning, and mitigation design. Routinely prepare reports to document field work and propose mitigation strategies to meet requirements of CEQA, NEPA, SMARA, state and federal wetlands requirements, and Iocal planning policies. Botanist.San Bernardino National Forest, 1987- 1989. Team leader for data collection and participants,damanalysis for vegetation management planning and ecosystem classification. Assisted in analysisand interpretation of vegetation data, leading to a classification system of southern California chaparral. Provided mapping and implementation recommendations for prescribed burn planning and other habitat management projects. Participatedin vegetation sampling of California spotted owl territories. Prepared Environmental Assessments in compliance with NEPA. Community College Instructor., Nit. San Jacinto College, Menifee 'Valley Campus, Spring semester 1993. Taught evcning class in Environmental Science. Course covered Ecological principals and impacts of land uses, pollution, and policy to environmental values. ISER1IrlC75 • Vegetation Comarnittee; California Native Plant Society(member since 1990; reviewer of A Afanual of California Vegetation [J.O. Sawyer &T. Keeler-Wolf 1995]). • Guest editor; Fremontia Coastal Sage Scrub special issue(October 1995). • Field trip leader and training seminar instructor for local volunteer organizations including The Crafton Hills Conservancy, The Riverside Land Conservancy, and The San Bernardino Valley Audubon Society. • Sourhem California Botanists Board of Directors(since 1997). • Research Associate at Rancho Santa Ana Botanic Garden and U.C. Riverside Herbarium M tiIBERSHIP California Botanical Association Society for Ecological Restoration California Native Plant Society Southern California Academy of Sciences International Association for Vegetation Science Southern California Botanists Society for Conservation Biology Southwestern Association of Naturalists CER-f IFICAT ON • California Department of Fish and Game Authorization to Collect State Designated Endangered, Threatened and. Rare Plants • USDA Forest Service California Region Botanical Collector's Permit PROFIESSIONAL PRESF.1"rrATIONS • "Structure and Function in Southern California Chaparral," presented at Southern California Botanists annual symposium, 1997. • With Martha Btane: "Planning and Monitoring for ]geological Function," presented at Society for Ecological Restoration California Chapter annual conference, 1996. • "Vegetation Descriptions, Site Characteristics, and Plant Ecology in Puente Hills.Shrublands," presented at the Symposium on Natural Resources in the Puente Hills-Chino Hills Corridor, Whittier College, 1994. Updated 4 Feb 98 _'i99B 1=. 5 �194�J�i^ S,:0TT ,jHITE SIOLOGIC PAGE e3 SCOTT D. WHITE Restoration and Revegetation • Society for Ecological Restoration. California Chapter, Region 5 Annual Meeting, Riverside, Feb. 1992. • Restoration Ecology. 3-unit biology course, UC Irvine, Fall semester, 1992. Peter A. Bowler, instructor. • Arid Land Restoration. Symposium sponsored by Shrub Research Consortium, National Park Service, US Fish and Wildlife Service, 'Ile Nature Conservancy, and University of Nevada, Las Vegas; UNLV, October 1993. • Desert Restoration Workshop. Sponsored by Society for Ecological Restoration, presented by David A. Bainbridge. Red Rock Canyon State Park, October 1903. • Methods of Habitat Restoration. UC Riverside Extension 3-unit course,Fall quarter, 1993. T. St.John, instructor • Society for Ecological Restoration, California Chapter Annual Conference. Yosemite, October 1996. Wildlife • Southern California Spotted Owl Symposium and Workshop. California Poly Pomona, 2 March 1990. • 'Me Wildlife Society Western Division Annual Conference: San Diego, 20-23 January 1997. • Sensitive herpetofauna of Southern California: San Diego Natural History Museum, 14 March 1997. Land Use, Management, and Mitigation Planning • Muitiple-Species Habitat Conservation. UC Riverside Extension, March 1990. • Mitigation Measure Development and Monitoring. UC Riverside Extension,January 1991. • Natural Resources in the Puente Hills-Chino Hills Corridor: Implications for Land Use and Planning. Whittier College, March 1994. • Brushfires in California Wildlands: Ecology and Resource Management. Soutih=California Academy of Science Symposium, May 1994, UC Irvine. • Southwest Ecoregion Monitoring Workshop. UC Riverside, November 1994. • CEQA Workshop, Paone, Callahan, McHolm& Winton; March 1996. • Regional Habitat and Conservation Planning. UC Davis Extension, September 1996. • Southern California Before 1900: Landscape, Climate, and Ecology. CSU Northridge, Sept. 1996. • Annual CEQA Workshop. Association of Environmental Professionals, February 1997. • 2nd Wildland ! Development Interface in Southern California Conference. Occidental College, April 1997, • California Surface Mining and Reclamation Act. UC Davis Extension, July 1997, RELATED EXPERIENCE AND PROFESSIONAL D-717ERESTS • Southern.California floristics and phytogeography, particularly inthe Inland Empire, San Bernardino Mountains, and San Jacinto Mountains. • Use of quantitative data and multivariate statistical techniques in classification of natural plant communities and wildlife habitat types. • Role of fire and other natural disturbance in ecology and development of southern California shrulblands and forests. • Effects of brown-headed cowbird nest parasitism on native bird populations, and the potential application of habits management techniques which might reduce parasitism rates. • Development of integrated mitigation policies, including "mitigation banking," to effectively preserve plant and anutial populations, sensitive habitats, and esthetic resources(e.g., "heritagetrees") using principals of landscape ecology. 3 Updated 4 Feb 98 rq—V 13: E, 903949933� SCOTT 4,1HIT- BIOLO,510 PAGE 04 RE PRESENTATIVE PROJECTS BIOLOGICAL ASSESSMENTS AND GENERAL SURVEYS • Lake Arrowhead Community Services District Proposed Wastewater Line: Biological Assessment and Lake Arrowhead Community Services District Proposed Water and Sewer System Master Plan Improvements: Biological Assessment: Prepared in 1991-92 for J.F.Davidson Associates. Reports completed for CEQA and NEPA compliance and US Forest Service review. • Market St. Bridge Seismic Retrofit: Biological Resources. Prepared for Riverside Co. Transportation Dept. in 1995,to determine presence or absence of two endangered plants (Santa Ana River woolly-star and slender-horned spineflower) and to assess potential impacts to other special status species and/or habitats. • Proposed Upper Furnace Canyon Quarry Expansion: Biological Evaluation and Revegetation Plan. Prepared in 1994-95 for Specialty Minerals, Inc. and submitted to San Bernardino National Forest and San Bernardino County Planning Dept. Focused surveys for federally-listed endangered plant species, prepared reports addressing endangered species occurrence,mitigation measures, and revegetation. The project has been approved by both agencies and quarry expansion is now pending. RAF.E PLANT SURNT YS • Federally Listed Plants on Selected Specialty Minerals,Inc. Lands. Prepared for Specialty Minerals,Inc and submitted to San Bernardino County Planning Department. Determined presence, abundance, and habitat characteristics of four listed limestone-endemic species on proposed set-aside areas as mitigation for impacts of new quarry. In coordination with the client and County, selected and finalized a mitigation area design. • Radcliffe Mine: Focused Rare Plant Surveys.Prepared for Compass Minerals (Reno,NV) and submitted to Bureau of Land Management to determine presence or absence of several agency-sensitive species at a proposed gold mine site in the Panamint Mountains. • Proposed Cadiz Valley Pipeline: Focused Rare Plant Surveys. Prepared for Cadiz Land Co., Ltd. Managed field team surveying potential pipeline routes on Bureau of Land Management land to determine presence or absence of several agency-sensitive plants, and- their relative abundance on alternate routes. Surveys totaled about 90 linear miles_ • City of Redlands Orange Street and Alabama Street Santa Ana River Crossings. Prepared for Redlands Public Works Dept. in 1993 to determine presence or absence of two endangered plants(Santa Ana River woolly-star and slender-horned spineflower) and identify measures to avoid or minimize impacts to these species during reconstruction of bridges lost during 1993 winter flooding. • Paradise Hills Specific Plan: Focused Biological Surveys. Prepared in 1993 for Fontana Corners III(landowner) and submitted to City of San Bernardino Planning Department. Carried out focused surveys for special status plants and plant communities; managed field surveys for special status animals, including California gnatcatcher,least Bell's vireo, arroyo toad, and San Bernardino kangaroo rat;managed report preparation. 1 SCOT F D. 13TIRTE 60 _r`1998 18:56 9099498337 SCOTT t,MITE BIOLOGIC PAGE 05 RM,rF GETATION, 1?I..aNi1TL.TG • Edwards Air Force Base: Base-wide Revegetation Strategy. Prepared in 1994 for Tetra Tech,Inc. (primary contractor) and submitted to US Air Force Flight Test Center Environmental Management Office. Prepared draft and final reports, addressing seed collection, nursery practice, soil salvage and stockpiling, site preparation,planting, monitoring, maintenance, and remedial planting;primary client contact throughout project. • Alberhill Ranch North Revegetation Plan. Prepared in 1993 for Halloran and Associates (primary consultant) and City of Lake Elsinore Planning Department. Prepared revegetation plan for mitigation of anticipated impacts to coastal sage scrub (occupied California gnatcatcher habitat) and wetlands;primary client and agency contact throughout project. The proposed project was approved by the City. • Revegetation Plan: Specialty Minerals,Inc. Operations on the San Bernardino National Forest, Specialty Minerals,Inc. A review of vegetation and habitat occurring on and carbonate soils of the northern San Bernardino Mountains and the progress of previous revegetation efforts; recommendations and specifications,including soil salvage and treatment,plant material collection, site preparation, plant palettes, scheduling, and monitoring plan. Revegetation Plan: Pluess-Staufer(California),Inc. Mining Operations on USDA Forest Service Land,San Bernardino National Forest, San Bernardino County, California, Pluess Staufer(California), Inc. A review of progress of previous revegetation efforts, including quantitative sampling to measure success; recommendations and specifications for future revegetation,including soil conservation,plant material collection,site preparation, plant palettes, scheduling, and monitoring plan. I ETLAINDS • Tustin Marine Corps Air Station.Delineation of jurisdictional wetlands and waters of the United States throughout the base in support of base closure and reuse planning. The project included analysis of present and former land uses throughout much of the base;particularly drainage channels and low-lying seasonally flooded areas. Focused surveys for special status plants and animals, and the potential occurrence of wetlands or other seasonal wetlands were also addressed. • March Air Force Base. In support of an environmental remediation program, prepared a delineation of jurisdictional wetlands and waters of the United States at an site which had historically supported vernal pools and other sensitive resources. • State Route 90/Culver Flyover: Jurisdictional Wetlands, Streambeds, and Waters of the United States. Prepared in 1995 for California Department of Transportation and submitted to US Army Corps of Engineers. Carried out wetlands delineation in area to be affected by proposed roadway improvements. • Cajon Pipeline Project: Jurisdictional Wetlands,Streatnbeds, and Waters of the United States. Prepared in 1993 for Cajon Pipeline Company. Wetlands delineations for 113 drainageways, including 63 jurisdictional streambeds and seven supporting jurisdictional wetlands. The client secured permit approval from state and federal agencies following submittal of the delineation. SOOTT D. WHITE �7 1993 I8: 5E• 50'39a98�3I SCOTT WHITE BIOLOGIC PAGE bh RESER*1vM PLAINTi*TIENG &N.AANAGEMETNT • Coal Canyon Tecate Cypress Reserve Management Plan. Prepared in 1990 for The Nature Conservancy and submitted to California Department of Fish and Game. Carried out field work and prepared management plan addressing potential reserve configuration and recommending management strategies for special status plants and animals, particularly fire management for Tecate Cypress. The State of California purchased acreage as a Tecate Cypress Reserve based on these recommendations, and is now implementing the plan. • San Bernardino County Sheriffs Training Facility Mitigation Area Management Plan. Prepared in 1990 for San Bernardino County Sheriff s Department. Carried out field work and prepared management plan recommending management strategies for special status plants and animals,particularly the endangered Santa Ana River woolly-star. The project site is now managed as a reserve area to mitigate loss of comparable alluvial scrub habitat at a Sheriff s Department training facility. • Cleghorn Canyon Candidate Research Natural Area: Ecological Survey and Bioregional Analysis.Prepared for USDA Forest Service Pacific Southwest Forest and Range Experiment Station. A broad review of flora, fauna, vegetation,ecological function, and management recommendations for the CRNA, including quantitative vegetation data. LET-HER • Winchester Hills Specific Plan: Assessment of Cumulative Impacts to Biological Resources. Prepared in 1993 for Cotton/Beland/Associates(primary contractor) and Riverside County Planning Department. Carded out literature review and site visits;prepared draft and final reports addressing cumulative impacts to special status plants, animals, and communities, including Stephens' kangaroo rat, California gnatcatcher, coastal sage scrub, vernal pools, wetlands, and wildlife corridors;primary client and agency contact throughout project. • Wildlife Corridor Assessment: Tentative Tract Flaps 12561 and 12562 in San Bernardino County.Prepared in 1992 for Stubblefield Companies (landowner) and San Bernardino County Planning Department. Completed literature review and field work; prepared draft and final reports primarily addressing potential project impacts to County- designated wildlife corridor on the project site and recommending mitigation for these impacts; primary client and agency contact throughout project. • Coastal Sage Scrub Classification for Western Riverside County. Prepared in 1994 for Pacific Southwest Biological Services(primary contractor) and submitted to Western Riverside County Habitat Consortium. Carried out multivariate statistical analysis of data collected throughout region and classified regional coastal sage scrub at the series level for ongoing habitat conservation planning; primary client contact throughout project. The classification was published in Madrono(an academic botanical journal) and forms the basis for Riverside County's planned Multiple Species Habitat Conservation Plan. 3 SCENT D. "NliI 'E 48 CHI,=H LA 11 TPU e�:,T PHO JE HID. . 71-4 560 '?^'� f'lo_,. _= 1' ' 10:4199 41•1 P2 / a-ma i f Tom Yocom to N&nQy Doraven, 5/19/98 page I of 2 eire-typeor clarity) Thank you for your call yesterday regarding areas that may potentially be subject to regulation under the Clean Water Act and/or Ravers and Harbors Act within the Shea Homes parcel at Bolsa Chica. As I told you yesterday, the determination of the geoographic extent of jurisdiction under these federal statutes belongs to the Corps of Engineers, Los Angeles District, with its determination of Clean Water Act jurisdiction being shared with the Natural Resources Conservation Service under an interagency Menorandum of Agreement. Although it is true that EPA made a "special case" determination of Clean Water Act jurisdiction for all of Balsa Chica in 1989, that determination has expired. As you also know, EPA determined in 1989 that portions of the Shea Homes parcel were subject to regulation under Section 404 of the Clean Water Act, but these areas were later disclaimed under the "prior converted cropland" rule that was adopted by the United States, I believe, in 1993. EPA also found in 1989 that it was likely that portions of the Shea parcel would be subject to regulation under the Rivers and Harbors Act, recognizing that the final determination of such ,jurisdiction rests solely with the Corps. I understand that the Corps is reviewing its extent of jurisdiction at the Shea parcel, including the extent to which portions of the site may pond water for sufficient duration in most years to constitute regulated "wetlands" (areas that pond water for more than 14 consecutive days in most years -- i.e., 51 out of 100 years -- are considered "farmed wetlands," rather than prior-converted cropland, and are, therefore, subject to regulation -- assuming that there is a commerce nexus) . A lack of wetland vegetation on an area that ponds water for such duration would not necessarily affect the extent of jurisdiciton. For example, iof an area is disked, this destruction of vegetation would not be grounds for disclaiming jurisdiction, unless either the hydric soil and/or hydrology parameters were determined to be missing in most years. I know that local persons have been recording evidence of ponding for the past couple of years, or more. Whereas these have been unusually wet winters, it can be possible nonetheless to assess the likelihood of ponding "in most years" from periods within these wet winters. However, I cautioned you that simply because ponding has been observed during the past couple of winters is not, in itself, strong evidence that "wetlands" hydrology exists at the Shea parcel in most years. Regarding your questions about EPA's preliminary assessment of Rivers and Harbors Act Jurisdiction, I strongly reiterate that the determination of such jurisdiction is solely the responsibility of the Corps. I will note, however, that the Ninth Circuit Court of Appeals (in the 1978 case, Froelke vs. Leslie Salt) instructed the Corps to assert jurisdiction to the plane of mean high water (the BOLSA +._H i t:A LAND TRUST PH&AE t 10. 714 '360 �9+ flay. �i� e-mail from Tom Yocom, EPA, 5/19/98 Page 2 of 2 mean high tide line) rather than to the more extensive mean higher high water (the mean of the higher of the two daily high tides) where the Corps bad already been asserting jurisdiction. The Court ruled that this extent of jurisdiction reached to the mean high tide line in its unobstructed natural state, regardless of whether a historically tidal site (or portions thereof) was presently tidal, or might be returned to tidal action in the future. The Corps of Engineers, San Francisco District, for example, has asserted jurisdiction over historical slough beds behind dikes, even when there is little or no evidence of the actual slough channels presently (they may, for example, have been obscured or leveled through agricultural practices over the past 100 years or more). I do not believe that the San Francisco District has based its assertion of jurisdiction on the likelihood that these areas would he returned to tidal action -- in fact, its jurisdictional determinations have often been made in cases where the future use of the site is decidedly upland uses (housing, light industrial, etc.). It was under these types of conditions that EPA assumed that Rivers and Harbors Act jurisdiction would reach portions of the Shea Homes property, given that portions of the site were historically tidal (see EPA's 1989 jurisdictional determination for Bolsa Chica, which included an estimate of Rivers and Harbors Act jurisdiction, based upon Coast and Geodetic Survey topographic charts from the 18501$), EPA assumed that, as with the San Francisco District, the Corps Would assert jurisdiction over areas where tidal sloughs were present prior to the alto being diked in 1899. I hope this helps with your questions about federal regulatory jurisdiction. Again the final determination of Clean Water Act Jurisdiction and Rivers and Harbors Act jurisdiction for the Shea Homes parcel will be made by the Corps of Engineers, Los Angeles District. I encourage you to contact the Corps with regard to any spectfric questions or comments you may have. Tom Yocom, EPA, Region IX Phone: (415) 744-1975 e-mail: yocomthomas@epamail.epa.gov 6222C-4/92 Ilk '�y;, F k. i MEDIUM DENSITY RESIDENTIAL 9i1 2 1 HIGH DENSITY RESIDENTIAL 'CO.ie, • •' '� ''; i 3 1 1 HEAVY DENSITY RESIDENTIAL Q i MC MARINA COMMER NO C� ` O �WQ LOCAL COASTAL PROGRAM BOLSA �• CHICA SEGMENT BOUNDARY LINE ey WETLAND WETLAND \ BOLSA CHICA STUDY AREA t 1 _FLOOD CONTROL' WETLAND BOUNDARY LINE ACH 3 CHANNEL ' I BOLSICA GARFIELDCONNfCrOq Jam' 3 LINEAR, j t�P 4 2 3 RPARK AL/I w 9 % •' 'OyQ 3 i 3 T MC m i _ 2 I i „ . •;� i 1 / 1 CENTRAL WETLAND MC i 3 3 I %� / I 3 i r 3 MC %I 3 / - PACIFIC COAST HIGHWAY 'will I oil Imam I BOLSA CHICA STATE BEACH OUTER BOLSA BAY WETLAND FEET COUNTY OF ORANGE +N. o Boo 1600 LAND USE PLAN Ftl ource: County of Orange FIGURE 2.4-1 PURPOSE AND NEED FOR ACTION Bolza Chica DEISIDEIR coastal oriented commercial uses. An environmental impact report was prepared for the LUP for the proposed project and the LUP was adopted in 1985 by the Orange County Board of Supervisors after extensive revision to satisfy the concerns of the California Coastal Commission. The California Coastal Commission denied the revised LUP,but then offered to certify the LUP provided that Orange County would accept certain conditions. The LUP was conditionally certified in 1986 and is shown as Figure 2.4-1. It should be noted that the conditions for the LUP were never fulfilled and lack of community support coupled with additional information on the extent of wetlands on site made the implementation of the LUP infeasible. The Bolsa Chica Planning Coalition (BCPC) was formed in late 1988 by Orange County Supervisor Harriet M.Wieder and then Huntington Beach Mayor John Erskine. The core members of the BCPC included the County of Orange, California State Lands Commission, City of Huntington Beach, the major landowner(Signal Bolsa Corporation),and the Amigos de Bolsa Chica. In addition, numerous interested parties and agencies were invited to form a technical advisory group to the core group. The Bolsa Chica Planning Coalition Concept Land Use Plan was developed through the BCPC. This plan is provided in Figure 2.4-2. This plan, which has not been formally certified or adopted by any public agency, was used by the Signal Bolsa Corporation as the concept plan for the proposed project (Alternative 1) and is the basis for the LCP being pursued by the City of Huntington Beach. 2-12 ' b I MW Rm \\,C\' ""k'f'. \ , I v : ♦\ .\AYE:.' I � . - . • ..; — — -- - �cr .Cf� • I I \ I y ; • J / /. • • r • • • • • •�_� I �' I 1 ICI) , '�f,wh`�`SY'r r S I I I 1 r J x x �� �I��� 1 \ s�'= a� M���`�..d\ s x:a• \\a,;,�.y,�c�a.�,....w"'�a'�c k"*s....._...L�,�.,� y y { r � -'L.. \� s - � Ss �\ 'fies✓ "~y:~�31 \ `a ��:s \ .-, '' r'. L t --W�. ebl 'x��,.�5� u• �,,.. r `h.�J•�ws^�'\ ''„y.�` ,r.r;i "F r�"�"`�`"v♦ `a' k .�\\\\��er.' >�:� �C x�'�^3�, :. • ,•• ;.a,�,. :s r''r�"���a'�a py x'r s:�.\il's.z`n.�,^\'r' E \,,,""k, �a' ^�.�\.. ,, c�. a..�� a"`�4,..�'�- \\ 1 • • • r �°F' £ ys� �n 3 x"�'�,c 'a,k. ..,;.�� s �- � `\"' \.. im �'\`ca.;d.r,-^c�>,Q�, ^s,�,• "' a e '.F.. >M �"-.i'^M `4,,,.�r:�,y'�% ' �o.:rx :."1.a`s� \�a�"'r,i'�i..♦ '.� ,ti,.,...::�� ..a''c .\;;�e,:..� .;y Y �a I { i I LEGEND u,TEmweo 9ou4Q'\R•r - - - _ - •F. - -l$?!• l- � - .7' - �: �\.-'I_c;p.i `�...` - _ _ _. .- - .. �air _ _ .- M-CW PATH J. eoLLAUZEA ptms 7. oxPOGssaw \� -�� 1 �,/ a. '' - 'r .?�.���� %`"`,4 (`i i/''is.•---\` _.�,�.�-- \"- �:•c, - �-f�, - \ i _ -(-• ter- _ _ �/ . �,.e,���1�� J� i�• —.J, ••',^":.� ��./^. _ _� _ - _ _ - -_ - /`/ ��-_ ="I�—_���- _ +v-+2v6_.Ct_— � _ - - - _ l` _ W1W+..W Y���.O.I� t e _ _ I /f� f - _ - _ -' - - a/-/�•,-• �C':�'- _ _ - _\ - _..- _ _ _ _ _ � _ � _ L.� m.am�w�me a.n w. 'OUTER eoLsa ear i T�..o. . S, •' -'_ u+Ne -__ _- n BOCSA BAY � -I•,_ _ � --�- - -" -•_ \-_-��'�.�•- _ - - ' - - 'ter 1 ` FEET Bolsa Chica V 120° EXISTING CONDITION DRAINAGE PATTERN MAP swa: wiuiwnsm JL scnfn;d,c;hl Engine«s Figure 4.4-1 A 4 .7(. oq v A v �' � a { �'• �4 z z x m � x Z 0 v m i � r ' ,r; rY':�IL' �•:- r ,- � 't�0::.� '� r. .� � ♦jam\]�� pli J' `'.� 1 l . Y .,• 1.:.'•A1{1� a•) ' \,� 1 �i'• ` 1 '!�• 1t\5t� II � •\ '.All,• (Z •'�} �/�:';�'?'t•r J•'1 ��,'� , ,.....� {I.• 11 I I'r: . 1 '�' 7:, ' y' o41 , ,1. '' j/ •\y ,,•.• ,',t .��n. '.r- m•C 10 lo Lu of It .� •, ice+„M• �:... ' f,`' �. 'r�' - \ '•�'�'•• ��' •,Il , .' r!. y• ,..•• ... , ,,• , ,�-/ F-� 'i I{`}•�I �;1,i i'%\`'' ,�c' I 1 '�� , '`, ,N, ''. .' '','J � ',' �..;�� O L� jl 11, � ,' • ' III I' �I' '\ ', , `�'� ••'�-J � :��•1;'! •`•1:,'�„ ' ,, .,,' 1 �`""�+'' -`: '•lam-"' I• `rF+`"S,' 1 ,'/r��I 11) ' .ctr,nt'. `� txj 041 gg � Ni ' tij l7 0 .i ss James L.Hudson,Jr. 5331 Kenilworth Drive June 11, 1998' Huntington Beach,CA 92649 (714)840-2773 Ms. Melanie S. Fallo J U R i 'Z7 1998 Director of Community Development City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Ms. Fallo: The following is one comment I have concerning Draft Environmental Impact Report #97-2 for the proposed Parkside Estates development. Environmental Analysis—Transportation/Circulation Page 5-74 Delete the second sentence of the second paragraph that states, "Alternative options may include secondary access through residential neighborhoods combined with left turn prohibition at the Graham Street/A Street Access." It is totally inappropriate for the drafters of this EIR to include a"possible" option (i.e., opening the Shea development on to Green Leaf Lane)that was purposely deleted by JLHa-1 the developer and removed from the revised traffic study that was approved by the Huntington Beach Traffic Engineer. Also see the statement on page 5-73 that states, "The project proposes unrestricted access (i.e., not gated) at the intersection of A Street (new project street) and Graham Street. According to the City Traffic and Fire Department(s),this access (along with secondary "emergency only" access) is adequate to serve the proposed project." In addition to deleting this misleading sentence it should be a matter of public record, should the proposed development be approved, that such approval is based on the condition that there would not be any future action taken to open access via Green Leaf Lane. This additional step should be included in any actions taken by the Huntington Beach Planning Commission. You and the Planning Commission should be well aware that the citizens of Kenilworth Drive and other streets in this area are very wary of what the City might do concerning the locked gate at Green Leaf Lane once the development, if approved, is built out. Res Res ctfully, "Y'James L. Hudson, Jr. 67 James L.Hudson,Jr. 5331 Kenilworth Drive June 11, !998 Huntington Beach,CA 92649 (714)840.2773 Ms. Melanie S. Fallo f� 1�98 Director of Community Development City of Huntington Beach CGy„ .: L't'V itir� ,�dtiT 2000 Main Street i:iV#T1' Huntington Beach, CA 92648 Dear Ms.Fallo: The following are additional comments I have concerning Draft Environmental Impact Report#97-2 for the proposed Parkside Estates development. Several places in the Draft EIR make reference to the Land Use Element(LUE) of the City of Huntington Beach General Plan as allowing a development density of 7.0 dwelling units per acre for property designated as RL(i.e., low density—residential). This is misleading and, in my opinion, is does not properly present the facts. First, the LUE presents a guideline for a maximum density of 7.0 DUs per net acre. This is consistent with the City of Huntington Beach building codes that prescribe a"Minimum Lot Area per Dwelling Unit" of 6,222 sq. ft. or the same as 43,560 divided by 7. The Draft EIR appears to treat the 7 DUs per acre as per gross acre. The first alternative JLHb-1 is presented on this basis and as thereby wholly without merit. More to the point, I believe the governing requirements to be the City of Huntington Beach Zoning and Subdivision Ordinance. The development standards for RL designated properties includes "Minimum Building Site Requirements" of 6,000 sq. ft. and 60 ft. width.There is also and additional requirement for a"Minimum Lot Area per Dwelling Unit"of 6,222 sq. ft.. The definition section of the ordinance does not provide a definition for this last requirement; however, as cited before, based on the LUE the Minimum Lot Area must be net lot size. In terms of the code requirements, the developer is proposing 113 lots of 208 total lots (54%) with a 50 ft. width.While not all of the 113 lots are exactly the same size, a far majority of them measure approximately 50 by 102 ft. or 5,100 sq. ft. The number of lots this size was not clearly stated in the Draft EIR and even with a magnifying glass I could not make and exact count,but I believe at least 80 of the lots were of this minimal dimension. It is possible that the details of the developer's proposed Conditional Use Permit may have been included in some of the attachments to or references in the Draft EIR,but I would consider the extreme number of variances to code to be a real issue. If the requested variances to code or not required to be addressed in the EIR,then it should be a matter of most importance addressed by the planning staff and the Planning JLHb-2 Commission. The following excerpt is from Chapter 241 of the Huntington Beach Zoning and Subdivision Ordnance concerning granting of variances. Variances may be granted to resolve practical difficulties or unnecessary physical hardships that may result from the size, shape, or dimensions of a site or the location of existing structures thereon; from geographic, topographic, or other physical conditions on the site or in the immediate vicinity of the site. JLHb-2 (Cont) I could understand a few (maybe 2 or 3) lots might be proposed which do not meet code because of the shape and dimensions of the property, but nothing in the procedures for approval of variances would allow for such wholesale waiving of the code. To the contrary, I find nothing that would even come close to supporting a recommendation for approval by the City Planning staff or approval of such a recommendation by the Planning Commission. Respectfully, James L. Hudso 68 STATE OF CALIFORNIA-THE RESOURCES AGENCY PETE WILSON, Govemor CALIFORNIA COASTAL COMMISSION South Coast Area Office 200 Oceangate,Suite 1000 ong Beach,CA 90802-4302 - (562)590-5071 • J.uhe 15, 1998 7 �na Jim Barnes, Project Manager City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 SUBJECT: Comments on the Draft Environmental Impact Report (EIR No. 97-2) for Parkside Estates (SCH #97091051) Dear Mr. Barnes: Thank-you for the opportunity to provide comments on the Draft Environmental Impact Report (DEIR) for the Parkside Estates (Shea Homes). The project under consideration is the subdivision of the project site and the construction of 208 single family residences on approximately 49 acres. Approximately 44.5 acres of the project is within the corporate limits of Huntington Beach. A total of 181 CCC-1 homes will be constructed on the 44.5 acres located within the corporate limits o the City of Huntington Beach. The remaining 27 units would be located on 4.5 acres in unincorporated Orange County which is within the Bolsa Chica Local Coastal Program area. The comments below identify project concerns which Coastal Commission staff believes should be addressed in the final EIR. PROJECT DESCRIPTION The project description should be revised to state whether the proposed residential development will be a "locked gate" private community or one containing public streets accessible to the public. The Coastal Act encourages projects which promote public access and provide visitor serving recreational opportunities. Clarifying the project description would allow the reader to evaluate whether the CCC-2 on-street parking and the recreational amenities located in the proposed development would be accessible to the public. The public access implications raised by the project are discussed further starting on page 5 of this letter. LOCAL COASTAL PROGRAM a. Huntington Beach LCP The project site is covered by two local coastal program segments. One is the Bolsa Chica LCP area and the other segment is the Huntington Beach LCP. The DEIR correctly notes that a portion of the proposed project site is within the Bolsa Chica LCP segment and would be subject to the Bolsa Chica LCP. The Bolsa Chica LCP is discussed fairly extensively beginning on page 5-17 of the DEIR. The DEIR, however, is silent on the relationship of the proposed development to the Huntington Beach LCP. Page 5-30 of the DEIR does contain a section titled "Coastal Element". The narrative, however, does not provide an adequate CCC-3 background concerning the project site's relationship to the Huntington Beach LCP. The portion of project site within the Huntington Beach LCP segment was deferred certification by the Commission in 1985. Consequently, the standard of review remains the Coastal Act and any proposed development occurring in the protect site will require a coastal development permit from the Commission until the area is certified. The project area within the City limits was deferred certification based on unresolved issues regarding the protection of wetlands. These issues are still of concern today. b. Bolsa Chica LCP The DEIR correctly notes that the Bolsa Chica LCP has been the subject of several lawsuits. On February 20, 1998 the presiding judge ruled that the Commission's action of October 9, 1997 should be reconsidered since the Commission limited public testimony to the two topics that were at issue. The judge's ruling has been appealed. Consequently, pending the outcome of the appeal process, the Bolsa Chica LCP should not be used as the basis for reviewing certain project components such as wetland fill or mass grading. As an additional note, though the CCC-4 Commission took action on the Bolsa Chica LCP on October 9, 1997 and the County adopted the Commission's suggested modifications, the Executive's Director report to the Commission of the County's adoption of Bolsa Chica LCP did not take place due to the lawsuit. Therefore, effective certification of the Bolsa Chica LCP has not occurred. Pending resolution of the appeal process, the standard of review for any development occurring within the Bolsa Chica LCP area is the Coastal Act. Two significant project components that may be affected by the appeal process are: wetland mitigation and land form alterations. For example, the DEIR notes that the fill of wetland areas can be mitigated consistent with regulation 2.2.25 of the Bolsa Chica LCP. Regulation 2.2.25 allows the fill of pocket wetlands with a CCC-5 mitigation ratio of 4:1 . Policy 3.3.2.11 of the Bolsa Chica LCP allows the mass grading of the Bolsa Chica Mesa. Until the appeal of the Bolsa Chica LCP is resolved, the Coastal Act is the standard of review. Section 30233 of the Coastal Page: 2 Act does not allow the fill of wetlands for residential purposes. Section 30251 of CCC-5 the Coastal Act requires that alterations of natural land forms be minimized. (cont.) PROJECT ALTERNATIVES The DIER examined five alternatives to the proposed project. Not included as one of the alternatives was a project designed to avoid impacts to wetlands such as the remnant pickleweed area in the County portion of the project site. Additionally, the DEIR did not include a project alternative which would minimize land form CCC-6 alterations on the Bolsa Chica Mesa. An alternative or alternatives which avoids wetland impacts and mass grading should be included. First, as previously mentioned, the Bolsa Chica LCP is the subject of a lawsuit which may result in the Bolsa Chica LCP being revised. Second, the Coastal Act, as well as other laws, promote environmental protection. The DEIR cites the Environmental Resources/Conservation Element of the City's Land Use Plan which states: "Protect and preserve significant habitats of plant and wildlife species, including wetlands, for their intrinsic values". Developing a project alternative or alternatives which CCC-7 avoids the fill of wetlands and which minimizes the alteration of landforms are feasible alternatives to the proposed project. The inclusion of alternatives which minimize adverse impacts to the environment through avoidance would contribute to providing the decision making body with full range of project alternatives. WETLAND ISSUES a. Status of Wetland Delineation's The project area has had a long controversial history concerning the presence of wetlands. The Coastal Commission in 1985 deferred certification of this area CCC-8 based on unresolved wetland concerns. As previously mentioned Section 30233 of the Coastal Act limits the fill of wetland areas to eight enumerated uses. The fill of wetlands for residential purposes is not one of the eight enumerated uses. To address the wetland delineation issue the City of Huntington Beach hired Tom Dodson and Associates to evaluate prior wetland determinations and to conduct additional work for determining if wetlands exist on the portion of the project site located within the City of Huntington Beach. Through a letter dated December 17, 1997 an ecologist for Tom Dodson and Associates concluded that the portion of the project site within the City of Huntington Beach did not contain any wetlands CCC-9 based on the Coastal Commission's wetland criteria. The City of Huntington Beach (January 8, 1998) then requested that the California Department of Fish and Game evaluate the work done by Tom Dodson and Associates. The Department of Fish and Game (March 16, 1998) concurred with the assessment of Tom Dodson and Associates that the portion of the project site within the City of Huntington Beach Page: 3 does not contain wetlands. The Department of Fish and Game also acknowledged CCC-9 that the County portion of the project site contains wetlands in the form of remnant (coot.) saltmarsh vegetation (estimated at .2 acres in the DEIR). The findings of Tom Dodson and Associates including the concurrence of the Department of Fish and Game with those findings, have been questioned by Scott White Biological Consulting (April 5, 1998). At this time it is unknown if the information developed by Scott White Biological Consulting will affect the validity CCC-10 of the findings made by Tom Dodson and Associates. The final EIR should continue to incorporate and evaluate the biological evidence concerning the presence of wetlands. b. Wetland Delineation Methodology The delineation of wetland areas is a complex topic. Each agency undertaking wetland evaluations uses different criteria based on their individual governing statutes and policy documents. When it comes to determining the existence of wetlands, the Coastal Commission uses the U.S. Fish and Wildlife Service's wetland methodology developed in 1979. Under this methodology a wetland area exists if it possess any one of the following three characteristics: 1) the area supports predominantly hydrophytes, 2) the substrate is predominately undrained hydric soil, and 3) the substrate is nonsoil and is saturated with water or covered CCC-11 by shallow water at some time during the growing season of each year. The U.S. Army Corps of Engineers (ACOE) considers an area Federal jurisdictional wetlands subject to regulation under Section 404 of the Clean Water Act if the area posses all three wetland characteristics. Accordingly, when the EIR concludes that an area is not a wetland it must clearly state which criteria were used for making this conclusion. Tom Dodson and Associates (December 17, 1997) concluded that the portion of the project site within the City of Huntington Beach does not contain wetlands based on the Commission's criteria. C. Wetland Mitigation As previously mentioned in the section above, each agency has its own legislative mandates and regulations. The Department of Fish and Game states (March 16, 1998) that project impacts to the approximate .2 acre wetland area in the County portion of the project site would have to be mitigated. Section 30233 of the Coastal Act, however, limits the fill of wetland areas to eight enumerated uses. CCC-12 The fill of wetlands for residential purposes is not one of those uses. Section 30230 of the Coastal Act states that marine resources shall be maintained and where feasible enhanced. Therefore, the final EIR should explore a project alternative which avoids impacts to wetlands rather than simply proposing that adverse impacts be mitigated. Page: 4 d. Density of Development To avoid the fill of wetlands, one alternative which the DIER could explore is the shifting of residential development to areas on the project site able to accommodate it. The DIER notes that under the existing zoning a total of 367 residential units CCC-13 could be constructed on the project site. The proposed development at 208 units is less dense and would afford the project proponent the opportunity to configure the proposed residential development to avoid the fill of wetlands. PUBLIC ACCESS A major Coastal Act policy is the provision for coastal access. Section 30212 of the Coastal Act mandates that new development shall provide public access. The Commission recently approved the Bolsa Chica Local Coastal Program with provisions for extensive public access. Additionally the Bolsa Chica Wetlands Steering Committee is in the initial phase of assembling a public access plan for the Bolsa Chica wetlands in State ownership. The proposed project is similar to that of California Coastal Communities (formerly the Koll Real Estate Group) proposal in that this is a residential project which is adjacent to the Bolsa Chica wetland CCC-14 ecosystem. The Bolsa Chica Wetland Ecosystem has long been used by the public for low cost recreational opportunities such as hiking, bicycling, and bird watching. Sections 30212.5 and 30213 of the Coastal Act promote the concept of distributing low cost public recreational amenities. Additionally, the DEIR cites a policy from the City's Recreation and Community Services Element which states: "Provide for the inclusion of recreational trails in new developments which link with the existing or planned trails The DEIR does not contain a coastal access plan. Therefore, how the project would comply with the requirement for providing coastal access is not readily apparent. According to the DEIR the project site will contain an 8.2 acre neighborhood park of which 3.6 acres will be usable as an active park and of which 4.6 acres will remain as open space. Further, the DEIR notes that bicycle and interpretive trails will be located near and adjacent to the project site (Exhibit 25 of CCC-15 the DEIR). However, a public access plan describing how proposed residential development including the proposed park would be linked to the existing or proposed trails has not been included. For example, exhibits which depict the conceptual layout of the project site (such as exhibits 5 and 28) do not show any linkages (through or around the perimeter of the project site) to existing or proposed trails which would be utilized by the public to access the recreational amenities at Bolsa Chica. Further, as described in our comments on the project description the DEIR does not state whether the project site will be a gated private community. Private gated CCC-16 communities are a concern as they have an adverse impact on the publics ability to Page: 5 traverse through the community to access coastal recreational opportunities and they impede the public's ability to access coastal recreational opportunities by restricting the ability to park on the community streets. The DEIR section on parking (page 5-75) does not specifically state in the affirmative that the public would be able to use on-street parking for purposes of accessing the proposed neighborhood park or the existing and proposed trail systems. One reason for this CCC-16 public access concern is that the East Garden Grove Wintersburg Channel which is (cost.) immediately adjacent to the project site is a very active pedestrian and bicycle trail providing public access to Bolsa Chica. The final EIR should include a public access plan and should clarify whether the proposed development would be a lock-gated private community. TRAFFIC AND CIRCULATION The DEIR notes that the proposed residential development is adjacent to the residential development which is being proposed by California Coastal Communities at Bolsa Chica. The Bolsa Chica EIR contained an extensive traffic and circulation mitigation program which was embodied into a development agreement. The Parkside Estates DEIR also contains traffic and circulation mitigation measures. The CCC-17 Parkside Estates DEIR, however, does not consider how the traffic and circulation measures required by the proposed project will be coordinated with the traffic and circulation improvements required by the Bolsa Chica EIR. The final EIR should further evaluate the coordination of traffic and circulation mitigation measures between the Parkside Estate residential development and the residential development proposed by California Coastal Communities. CULTURAL RESOURCES The protection of cultural resources has been a controversial topic. Section 30244 of the Coastal Act requires that where development would adversely impact archeological and paleontological resources identified by the State Historic Preservation Officer that reasonable mitigation measures will be required. The DEIR states that CA-ORA-1308 and CA-ORA-1309 may be significantly impacted by the project but that mitigation measures will reduce the impact to a level of insignificance. Mitigation measure number two (page 5-172) which applies to a CCC-18 cultural resource management plan should be strengthened in the final EIR by: 1) requiring peer review in conformance with the Commission's archeological guidelines, 2) consultation with appropriate Native American organizations. Mitigation measure number three should also include provision for Native American review of grading operations and the handling of any archeological resources uncovered. Page: 6 Thank you for the opportunity to comment on the DEIR. Should you have any questions please give me a call. Commission staff looks forward to receiving the CCC-19 final EIR on the proposed project. Sincerely, A--`I />P�� Stephen Rynas, AICP Orange County Area Supervisor c:shea3.doc Page: 7 69 JUN 16 199 10:57AM ORANGE LAFCO P.2i2 LAFC- Local Agency Formation Commission Orange County June 13, 1998 CHAIR J.a E Mr. Jim Barnes,Project Planner COUNCILMAN City of Huntington Beach CITY OF LAGUNA HILLS Department of Community Development VICE-CHAIR 2000 Main Street CHAALHS V.SMITH Huntington Beach,CA 92648 SUPERVISOR FIRST DISTRICT SUBJECT: Draft EIR No. 97-2—Parkside Estates Subdivision SUSAN WILSON ASPRESENTATIVS OF GENERAL PVBUC Mr.Barnes, M-MR HERZOG MAYOR CITY OF LAKE FOREST Thank you for extending the review period to allow LAFCO to review and comment on the Draft EIR prepared for the above referenced project. LAFCO will be a LAFCO-1 JOI a.%VrrHERS responsible agency for this project under CEQA. DIRECTOR IRVINE RANCH WATER DI$IRICT It is to our understanding that the 4.5 acres of County territory is not curtly within WI LIAM G.STEINER the boundaries of the County Sanitation Districts of Orange County (CSDOC). sweRVISOR Annexation of the 4.5 acres to CSDOC will be required for the project to receive LAFCO-2 FO°"mD7S7RICT sewer services. The project description and the discussion of public services and ROIIERT J.NUNTLEY utilities should adequately address and discuss the required concurrent annexation to DIRECTOR CSDOC, MUNICIPAL WATER DISTRICT OF ORANGE COUNTY Age,thank you for this opportunity to comment,and please sand LAFCO a copy ALTERNATE of the Final EIR upon completion. LAFCO-3 RHONDA MCCUNE �GENERAL u OF If you have any questions,please call Kenneth Lee or me at(714)834-2556. ALTERNATE TOM HARMAN Sincerel , COUNCILMAN y CITY OF HUI TINGTON BEACH ALTERNATE BILL GOODwIN DANA M. SMITH DntECTOR LOS AL450S Executive Officer WATER DISTRICT ALTERNATE TODD srtTZXR DMS:KGL SUPERVISOR THIRD DISTRICT DANA M.SMITB MMCUTtvE OFPICPR 12 Civic Cenler Plaza,Room 235,Salta Ana,CA 92701 (714)834-2556 FAX(714)834-2643 70 R,PA RESOURCE PRESERVAT14ON ALLIANCE 5342 Kenilworth Drive Huntington Beach,CA 92649 Phone: (714) 846-9117 June 15, 1998 Mr. Jim Barnes City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 Re: Public Comments on Draft EIR No. 97-2 Dear Mr. Barnes: This letter contains written comments relative to the above referenced Draft EIR for SHEA Homes proposed Parkside Estates development on Graham Street in Huntington Beach, CA. There are several issues that require clarification, modification or further review, however, before addressing those issues there were several areas of concern that were identified in our response to the NOP that were not addressed in the Draft EIR. Following is a verbatim list of the points submitted, none of which have been addressed: RPA-1 1. We want to be sure that the cumulative effects of this development, coupled with the proposed Koll development on the Mesa (1,200+ homes) and the proposed residential development at the Meadowlark Airport site, are analyzed. 3. The NOP indicates that the city traffic engineers have already approved a third parry study of the proposed ingress and egress and traffic light proposals for the project. This is an area of grave safety concern for all of the adjoining tracts. The proposed traffic light at the entrance to the project is at a location that is RPA-2 inherently dangerous under current conditions. When the added congestion from the proposed development coupled with the cumulative effect of the other developments proposed in the area are considered we believe a much more detailed look at this proposal is required. 4. It is evident that the plan leaves open the possibility of opening the fire access proposed at Greenleaf Lane to through traffic in the future, especially when the RPA-3 residents of the proposed project demand broader access. How will this be mitigated and what will be the effects? 7. Please review what is going to be done at the junction of the existing properties on Kenilworth Drive and the proposed new houses that will be adjacent to them. Included in our concerns are fencing, grading, foliage, sightlines, privacy etc. RPA-4 With most projects proposed in Huntington Beach, the Planning Department allows for buffer zones between new development and existing properties. This is AWAMS01MCE PRESERVATION ALLIANCE an especially sensitive area relative to the subject development. Why can there not be a small, linear park along this boundary of the property, then the internal street and then homes? This would diffuse a major problem for existing residents RPA-4 while not creating the burden of securing an alleyway. (Cont) 8. What will be the impact of the proposed improvements to the regional drainage/runoff system during construction? Also we have heard wonderful reports of how the new system and pump station will improve our storm runoff. RPA-5 It is a little disconcerting to learn that the engineers no longer believe that an additional pump station will be required. We would like you to review this development thoroughly. 9. SHEA also claims that the drain/runoff system will not be funded until they start selling homes. This is very disturbing for several reasons. First, local developers are notorious for not having the money to fund such promises when the time comes (bankruptcy is the typical solution). Second even if the new system is eventually funded, what is going to happen to the surrounding neighborhoods RPA-6 between the time SHEA is allowed to complete their grading plan and when they complete the system? We believe it is imperative that this drainage/runoff system be fully funded via bonding before any grading is permitted. As this system improvement is the primary reason the city is allowing this project, we believe this course of action is in the city's best interest as well. 11. We believe that the EIR should include a detailed review of the short-term and long term revenues that the city is likely to generate from this project as well as the long-term and ongoing expenses that are likely to be incurred. These RPA-7 should include but not be limited to police, fire and paramedic services, park and public infrastructure maintenance, parks and recreation department expenses, the cost of actually developing the park if necessary, and the costs of providing public education. 12. SHEA's self described plans are to sell these houses at values significantly below the surrounding tract's levels, on a per square foot basis. This, in addition to the RPA-8 other negative impacts of the project, will likely reduce the values of those properties surrounding the project. Will you be addressing these impacts as part of the EIR. Are these outside of the scope of the review, were they inadvertently left out or were they deliberately omitted? I would like a compelling and believable answer to these questions regarding each of these points. I have thoroughly reviewed the Draft EIR No. 97-2 as have several of the members of our RPA-9 neighborhood and organization. Also, we have retained the services of a law firm that specializes in the review of environmental impact reports and litigation of environmental matters. These independent reviews have identified many areas of concern ranging from — 2 — legally salient issues relative to the EIR process itself as well as potential litigation the City may be faced with, areas we believe are deficient in scope and need to be analyzed in more detail, areas of contradiction or outright falsehoods within the body of the document, inadequacy of certain sections relative to CEQA requirements, errors that need to be RPA-9 corrected and a clear definition of what constitutes a "LESS TIMN SIGNIFICANT (Cont.) IMPACT'. Following is an outline of the actions we believe need to be taken in order to have the subject EIR No. meet the adequacy parameters as required under state law. L NOTIFICA77ONREOUIREMENTS Current City of Huntington Beach regulations require that residences within 300 feet of a site be notified, by mail, about applications for zoning changes, conditional use permits, requests for variances, tentative tract map applications etc. CEQA also has similar notification requirements. An informal survey of those properties within 300 feet of the exterior RPA-10 boundary of the subject parcel indicate that only a fraction of these residences received notification of the EIR and that none received notification of the various applications for zoning changes, permits, tract maps, etc. Exactly who was notified of what and when this occurred should be reflected in the EIR. IL APPEARANCE OF CONFLICT OF INTEREST Three of the firms that supplied key technical support, analysis and recommendations for this EIR have worked for SHEA Homes, on this project, prior to an EIR being requested. When SHEA purchased the property in late 1996 they had these firms conduct studies, research and analysis in an effort to receive Negative Declaration status for the project. Subsequent to this the City made the decision to require an Environmental Impact Report for RPA-11 this application. Bids went out and the contract was awarded to those firms who had already had been working on the project. While this certainly would have been the most cost effective bid to take (as much of the primary research would have been completed) it seems that it would be difficult to get an unbiased result under these circumstances. Using the data generated is one thing but to have these firms providing key analysis and recommendations, at least has the appearance of a conflict of interest. III. DOCUMENT APPEARS TO BE BIASED FOR PROJECT Our legal counsel had the following observation after reading through the EIR: "Page 8-3 - No unavoidable adverse impacts. Well that's just great! Absolutely no adverse impacts at all! We all ought to welcome this RPA-12 with open arms because it's also very good. Whenever they make this statement in an EIR.it shows to anyone familiar with them that this is all B.S.. They are always some unavoidable impacts that can't be mitigated but they deny that even exists." — 3 — RESOURCE PRESERVATION ALLIANCE As will be shown later in this letter there are many adverse impacts that have not been mitigated to a "less than significant level". In fact in the body of the document itself there RPA-12 should be a definition of exactly what "less than significant" means. If this is simply the (Cont.) opinion of the preparer and not a definitive concept with measurable parameters, then this document has little value. The report contains no credible alternatives, implies that all impacts of this project can be mitigated, assumes that major engineering efforts can be completed successfully, at a an economically feasible cost, but does not review them at any technical level. Also the analysis of cumulative effects, when it is actually done (only in the traffic section) considers on the RPA-13 Holly Seacliff development which is some 5 miles from the proposed site. The Catellus project and the proposed Koll development at Bolsa Chica are not reviewed at all. Because any potential negatives are either not considered or are completely ignored the document is, by definition, biased. IV.PROJECT ALTERNA77VES ARE INADEQUATE The only project alternatives that are considered are a larger development (Development Under Existing Zoning), the possibility of developing a 9-hole golf course and the potential repositioning of the park and secondary access road. The latter three are dismissed as RPA-14 impossible to accomplish for reasons that are very shallow, at best. Who says that a 9 hole golf course requires 80 acres? How many acres is Meadow Lark? It's an 18 hole course. What about building homes of the size SHEA is currently proposing plus a 9 hole golf course? Is that feasible? Sure gives a place for the water to go if it floods! As to the suggestion that a secondary access to Bolsa Chica Road is impossible because the cars would be going 45 MPH is absurd. Simply put up a stop light and post a 15 - 25 MPH speed limit. The alternative to develop the site under the existing zoning is deliberately misleading. Existing zoning ordinance specifically states that the minimum lot size is to be 6,000 square feet with a 60 foot frontage. The City's Land Use Element (LUE) separately requires lots that are no smaller than 6,222 square feet per dwelling unit. If these requirements are considered, the 113 lots that are substandard (approximately 5,000 square feet) should actually be approximately 96 lots of 6,000 square feet each. The alternative presented in the RPA-15 EIR uses the 7 units per net acre aspect of the zoning ordinance to come up with the 367 units. This assumes that some 52.43 acres are available for residential development; this is false because 3.6 acres are required to be devoted to a public park and an additional 4.6 acres are unusable as they are at steep grade and are zoned open space. As the site is in reality only 48.5 acres of which only 40.3 are applicable to the zoning and LUE requirements, even if a 7 units per gross acre density is used the maximum number of units would be 282, not the 367 indicated. This alone makes this EIR both inadequate and less than credible. This is a deliberate misrepresentation of the facts. — 4 — VIESOURCE PRESERVATION ALLIANCE Why is a potential alternative of actually developing the site with all lots having a minimum size of 6,000 square feet and a minimum frontage of 60 feet not considered? Afterall this is RPA-16 what is actually required under the existing zoning. Also why was the alternative of creating a buffer area between the existing Kenilworth homes and the subject project as suggested in point#7 in our response to the NOP(see above and RPA-17 in the EIR in Technical Appendix- Volume I) not considered as a possible alternative? Another alternative that should be considered is to have the developer gain the necessary entitlements and then either sell to or trade the property with federal , state or county I RPA-18 agencies. { The document would have us believe that the only possible alternative is to have the developer construct 370 homes on the site. This all gets back to the issue of the study being biased. At every potential negative area the facts are either ignored or the statistics are RPA-19 manipulated to make it appear that this project has no impact or is in some way beneficial to the community because it is better than the alternative. CEQA requires the discussion of alternatives to " foster informed decision making and informed public participation" (see Section 15126 (d) (4)). This document does neither. V.DRAINAGEIHYDROLOGYREVIEW IS INADEOUATE Following are some of the observations of our legal counsel relative to the Hydrology sections of the EIR: "Our research indicates that there has been flooding in the area but RPA-20 the report in December 1992 indicated that the overtopping occurred up near the 405 Freeway and really brought into question whether the capacity was appropriate around the 405 Freeway. The possibility being that the channel under the freeway was under capacity. Didn't see any specific indication of flooding in this area. If an area that has not flooded before or was not subject to the flooding before, then the public entity allows a development in the face of knowledge that flooding may now occur the public entity is strictly liable for losses from the flood. Remember that if this RPA-21 happens and the strict liability is imposed, we're talking about punitive damages plus attorneys fees to the plaintiff by the City. This kind of comment to the City should at least cause them to look into the flood control aspects a little better than they have. Page 3-31 - They want to expand the capacity of the Wintersberg Channel because of drainage deficiencies. (On this site? What do RPA-22 they plan to do? Will this housing be subject to flooding in heavy — 5 — RJES101"URCE PRESERVATION ALLIANCE rains? City is going to be strictly liable if that occurs! Also, liable for RPA-22 attorneys fees for the homeowner.) I (Cont) Study the likelihood of flooding of area homes and the liability to the City for allowing this development without some massive and RPA-23 effective flood control measures for this site. The site is low and it looks like a retention basin as it sits there today. Have developer explain what they propose to actually do — page 3-31 - expand capacity of channel - how are they going to do that? Do RPA-24 they have County of Orange approvals? Remember if it's a drain then it doesn't work because the channel is already full when it gets to this property. Page 5-138 - Overtopping on the south of the channel can occur. I RPA-25 That's where the houses on Glenstone are. Orange County said that this channel was not a 100 year storm drain channel. The text from about page 5-136 through 5-138 seems to RPA-26 infer that it's a 100 year channel. It's therefore misleading. There is not likely to be any improvement in the channel. The County of Orange has been trying to improve it for 20 plus years and it can't. It doesn't do any good to improve the channel in this area RPA-27 and to the east. You have to improve it to the west and that's not being allowed. The Bolsa Chica people do not want more water introduced into this area and they have fought any changes to improve the channel. Exhibit 42 - Lined pump station goes under the channel. That's a I RPA-28 real engineering feat! You hit water in this site at 6 feet, how are you going to build this thing? This new storm drain system is going to drain directly to the Slater Pump Channel. That pump channel is already over capacity in a serious storm. So your pump won't help you to dispose of more of it. What is it they can do? Well what they will do is they'll put in their RPA-29 storm drains and if it can make it to the Slater Pump Station it will then get pumped by the Slater Pump Station into the channel and after that occurs because the channel is already overtopping it will just overtop that additional water you put in which will still come back and flood you. What kind of solution is that? I can't say for certain but it appears that if houses and streets already (RPA-30 have some flooding problems, then this tract puts in a system and — 6 — A&M,op"URCE PRESERVATION ALLIANCE that in turn either puts additional pressure on the surrounding homes on either the south or north of the project or if this side is lower than Graham and Warner then the water will run right down into the tract RPA-30 and when the drain becomes full they are going to flood in the lowest (Cont.) spot. If this is the lowest spot in any drainage area, this is where the water is going to settle. As adjacent homeowners you want to make real sure that drainage from your property is not interfered with. In other words, you want RPA-31 to be higher than this new site. You better not be lower and don't let these walls they want to build around their project block the natural water course of water from your property." As the above dissertation indicates, the hydrology section of the EIR is inadequate in several areas. First, there is no discussion of the fact that the site, in its current state, is a retention basin for a vast amount of rainfall and runoff from other areas. It actually functions in much RPA-32 the same way as the Meadowlark Golf Course is described to in the EIR. This factor is not mentioned and it is not considered in the modeling for potential increases in waterflow as a result of the proposed project; at least not in a manner that is identifiable. The next area of concern is in the many references to the Wintersburg Channel having base flood (100 year) capability. We have obtained documents that indicate that the Wintersburg Cannel currently has only a 10 -15 year flood capability. This has been corroborated by officials of the Orange County Flood Management District. The Wintersburg Channel was RPA-33 originally planned to be capable of handling a 25 year flood; however, it was to be done in two phases. The first phase was the earthen channel that now exists. The second phase was to be a concrete lining of that channel, but the bond issue to pay for the Phase lI work was defeated and the improvements were never completed. Therefore this channel currently only has the capability of handling a 10 - 15 year flood event. Added to this is the fact that the Wintersburg Channel, at Graham Street, as reported by county officials, is at capacity during heavy rainfall and a high tide. They further report that this capacity can only be increased through major improvements to the west of the subject site. They have been trying to do this for years but have been unsuccessful. The letter from RPA-34 the County of Orange, Planning and Development Services Department presented in Technical Appendix Vol I in Appendix A-2 states that "the existing channel does not have the capability to accept additional flows from the developers Slater Pump Station improvements. For these reasons the developer should be required to improve the EGGWC to being capable of conveying the approved 100-year discharges". Further this letter states that "Storm water drainage and flood control issues are important for this project because of the Federal and State Bolsa Chica restoration project which proposes to introduce ocean tidal water around the EGGWC levee and into the area labeled RPA-35 "N.A.P." at the southwest comer of the 5-acre parcel (see attached Amendment 2B). The — 7 — RESOURCE PRESERVATION ALLIANCE practical implication of this could be that the OCFCD's levee will not offer flood protection RPA-35 against coastal tidal flooding". There is no mention of nor any reference to this anywhere in Cont.) the EIR. For this reason alone this document is seriously deficient. The EIR recommends Wintersburg Channel improvements at the site location but nothing "downstream"; this will not result in any increases in the channel's capacity. Therefore, in a typical year storm event, the proposed drainage system plan will increase the flow into the already over capacity Wintersburg Channel (at the Slater Pump Station) by an additional RPA-36 126.2 cfs. Because the Wintersburg Channel would be at full capacity at this time the additional 126.2 cfs of water would overtop the Channel at this point flooding surrounding areas. This does not seem to be a sound plan for improving deficiency's in the area, nor does it seem to be a "less than significant impact". However, the EIR states (on page 5-140) that 'Me above improvements have been required as mitigation for the proposed project. Implementation of these improvements will mitigate RPA-37 proposed drainage impacts to a less than significant level. The data presented in the report itself indicates a far different conclusion, unless increased flooding in the area is considered to be a "less than sipni icant impact': The cumulative effects section indicates no reference to the Catellus project that will RPA-38 certainly impact drainage and storm flow in this area. Why is that? Mitigation Measure 1 on page 5-142 states that : "Prior to the issuance of building permits, the project applicant shall implement conditions of the Public Works Department regarding storm drain improvements which will include but not be limited to: RPA-39 Construct the necessary storm drainage improvements (identified on Exhibit 42 within the EIR) to handle increased flow and intercept off-site flows. Construct the necessary improvements to the EGGWC (CO5) along the site perimeter. Careful review of the document and Exhibit 42 show that the only analysis of changing/improving the storm drain system in the area consists of a recommendation to: connect these lines to a 120 inch stone drain line on-site which will connect to the Slater Pump Station via a RC box under the COS. — 8 — RESOURCE PRESERVATION ALLIANCE This is supported solely by an Exhibit that shows the proposed system in colored highlighter markers. There is no technical analysis as to whether this is possible, feasible, viable or environmentally sound. Further, because the EGGWC is a permeable earthen levee and is RPA-3f subject to tidal influence at this point, and because the watertable (due to the unlimited aquifer (Cont.) of the Pacific Ocean) is at about 6 feet at this location, the recommended RC box will be immersed in seawater. While I'm sure that this can be engineered, the cost of this should be considered before any permits are approved. This improvement to the storm drain system is the primary reason that the city is so focused on having this project go forward. It seems to us that this EIR must contain a detailed technical analysis of how this plan will work, how it is to be implemented, an engineering certification that it will be capable of doing what is proposed and an estimation of the probable cost. All there is now is a drawing in magic marker. VI.REVIEW OF THE IMPACT OF DEWATERING IS NONEXISTENT The EIR briefly touches on the need for dewatering prior to remedial grading. This is the single most glaring deficiency in the EIR document. The EIR states, on page 3-21: "The remedial grading component of the project will require dewatering. The dewatering activities are estimated to occur over a four to six month period. Approximately 30 to 40 , submersible pumps could be utilized in this effort in RPA-4C conjunction with gravel drains and surface pumps that will be placed within the excavation bottom. Dewatering techniques adjacent to existing improvements will be limited to gravel drains and surface pumps only in order to limit drawdown below off-site improvements. These procedures will be monitored to have no significant settlement impact on these facilities. The exact location of the pumps placement is currently unknown; however, they will most likely be placed on-site adjacent to the EGGWC because groundwater levels are typically higher at this location." The only other remotely technical reference to dewatering occurs on page 5-128 where it is stated that: "According to PSE no subsidence impacts to adjacent properties from the proposed dewatering are anticipated. Implementation of Mitigation Measure 4 will ensure that the proposed local dewatering does not result in subsidence of adjacent properties along the projects northern property boundary." — 9 — Mitigation Measure 4 reads: "Prior to the issuance of grading permits, the applicant shall contract with a dewatering expert to prepare a detailed Dewatering Plan. This plan shall include the placement of monitoring wells along the northern property line to evaluate groundwater levels during the proposed project dewatering RPA-40 activities. The dewatering activities shall be adjusted (Cont.) immediately if the monitoring wells show groundwater level changes which may effect subsidence of adjacent properties. The Dewatering Plan shall be reviewed and approved by the department of Public Works." These are the only references to dewatering in the entire document with the exception of a discussion of the noise that will be created by the pumps. An engineering effort that requires 40 wells to be dug to a depth of 20 feet into which submersible pumps will be inserted and run continuously for a period of 4 to 6 months would seem to require a depth of analysis th'est= is more comprehensive than three paragraphs that include the words "limit and anticipated': The wording suggests that, even without an analysis of the underground aquifers, the EIR consultants EXPECT there to be a problem with possible subsidence of the existing adjacent properties. We have a real concern that the monitoring wells may fail, may not be monitored 24 hours a day and that whatever parameters that they use as a crisis point may be RPA-41 flawed. It also seems incredible that a property that has goundwater levels at between 4 - 6 feet (page 5-123) and requires continuous pumping of groundwater for 6 months to put it in a position to be graded is a good place to allow residential construction. Also it seems incredible that the biological consultants could, given these facts, state that there are no RPA-42 wetlands of any kind here because there is no water and no possibility of water getting to the site. There is also no analysis of the actual underground aquifer. The consultants do not know if I RPA-43 the groundwater continues from the subject site under the existing properties at the northern boundary. The other major problem we see is that it is likely that they are dealing with an unlimited aquifer (the Pacific Ocean). It is documented that the area to the southwest of the project is subject to tidal influence, it was clear from the test pits that were dug adjacent to RPA-44 the EGGWC that the groundwater there was 1) saltwater and 2) subject to the tides and finally the EGGWC is earthen and not lined. It seems obvious that a large portion of the underground aquifer is indeed not a closed system and therefore would be unaffected by dewatering. Finally there is no mention of where the water will go once it is removed. We can only assume that the applicant will put it into the EGGWC. Is this the case and if so has the County approved this and will the water quality be monitored? At the very least, the RPA-45 Dewatering Plan recommended in Mitigation Measure 4 should be required as part of this EIR document. — 10 — RESOURCE PRESERVATION ALLIANCE V11 REVIEW OF THE IMPACT OF OFF-SITE FILL IS NONEXISTENT Our legal counsel had the following comments relative to the remedial grading and infill program: "3-21 to 3-23 - Make sure they have approval for all soils to be RPA-46 imported from adjacent parcel so there is no use of public roads. Note that if the developer doesn't agree or guarantee he'll be getting this fill dirt he has to bring in from Bolsa Chica.. If they don't then the report needs to address all the dirt, dust and degradation to the local roads by the use of thousands of dump trucks for several months. Also, what about traffic congestion because of all the goings and comings of these trucks. Require a written agreement from the adjacent property owner to allow all dirt to come from his site. Otherwise, you will have your roads destroyed with all these dump trucks on your local streets. That is not an efficient or effective use of tax funds because the roads will have to be repaired by local taxpayers. The reason I think you should require this is it appear that the adjacent landowners might be within the ecological area and that Alk is all subject to a lawsuit at this time and it seems hard for me to believe that they are going to allow you to start removing areas from this ecological area or at least claimed ecological area with lawsuits pending. 3-21 - Have them tell you how many dump truck loads it takes to import 210,000 cubic yards of dirt. I submit it's probably 10,000 to 20,000 dump truck loads. When you are dealing with dump trucks, the more they carry, the more damage they do. Remember the weight of these trucks can do substantial damage to streets that are only used to handling a very small percentage of trucks and it RPA-47 suddenly jumps. The road bed is weakened and beat up and almost anybody can tell you that that's occurred to them if they've ever lived at or near a place that went from being residential to one where there was heavy construction traffic. People in that situation notice that a roadway is cracked and broken within 30 days of the time the construction project starts. Because the developer may have problems accessing the fill from the adjacent borrow site the above referenced off-site fill may be required. As our counsel states the impact to the road RPA-48 bed, traffic flow and air and noise quality will certainly be significant if this contingency becomes necessary. — 11 — SOUR ,E P tat V A i ION ALLIANCE While this contingency is briefly touched on in the EIR, with regard to the city approving a route and the hours of operation, there is no analysis of the potential road bed damage and RPA-48 who would pay for it, or an analysis of the volume of loads and therefore trucks that would be (Cont.) required. These issues must be addressed in detail in the revised EIR. VIII. LAND USE COMPATIBILITYREVIEW IS INADEQUATE On page 5-2 there is a reference to a survey conducted by Hunsaker and Associates that is supposed to analyze the density of land uses surrounding the project site. The results of this survey are presented in Table C on page 5-5. The methodology of this analysis and the conclusions are flawed and misleading. With the exception of areas 5 and 6 which predominantly have condos the rest of the study area is zoned for low density residential. The analysis looks at areas 1, 2 and 4 which have only homes and no park site and area 3 RPA-49 which has a park site that is excluded from the boundary and subsequent acreage calculation. Therefore, for the purposes of this analysis, all four areas have only residential lots included in the acreage calculation. When they analyze the subject site; however, they include the 8.2 acre park site. This totally skews the data and compares non-like properties as if they were the same. Based on this analysis, it is the conclusion of consultant that the subject SHEA development has only 4.17 dwelling units per acre or about 10 percent less than the surrounding T neighborhoods and will therefore have no impact. If the five sites are all analyzed on the same basis (the park acres are backed out of the project site acreage); however, it is evident RPA-50 that there are 4.99 dwelling units per acre or 8 percent more than the surrounding area. This is deliberately misleading and is another example of the bias for the applicant that is consistent throughout this document. Table C and the related text should be changed in the EIR to reflect the reality of the situation. There is no indication in the EIR about the sizes of the homes in the six surrounding areas. While we have not compiled the exact information yet, the largest house size in Area 1 is about 2,600 square feet. The proposed development will have houses that range from 2,500 RPA-51 to 3,300 square feet. This also is not in the least bit compatible with the homes in Area 1 or we believe any of the other three areas identified. Also the proposed lot sizes are either about 5,000 square feet or 7,000 square feet, again significantly different than the existing 6,000 square foot lots ( as per city codes). The combination of these factors suggests that if the homes command a price/square foot at the same level as those in the surrounding areas they will be priced about 25 percent higher than the surrounding homes, again not a compatible use. If the homes are price similar to those in the surrounding areas then the houses in the surrounding areas will decrease in value by about 25 percent. RPA-52 There must also be an analysis of the effect that the proposed development will have on the value of the homes in the surrounding areas before a determination of whether or not the proposed homes will be compatible can be made. — 12 — RESOURCE PRESERVATION ALLIANCE The comment on page 5-36 that states: "The establishment of new residential land use relationships with adjacent land uses will not result in significant impacts." is totally without merit. The fact that the developer proposes to remove and replace the back walls of these existing properties, will replace open space with a two story structure above the grade of the existing properties and will develop homes that are either significantly higher in price or are RPA-53 significantly lower in cost on a$/square foot basis than the existing properties is a significant impact to those property owners. The value of these homes will be reduced as will the quality of life of those residents. To say that this is not a significant impact is insulting and patently false. Ix TRAFFIC IMPACTSARENOTADEOUATELYMI77GATED The analysis of the traffic implications of the project are inadequate and the mitigation measures do not fully solve the traffic problems. First there is no analysis of the impact that the increased traffic flow on Graham Street will have on those people exiting from Kenilworth Dr., Pendleton, Glenstone or Gershwin onto Graham. It is currently very busy at these intersections in the morning and evening peak times. The traffic study indicates that the proposed SHEA project will generate an additional 2,496 daily vehicular trips (see page 5- 68) and that about 10 percent of these trips will be generated in the peak hour. The study RPA-54' further indicates that "The proposed project will not result in project-specific impacts related to vehicular traffic increases at the modeled intersections and roadway segments under the existing plus project condition" (see page 5-84). Exhibit 30 and Table G indicate that the existing ADT count on Graham Street at the site location is 7,200. The addition of some 2,500 cars per day to this already congested street is an increase in flow of nearly 30 percent. This is significant under any possible definition of the term and will result in project- specific impacts. The plan/suggestion to put a traffic light at this location is also not well thought out. The way "A" Street is designed it will be at a fairly steep grade at the intersection with Graham and there is only about 150 feet to the `B'TV' Street junction. With an anticipated 200 cars per hour (a car passing every 20 seconds) at the peak morning hour, there will likely be 20 - 30 cars stacked at this signal at one time. Also the peak evening traffic volume of 250 RPA-55 cars means that there will likely be 25 - 30 cars stacked at the southbound light at one time. None of these potential impacts are considered in the traffic study. These impacts are not considered in the traffic study, nor are the sight line problems associated with the hill rising over the EGGWC addressed sufficiently. They need to be reviewed in more detail. Finally, the cumulative impacts section only considers the increase in traffic from the Holly Seacliff development 5 miles to the south of the project site. That development will obviously have little effect on the traffic flows at the subject site. Potential traffic flows from the Catellus and Bolsa Chica properties are likely to have a significant effect on nearby RPA-56 traffic flows. Neither of these is assessed in the cumulative effects section_ WHY? The cumulative effect of the potential traffic from these to nearby proposed developments must be included in this analysis. — 13 — RESOU1101'CE PRESERVATION ALLIANCE x CUMULATIVE IMPACTS ARE NOT ADDRESSED SUFFICIENTLY The only section of the report that considers actual cumulative effects of"the proposed project with other past, present and reasonably foreseeable future projects" is the traffic study's reference to the Holly Seacliff development and as discussed above even that discussion is inadequate. In every other section of the study the following canned phrase is RPA-57 presented as the complete, cumulative effects analysis: The proposed project, in conjunction with other past, present and reasonably foreseeable future projects, will result in impacts that will be reduced to a less than significant level. But there is no mention of what those other cumulative impacts are. Each section of this report requires an analysis of how the proposed Catellus project and the proposed Bolsa Chi Mesa project will effect the various aspects of the subject project and specifically what will be done to mitigate these impacts. M. CONSTRUC77ON NOISE LEVELSARE STATED TO BE SIGNIFICANTL Y GREATER THAN EVEN THE CITY'S LIMITS While the long term noise associated with the project appears to be within the parameters allowed by the various jurisdictions the short term noise levels associated with the project are not. The EIR states "65 dbl is commonly considered maximum the outdoor noise level." It further states that the State of California and City of Huntington Beach both specify 65 CNEL as the maximum outdoor noise levels acceptable in an area. Then, in the short term RPA-58 noise section on pages 5-107/5-108 go on to state that during the construction phase of the project noise levels of 75 - 88 dbl will be common at a distance of 50 feet. This will come from dewatering pumps (65 dbl with a 10 dbl penalty for nighttime use), bulldozers, heavy trucks, backhoes and pneumatic tools. This is not considered, by the consultant, to be very significant because they will primarily be operating from 7:00 am to 5:00 pm. This project is different from any other development in the City of Huntington Beach because it is being developed adjacent to existing properties that have been occupied for some 30 years. If you look at the remedial grading recommendations, the overall plan, the recommendation to remove the existing property's walls and to dig up the existing storm drain it is evident that much of this activity will not be 50 feet away but 0 - 1 foot away from these homes. another factor that is overlooked is that the majority of those existing properties are homes to retired couples or families with wife and children home all day. The fact that this activity will only occur from 7:00 am to 5:00 pm is not very beneficial to those people who are trying to use their backyards during the day. — 14 — RESOURCE PRESEUVATION ALLIANCE According to the consultants recommendations/conclusions this project will result in, short- term noise levels that are over 30 percent higher than those mandated by the State of California and the City of Huntington Beach. This is considered to be a less than significant RPA-59 impact as long as the trucks have good mufflers and they are parked (not running) as far away from the existing properties as possible. We believe that the recommended mitigation measures are wholly inadequate. We further believe that the developer should be required to construct a 30 foot soundproof wall adjacent to the existing properties for as long as is necessary to mitigate the noise of construction. As a side note we find it interesting that an admitted construction period of 4 - 5 years (6 months for dewatering, 6 months for remedial grading and 3 - 4 years for construction) is considered to be short - term. This is about the average amount of time new buyers spend in RPA-60 a property before reselling. We believe that you should either rethink your definition of short-term in the document or at least more clearly describe it as what it actually is (5 years). AR REMEDIAL GRADING WILL HA VE SIGNIFICANT IMPACTS A project that has the requirements to conduct a massive dewatering program (6 months of continuous pumping of groundwater), prior to excavation of depths up to 20 feet (6 months) in order to recompact the soils to bring them to a point that the site can actually be RPA-61 developed safely, does not seem like the highest and best use for this site. Further to subject "= those residents in properties adjacent to this site to this type of activity for a period of over one year is certainly not a less than significant impact. Finally there is no technical discussion anywhere in the EIR of the actual grading plan for the site. It is understood by many that the infill plan is to increase the grade substantially at the EGGWC and slope it towards the existing properties at the northern boundary. The study makes grand pronouncements that the grade elevations will only change by about 2- 3 feet, on average. This could mean that the elevations will rise by as much as 9 feet at the southerr most boundary sloping to 0 feet at the northernmost. Taken collectively this would, in fact, result in an average change of only 3 feet; however, it would also result in a 2% grade towards the existing neighborhood While this may not seem like much, in the event that the proposed storm drain system fails, does not work or is not implemented, the existing properties on Kenilworth Drive (and at he northernmost boundary of the subject development) will surely be flooded as the 126.2 cfs of runoff coupled with the runoff that would have been retained if the project had not been built seeks the lowest point. Again we consider this to be a more than significant impact. This EIR must detail the proposed gcadin plan and analyze the potential impacts thereof.- - 15 — RESOURCE PRESERVATION ALLIANCE MR NO REVIEW OF FISCAL IMPACTS OF THE PROJECT There is no review of the fiscal impacts of the project on the City if Huntington Beach. It is clear that residential development only generates about one tenth of one percent of assessed value to the city jurisdiction on an annual basis. The proposed project will create an assessed RPA-62 value of approximately $80,000,000 in assessed value with resultant annual property tax to the City of Huntington Beach of about $80,000 annually.' This will not come close to paying for the added public services associated with the project. This type of analysis should be included as part of the EIR. XIV. FIREAND PARAMEDICRESPONSE TIMESARENOTADEOUATE The EIR concludes that because the fire station at Hiel Street will be relocated that fire response times to the site and therefore to all of the surrounding tracts does not currently meet the minimum criteria established by the city. It then states that Mitigation Measure 1 will reduce this to a less than significant level. Closer review of Mitigation Measure 1 reveals that: "Prior to approval of building permits, building plans shall be RPA-63 submitted to and approved by the Fire Department. If during the Fire Department's plan check it becomes evident that fireground operations will become impeded, the department will impose standard fire code requirements such as automatic sprinkler systems, alarm systems, access roads, etc." First of all what is meant by access roads? This entire process has proceeded with the understanding that the Greenleaf emergency access will never be turned into a permanent road and that all of the Alternatives at the west end of the project are totally infeasible. Where then do you recommend that the Fire Department require an additional access road. This is a major departure from the plan that is cavelierly suggested in a one sentence reference. You must clarify exactly where this will be and what the impacts will be. A second problem is that if the subject property won't have adequate response time it is evident that the surrounding properties will not either. The recommended alarms and sprinklers may appease the SHEA developments buyers relative to inadequate fire response RPA-64 times but they will do nothing for the existing property owners. The fire response issue requires a much more critical analysis, especially in view of the fact the potential cumulative effects of the proposed Catellus and Bolsa Chica Mesa projects are completely ignored — 16 — RESOURCE PRESERVATION ALLIANCE MV.SCHOOL FACIU77ESARENOTADEQUATE The EIR concludes that the proposed project will create the need for two additional elementary school classrooms, two additional middle school classrooms and one additional high school classroom. It goes on to state that Hope View School and Marine View School are currently over capacity and generally built out. The local high schools are also reported to be "fully occupied". Specifically it states, on page 5-180: RPA-65 "The development of 208 new residential units would generate additional students. Overall, schools are built out and could not accommodate additional students. Other costs include the need for increased staff(certified and classified), classroom supplies, textbooks, transportation, and technology equipment." The conclusion drawn from this is that Mitigation Measure 1, the state mandated school fee schedule for developers (which is required) will mitigate this to a level that is less than significant. The state fee schedule requires payment to the school districts. This does not reduce the burden on the schools to a less than significant level. Even if there were space available at the schools in question to add the new classrooms (there is not), five new classrooms of say 600 square feet each at a construction cost of$75/sq. ft. would require $225,000 for build out alone. Land acquisition, the costs of furnishing and supplying them and hiring teachers will easily triple this. But the land is not available at the existing facilities, therefore, by definition new schools will have to be built. This analysis of the school system requirement, like everything else in this EIR, does not consider the cumulative impacts of the Catellus project or the Bolsa Chica Mesa project. As a result we believe that the implementation of Mitigation Measure 1 is not a mitigation measure but a state requirement and that the fees raised by this will in no way alleviate the RPA 66 burden that this project will put on the local school systems to a less than significant level. Further we believe that the developer should be made to participate on a prorata basis in the acquisition and construction of the new schools that this and the other proposed developments in the area will necessitate. XV WETLANDSREVIEWISINADEOUATE Because this sensitive issue will be the subject of many other responses which will be more comprehensive that ours, and because a determination is supposed to be made on the disposition of the issue within the next few weeks, we will simply assess the general factors in this area. As you will know the part of the property in question, was delineated as wetland by the EPA and Army Corps of Engineers as recently as 1992. The determination to change RPA-67 the designation to "prior converted cropland" is subject to review and revision because the farming use had stopped for a period of five years or more. It is obvious that, left alone certain areas of the site return to a wetlands state as evidenced by an independent analysis prepared for us by a certified biologist with expertise in this area. The determination by the — 17 — RESOURCE PRESERVATION ALLIANCE consultants "ecologist" was based primarily on review of past studies and a determination that the conclusions in those documents were flawed. This does not seem to be a very complete or compelling analysis of this sensitive issue. The analysis of the ecologist also loses credibility when comments she made at a recent city council meeting conflict with data presented in the EIR document in the hydrology section are considered. Finally, while the California Fish and Game Department originally wrote a letter agreeing RPA-67 with the consultants position (without looking into it themselves), when presented with (Cont.) detailed evidence that conditions indicating a wetland were indeed present,they agreed to review the site in order to make a final decision. They and the city council asked that the applicant not degrade the site until CFGD could make an on-site inspection. The next day the applicant disked and graded the site, removing all evidence of wetlands. We believe that the site must be left fallow for a period of one year after the current crop is harvested so that a proper determination can be made. The applicant knew full well that there was a wetlands issue relative to this site when they purchased the property. This issue needs to be more comprehensively reviewed in the final document. — 18 — RESOURCE PRESERVATION ALLIANCE This letter is intended as a resource for identifying areas in the EIR that are in error, inadequate or need further review. It is also intended as a public representation of these problems and a vehicle for bring them to your attention. I suggest that you read this closely and act accordingly because if these areas of deficiency are not addressed adequately and future problems arise as a result, this document will serve as evidence that you were forewarned and deliberately and voluntarily chose to ignore it. Sincerely, Resource Preservation Iliance RPA-68 Douglas Stewart cc: Huntington Beach City Council (all members) Huntington Beach Planning Commission (all members) California Coastal Commission CEQA State Clearing House Barry Allen, Esq. — 19 — 71 rt r �U �n a�UTHERN CALIFORNIA C June 15, 1998 v ASSOCIATION Of Mr. Jim Barnes, Project Planner GOVERNMENTS City of Huntington Beach Department of Community Development 2000 Main Street Huntington Beach, CA 92648 Main Office RE: SCAG Clearinghouse 19800289 818 West Seventh street Parkside Estates Subdivision Lzth Floor Los Angeles,California Dear Mr. Barnes: 90017-3435 We have reviewed the above referenced document and determined that it is not regionally significant per Areawide Clearinghouse t(213)236-1800 criteria. Therefore,the project does not warrant clearinghouse f(213)236-1825 comments at this time. Should there be a change in the scope of the project,we would appreciate the opportunity to review and comment www.scag.ca.gov at that time. Offices:•Prestdent:Mayor.Bob Bartlett.City of SCAG b-1 Monmvia•Firs,vice President Supervisor Yvonne A description of the project will be published in the June 15, 1998 Brathwarm Burke.Los Angeles County•Second Vice waits Burk',k',LoslmemberRon Bates.SCity of econd Intergovernmental Review Report for public review and comment. Los Aiamuos • Immediate Past President Supervisor Judy Mikels.Ventura County, -=d l3flion.EJ C TomVessey Imperial G°°city The project title and SCAG Clearinghouse number should be used in •David Dhillon.F1 Centro Co-ryofLosAngel-Yvonne Braithwaite Burke, all correspondence with SCAG concerning this project. Los Angeles County os hardAngeles les-Alarcon.Los Angeles Correspondence should be sent to the attention of the •Richard Aluortt.Los Angeles•Eileen Ansart. Diamond Bar• Bob Bartlett.! •Bruce Barrows.Cerritos•George Bass..Bell Clearinghouse Coordinator. If you have any questions, please Bell-Sue Bauer. Glendora-Hal Benison.Los Angeles•Robert contact me at (213) 236-1917 or Bill Boyd at(213) 236-1960. Bruesch.Rosemead•Laura Chick,Ws Angeles -Gene Daniels.Paramount•Doug Drummond, Long Beach•John Fernm,Los Angeles•Michael Feuer,Los Angeles•Jane Friedkin.Fl Segundo• Sincerely, Ruth Galanten Los Angeles • Eileen Givens, Glendale•Jackie Goldberg,Los Angeles•Garland Hardeman, Inglewood Mike Hernandez. Los \ .Angeles • Nate Holden, Los Angeles • Keith McCarthy.Downey•Barbara Meninx.Alhambra• _— Cindy Misakowski.Los Angeles•David Myers, Palmdale •Santa Nakano.Torrance • Pam �anager, DAVID STEIN O'Connor.Santa Monica•Jenny Oropeu,Long Beach•BLosAn eles Pico Rivera.Mark Ridley. Performance Assessment 7homu Los Mgeles•Diann Riag.Claremont• Richard Riordan,Los Angeles• Marcme Shaw. and Implementation Compton-Rudy Svormich.Los Angeles•Joel Wachs,Los Angeles•Rita Wait—Los Angeles Dennis Washburn, Calabasas • Paul Zee,South Pasadena J DS:Ij County of Orange: William Steiner. Orange County•Steve Apodaca.San Clemente•Ron Batts, Los Alamims•Art Brown.But Park•Jan Debay, Newport Beach•Richard Dixon,Lake Forest Charlene Hatakeyama.La Palma•Bev Perry Brea County of Riverside: James Venable. Riverside Cop, ;;,fin Leja,Beaumont•Dick Kelly,Palm Loveridge,Rwersid<-'An Puga. C '!h Roberis.Temecula 'ping of San Bernardino: Larry Walker. San Bernardino County • Bill Alexander, Rancho Cucamonga • Jim Bagley,Twentymne Palms - David Eshleman.Fontana•Lee Ann Garcia.Grand Terrace•Gwen Norton-Perry.Chino Hills-John Sarbuck.Highland Cory of Ventura:Judy Mikels.Ventura County Andrew Fox.Thousand Oaks • John Melton. Santa Paola•Tom Young.Pon Hueneme ® Printed on Recycled riper +/I S/98 72 �Pt�p•µS OF Th_ IlSB 6 IMMLOM United States Department of the Interior FISH AND WILDLIFE SERVICE g e *•�pck a�e►0 Ecological Services �' Carlsbad Field Office 2730 Loker Avenue West Carlsbad,California 92008 JUN 15 1998 Mr.James Barnes,Project Planner Department of Community Development City of Huntington Beach 2000 Main Street Huntington Beach,CA 92648 Re:Comments on Draft Environmental Impact Report No.97-2 for the Shea Homes Parkside Estates Subdivision Dear Mr. Barnes: The Fish and Wildlife Service(Service)has reviewed the referenced document and offers the following comments. The Service is a Federal agency with expertise in fish and wildlife habitat evaluation and mitigation and a long history of involvement in the fish and wildlife issues of USFWS-1 Bolsa Chica and the City of Huntington Beach. We are one of the agencies implementing the Bolsa Chica Lowland Restoration Project on State-owned property immediately adjacent to the subject property. The Service had provided a response,dated October 16, 1997,on the Notice of Preparation for this project,yet we do not find that the issues we identified have been addressed in this draft EIR. We believe that the subject draft Environmental Impact Report(dEIR)needs expansion or USFWS-2 improvement in the following areas:the nature and extent of wetlands on the property, alternatives to avoid or mitigate wetlands impacts on the property,and the relationship of the proposed plan to the Bolsa Chica Mesa development plan,the lowland restoration plan,and flood channel improvement plans. The actual nature and extent of wetlands on the site continues to be somewhat in dispute. It is our understanding that the Corps of Engineers has yet to confirm whether the"seasonal pond"is under Federal jurisdiction pursuant to Section 404 of the Clean Water Act,or not. The site history indicates that there is a regular occurrence of ponding and wet soil conditions,as well as frequent disturbance,such as discing. Evidently an obvious and recurrent seasonal pond exists USFWS-3 on the site on the westerly end of the property,which would seem to qualify as a"wetland"under j the California Coastal Act. If this seasonal pond were not frequently disced,it probably would exhibit other characteristics of wetlands than just ponded water,such as hydrophytic vegetation, hydric soils,and aquatic organisms. Therefore,we recommend that the proponent and the City of Huntington Beach should consider"environmentally"preferable alternatives such as -� ..v :. n, v ,. t•`v .Al 7% protecting the seasonal pond in place,by reducing the development footprint on the western third I USFWS-3 of the property. (Cont.) The dEIR(pages 5-160&5-162)identifies proposed mitigation of the acknowledged wetlands I on the"County Parcel"as 4:1 mitigation within the Bolsa Chica Lowlands or an alternative site would be found. We recommend that this proposal be considered as inadequate,since the proponent does not have any evident concurrence from any other landowner that they may mitigate any wetland impacts in the Bolsa Chica Lowland. No offsite mitigation opportunity is USFWS-4 apparent. We recommend the dEIR include a discussion of wetland mitigation measures for all of the"wetland"areas of the property. We further recommend that the mitigation measures be site specific and sufficiently detailed to allow the reader and decision-makers to evaluate the allowableness and feasibility of the proposed measures. The dEIR discussion of"aesthetics"includes a discussion of trail alignments. Exhibit 25,page 5-46,shows an"interpretive trail"and a class I bicycle trail along the edge of the subject property but extending into the Bolsa Chica lowlands. This figure infers that the dEIR preparers considered the now defunct Koll development plan to be relevant. In actuality,the proposed trails may not ever exist in the form shown on that figure.(Our wetland restoration plan dEIR/S will include alternative trail alignments on the State property later this year.) The proponent appears to be proposing a dead-end interpretive trail sandwiched between a concrete vertical wall USFWS-5 flood channel and perimeter wall at the back of the houses(Exhibit 6b,cross section A-A,page 3-9). We recommend that alternative trail alignments be considered at the west end of the subject property that would connect through the proponent's property to the private property, bicycle trails,and scenic route to the northwest of the subject property,rather than enter or skirt the wetlands of the lowland. The trail alignment along the southerly boundary of the proponent's property should also be considered for a widened,landscaped treatment,more along the lines of a "green way"than a concrete chute and preferably located on the proponenCs property,rather than on the flood channel edge. Alternative uses for the 4.9-acre parcel within County jurisdiction should be considered that would avoid houses jutting further into the lowland area currently being planned for restoration and long-term conservation of fish and wildlife. This action would appear to allow for a scenic, USFWS-6 naturally landscaped(nontidal wetland and upland habitat restoration),green way connection to the proposed"mesa community park"and further buffer the wetland area from urbanizing influences. This action could even incorporate an interpretive function. As a preliminary part of the engineering analysis for our wetland restoration project,the Service is evaluating the East Garden Grove-Wintersburg flood channel functions and inadequacies. We are finding that with some alternatives for improving the flood channel capacity to handle the 100-year flood,a detention basin would be necessary to avoid having to make improvements to USFWS-7 the Warner Avenue connection between Outer Bolsa Bay and Huntington Harbour. The subject property may be considered an excellent location for such a detention basin. We recommend that the dEIR include an evaluation of the alternatives for addressing this section of flood channel, since their action may foreclose implementation of otherwise feasible alternatives for solving existing threat of flooding and storm water damage. i Also as part of our preliminary analysis for our wetland restoration project,the Service has received information from County agencies regarding the quality and constituents of runoff in the area of this proposed project. Some potential problems are being noted that probably originate with street and yard runoff. For example,high total coliform counts have been detected in the USFWS-8 wetwell of the Slater pump station,large amounts of trash and urban debris deposit in the flood charinel. The proposed project apparently would incrementally contribute to these problems. We recommend a discussion of these problems and measures that the proponent may implement to avoid incremental degradation,such as Best Management Practices,grease traps,and vegetated swales/detention basins. We look forward to working with the City of Huntington Beach and the proponent on this project. We are particularly interested in aspects to the subject project that may impinge on the USFWS-9 wetland restoration project that we are evaluating. Please refer any question to Jack Fancher of this office at(760)431-9440. Sincerely, ' A. Bartel Assistant Field Supervisor 73 b ite of La lifflrni, "f= GOVERNOR'S OFFICE OF PLANNING AND RESEARCH 1400 TENTH STREET PETS WILSON SACRAMENTO 95814 _ ;�.1UL F t,;91NER r pj -.-ECTCR June 15, 1998 U11� 1 � �0 JIM BARNES CITY OF HUNTINGTON BEACH 2000 MAIN STREET HUNTINGTON BEACH, CA 92648 Subject: SHEA HOMES PARKSIDE ESTATES SUBDIVISION SCH #: 97091051 Dear JIM BARNES: The State Clearinghouse has submitted the above named draft Environmental Impact Report (EIR) to selected state agencies for review. The review period is now closed and the comments from the responding agency(ies) is(are) enclosed. On the enclosed Notice of Completion form you will note that the Clearinghouse has checked the agencies that have commented. Please review the Notice of Completion to ensure that your comment package is complete. If the comment package is not in order, please notify the State Clearinghouse immediately. Remember to refer to the project's eight-digit State Clearinghouse number so that we may respond promptly. Please note that Section 21104 of the California Public Resources Code required that: "a responsible agency or other public agency shall only make substantive OPRA comments regarding those activities involved in a project which are within an area of expertise of the agency or which are required to be carried out or approved by the agency. " Commenting agencies are also required by this section to support their comments with specific documentation. These comments are forwarded for your use in preparing your final EIR. Should you need more information or clarification, we recommend that you contact the commenting agency(ies) . This letter acknowledges that you have complied with the State Clearinghouse review requirements for draft environmental documents, pursuant to the California Environmental Quality Act. Please contact at (916) 445-0613 if you have any questions regarding the environmental review process. Sincerely, ANTERO A. RIVASPLATA Chief, State Clearinghouse Enclosures CC: Resources Agency See NOTE below SCH#97091051 NOTICE OF COMPLETION AND ENVIRONMENTAL DOCUMENT TRANSMITTAL FORM Appendix F 3 i to State Clearinghouse 1400 Tenth Street Sacramento.CA 95814 9161445.0615 Project Title:Parkside Estates EIR No 97- _— Load Agency: City of Huntington Beach Contact Person: Jim Bames ; S:reat Address: 2000 Main Street Phone: 1714)536-5271 City: Huntington Beach Zip: 92648 County: Orange Project Location County Orange City/Nearest Community: Huntington Beach Cross Streets: Warner Ave and Graham Street _ Total Acres: 51 Assessors Parcel No 110 015-24.2526.27 Section: 28 Twp: 5 South Range: 11 West Base: Seat Beach,Los Af.-,mmos Quad Within 2 Miles: State hwy#:_ Waterways:Wintersburci Channel Airports: �mlways: Schools: Document Type ZEQA: NOP SupplemenVSubsequent NEPA: _ NOI Other. _ Joint Document Earty Cons EIR(Poor SCH No.) _ EA _ Final Document _ Neg Dec Other _ Draft EIS Other X _ Draft EIR FONSI Local Action Type General Plan Update Specific Plan X Rezone _ Annexation(Water District) General Plan Amendment Master Plan _ Prezone _ Redevelopment General Plan Element Planned Unit Development X Use Permit X Coastal Permit Community Plan X Site Plan -X Land Division(Subdivision Other Sphere of Influence Amend Parcel Map.Tract Map.etc.) Development Type x Residential: Units 208 Acres r __ Water Facilities: Type MGD Offices: Sq.Ft._ Acres Employees — Transportation: Type Commercial: Sq.Ft_ Acres Employees _ Mining: Mineral Industrial: Sq.Ft._ Acres Employees — Power. Type Wars_ Educational. a Waste Treatment: Type Recreational: Hazardous Waste: Type Other. Project Issues Discussed in Document X Aesthetic Visual X Flood Plain/Flooding X Schools/Universities X Water Cluality - X Agricultural Land Forest Land/Fire Hazard Septic Systems X Water Supply/ X Air Ouality, � ___ Geologfc/Seismic X_ Sewer Capacity Groundwater X Archaeological/Histoncal _ Minerals X Soil Erosion/Compaction/Grading X Wevand/Riparian X Coastal Zone X Noise X Solid Waste X Wildlife X DrainageiAbsorption X Population/Housing Balance X ToxictHazardous X Growth Inducing Economics'Jobs X Public Services/Facilities X Traffic/Circulation X Land Use Fiscal X Recreation/Parks _X Vegetation X Cumulative Effects X Other Light/Glare Present Land UselZoning(General Plan Use _ Please refer to page 1 of the Initial Study. Project Description The project will consist of the approval of Tentative Tract Map(No.15377).Conditional Use Permit(No.96.60).Coastal Development Permit(No.96- 18)and pre-annexation request for the development of 208 single family homes on 51 acres of land Of that 51 acres,an 8 acre park site is also n,cluded. State Clearm:_house Contact: Mr.Chris Beloky Project Sent to the following State Agencies (916)445-0613 X Resources State/Consumer Svcs Star Rc1 ie1 B:_an: __--—Z biotin_ General Sen ices l�Coastal Comm Cal/EPA Dept.Revic%%Ir+.4__cnc� S7 _ Coastal C'onsv _ARII q Colorado Rvr 13d CA Waste M_nit Bd A enq Res to SCIi `S - z( --Conservation SN'RCB: Grants _X Fish&Game # .r SWRCB: Delta SCH CO\tI'L1:\ACC _ (O/ �S Delta Protection Fyrestry _SWRCB: \\'tr Quality 2_Q"aL sdC Rcc/011P _SWRCB: Wli Ri_hi+ Please note SCH Number on all Comment Reclamation X Reg,WQCB r _ 20� �D�/��/ DISC,CTC � DWR WR Please forward late comments directiv to the OES Yth/Adl[Corrections Lead Agency Bus Transp Hous _Corrections Aeronautics Independent Comm /, _CIIP _Energy Comm AQMD:APCD S3(Resources: j �<� ) X Caltrans# `X_NAHC Trans Planning __PUC Housing&Devel Santa Mn Mtns Health S Welfare X State Lauds Comin _Drinkine H2O _Tahoe Rsl Plan _Medical Waste Other: i 74 State or California - The Resources Agency PETE WILSON, Governor DEPARTMENT OF FISH AND GAME http://www.dfg.ca.gov South Coast Region 330 Golden Shore,Suite 5.0 Long Beach,California 90802 (562)590-5113 June 15, 1998fVi i jC Mr. James R. Barnes, Project Manager City of Huntington Beach 2000 Main Street Huntington Beach, California 92648 Dear Mr. Barnes: Parkside Estates Draft Environmental Impact Report SCH#97091051, Orange County The Department of Fish and Game has reviewed the Draft Environmental Impact Report (DEIR) for impacts to biological resources for the above referenced project. The proposed project includes the construction of 208 single family homes and a park site on approximately 49 acres of land. Approximately 44.5 acres of the project is located in the City of Huntington Beach and 4.5 DFG-1 acres is located in the unincorporated County of Orange. The Department has the following concerns regarding wildlife impacts and makes the following comments regarding mitigation measures for the project: Habitat Impacts Appendix G of the DEIR includes a March 16, 1998 letter written by the Department to the City of Huntington Beach. In that letter the Department concurred with the no wetland value determination as described in the December 17, 1997 verification/update report of the wetland value determination conclusion prepared by the City of Huntington Beach's consultant,Tom Dodson and DFG-2 Associates, for the Shea Company Property TT#15377. The Department's letter was based upon the information provided by Tom Dodson and Associates in their verif:caticn/update of wetland determination as referenced above. The DEIR states "Historic aerial photographs clearly show that the Orange Coun1y portion of the property was formed from the upper margin of the Bolsa Chica marshlands." Although this area has been severed geographically by the construction of the East Garden Grove-Wintersburg Channel and its biological values degraded by off-site road construction, oil drilling and associated surface activities,the Department has identified wildlife values on the parcel that should be mitigated. Namely,the loss of two small patches of degraded pickleweed habitat identified in the DEIR. The DFG-3 Department recommends that the wildlife values associated with this parcel be mitigated by the preservation and enhancement of 2.0 acres of appropriate wildlife habitat at a location acceptable to the Department. Therefore, Section 5.8, Mitigation Measure No. 2 should be amended to increase the mitigation from 0.8 to 2.0 acres. This mitigation should encompass the protection and enhancement of wildlife values on or as a part of a significant ecological system in the project Mr. James R. Barnes June 15, 1998 Page 2 vicinity, such as the Bolsa Chica Lowlands or the Upper Newport Bay Ecological Reserve. Alternative equivalent mitigation may also be acceptable if it is consistent with the DEIR and DFG-3 approved by the Department prior to any site development activities. I(Cont) Section 8.4-Mitigation and Measures Page 8-16 -Biological Resource Mitigation Measure Two 1. The Department recommends that mitigation measures for the pocket wetlands located within the Orange County portion of the proposed project be implemented prior to receiving DFG-4 a grading permit for the site. 2. The second sentence of biological mitigation measure two,page 8-16, is unclear and should DFG-5 be reworded to clarify the intent. Raptor Habitat Impacts The biological report contained in Appendix G of the DEIR states that the proposed site supports an "abundant gopher and ground squirrel populations that may attract resident and seasonal DFG-6 hunting use by birds of prey, including a number of hawks and owls." Wintering raptors migrate from their breeding grounds in the northern latitudes to southern California and beyond. Agricultural areas, grasslands and wetlands are of seasonal importance to DFG-7 several species of raptors in Orange County by providing important, if not vital, staging and wintering habitat. These habitats also provide foraging areas for resident breeding raptors. The biological report further indicates that 13 sensitive raptor species could be "observed localiy or expected to pass through the general site vicinity during seasonal migration." The report documents the sightings of several raptor species foraging or flying over the site. These DFG-8 observations include: a mated pair(presumably)of white-tailed kites (Elanus leucurus), a California Fully Protected Bird; a Ferruginous hawk(Buteo regalis); and a Northern harrier(Circus cyaneus) both California Species of Special Concern. Based on its status as a fully protected species,the take of white-tailed kites is prohibitated. The reduction of available raptor foraging areas within the project site and vicinity may also result in an increased dependance by birds of prey on dwindling remaining open space containing finite and/or sensitive prey resources such as the adjacent Bolsa Chica Ecological Reserve. The DFG-9 Department is concerned that this may result in increased raptor densities in the reserve resulting in increased predation on sensitive bird species such as the California least tern (Sterna antillarum brown)and Belding's savannah sparrow(Passerculus sandwichensis beldingi). Alternatives to the Proposed Project An evaluation of alternatives to the proposed project which would reduce biological impacts to a level of insignificance as required under CEQA Guidelines Section 15126(d) 1 was not include DFG-10 for impacts to wildlife habitats which provide wetland values and/or raptor foraging areas on the proposed project site. Mr. James R. Barnes June 15, 1998 Page 3 In summary, the Department recommends the proposed Parkside Estates Residential Development Project only be approved if all significant impacts to wildlife resources are disclosed DFG-11 and mitigated to less than significant levels. The Department realizes the many challenges that are involved in evaluating the proposed project related biological impacts on the site and appreciates the opportunity to comment. If you DFG-12 have any questions, please contact Mr. Scott Harris, Wildlife Biologist, at the letterhead address or by telephone at(562) 590-5100. Sincerely, Ronald D. Rempel Regional Manager cc: Department of Fish and Game Long Beach Mr. Larry Sitton Mr. Scott Harris Mr. Stephen Rynas California Coastal Commission Long Beach Mr. Jack Fancher U.S. Fish and Wildlife Service Carlsbad Mr. Eric Stein U.S. Army Corps of Engineers Los Angeles 75 June 17, 1998 t 1 ' To: City of Huntington Beach 'a Planning Dept. �- Attention: Jim Barnes J U N 9 2000 Main Street, 3rd Floor Huntington Beach, CA 92648 I am writing regarding the Shea Home Development west of Graham. I have previously made comments to this project at a city hall meeting. I would like to start by saying that I feel this 50+acre parcel is a contiguous part of the Bolsa Chica Wetlands. If DK-1 this is destroyed by development I feel that this will be a grievous loss to not only H.B. residents, but also everyone who realizes the value of wetlands as a precious resource. If however development were given the green light,I would like to comment on the draft EIR. In particular I would like to talk about traffic flow. I feel if Greenleaf DK-2 Steet,which dead ends into the Shea parcel, was connected to the development(as it was obviously intended)then the traffic flow would greatly benefit. While the draft EIR does not now address the Greenleaf alternative,I feel this is a superior alternative above all others in respect to traffic flow and circulation. The California Supreme Court has noted, "One of it's (an EIR's)major functions --- is to DK-3 insure that all reasonable alternatives to proposed projects are thoroughly assessed by the responsible official." Laurel Heights Improvement Assn. V. Regents of Univ. of California(1988)47 Cal. 3d 376,400. The connection of Greenleaf to the proposed project would allow project residents the alternative of three exits. The shortest route would be to the signalized"Super Street" Warner. There would also be exits on Graham, south of Warner and Graham, north of Glenstone. While the approximatly 208 households of the Prestige track may feel that the connection of Greenleaf would be an imposition to them, I feel that it should be considered. I feel that traffic flow on Graham would be improved with the Greenleaf DK-4 connection. The residents of Landing's tract,the Cal Classic tract,the Cal Classic by the Sea tract, and all those who would use Slater Ave. as an alternative to Warner, would benefit greatly from this better traffic flow. As you know most of the above mentioned tracts and it's residents were not notified about this project or its possible impacts. When you make your decision on this project I urge you to do what is best for all the residents of Huntington Beach. Thank you for your consideration. Dan Kittredge 5332 Glenstone Dr. Huntington Beach, CA 92649 76 June 21, 1998 Bryan & Robin Foster JUN � � 1998 5282 Kenilworth Dr. Huntington Bch, CA 92649 City of Huntington Beach Dept. of Community Development 2000 Main St. HB, CA 92648 RE: Tentative Tract Map No. 15377 & 15419 Following is our list of concerns relative to the proposed development behind our home, at 5282 Kenilworth Dr., off Graham: B&RF-1 1 ) Increased traffic volume added to one of the heaviest used streets in our area (Graham St.) 2) High potential of rear-end collisions at the proposed single entrance to the subdivision, off Graham St., near the bridge on the hill at B&RF-2 the Wintersburg Channel. 3) Increased noise created by increased traffic. One of the main reasons we chose to buy our home exactly where we did, was because the neighborhood is so quiet. We can actually enjoy the silence, and the singing of all the indigineous birds,(Owls, Kites, Blue Herons, Orioles, B&RF-3 Meadowlarks, Red-Winged Blackbirds, Ducks, and Geese, to mention a few) most every morning and evening-not just weekends. Obviously, all of this would be destroyed by removing the bird's habitat, and adding another 3- 400 vehicles travelling in and out daily. 4) What will be done with the coyotes that currently inhabit the property? Will they be transported to a new habitat? 68�RF-4 5) Inadequate, poorly designed single exit from tract: potentially 400+ vehicles lined up at the "Y" , with street only the length of a single B&RF-5 lot for vehicles to wait at the light at Graham. 6) Although the "emergency exit" at Greenleaf is shown as a gated exit on the proposal, it seems not only inevitible that it will be used as a MAJOR exit to Gramham and Warner (their design won't work), but will B&RF-6 have to be opened almost immediately for safety reasons! How could this plan have been approved by the Planning Commision? 7) The proposed "future connection to Bolsa Chica" should be a requirement to even consider the proposed Shea Development. This would allow a safe exit not only from the development but for the proposed park B&RF-7 at the west end of the site into a high traffic-volume street. 8) All of the homeowners on Kenilworth Dr. i I remain concerned that the proposed grading of the development, rising from level at the rear of our homes, to over eight feet near the channel, will create flooding B&RF-8 problems. We are already required to carry flood insurance. What is the likelihood that the addition of this development will cause the cost of our flood insurance to rise?? 9) We are concerned about the pesticides or hazardous chemicals that B&RF-9 have been or will be used to clear the land for building and eventually be in our water table or worse, enter into the channel, and then our wetlands and ocean. It might be possible to build a development on the proposed site that would be a worthwhile addition to this neighborhood, one that would not destroy the quality of the already existing community, but complement B&RF-10 all of its positive attributes. The proposed plan is a long way from that possibility. Sincerely, Bryan & Robi . F ter 77 J ` E6 61 60 1111I ' rd-wa- - 78 J JUNE 23,2998 cr JIM BARNES, PROJECT PLANNER CITY OF HUNTINGTON BEACH JU�I DEPARTMENT OF COMMUNITY DEV. 2 6 1�98 2000 MAIN ST. HUNTINGTON BEACH CA. 92648 CO.. ( r= =+ri;,;:=;'d =J. RE: TENTATIVE TRACT MAP NO. 15377 AND 15419 DEAR MR. BARNES: WE HAVE BEEN IN AND OUT OF TOWN AND WILL NOT BE ABLE TO VIEW OR COMMENT UPON THE DRAFT EIR AS RELATED TO ABOVE IN RE: . C&DM-1 HOWEVER IT MAY BE OF INTEREST TO YOUR OFFICE,:,TO HEAR WHAT WE HAVE BEEN AFFORDED THE LUXURY OF VIEWING FROM WINTER TO MID-SPRING BY THE LOCATION OF OUR CONDO DECK FOR THE PAST EIGHT YEARS AT THIS ADDRESS: SMALL TO LARGE MINI-LAKES OR PONDS SET AMONGST DENSE GROWTH GREEN ABUNDANT AND TALL. THE WATERS TURNING GREY TO BLUE TO GREY AS CLOUDS PASS OVER-HEAD AND LASTLY SHIMMERING AMBER AS THE DAY ENDS. THE WATERS FREQUENTED BY SANDPIPERS, DUCKS OF COLOURSZI HAVE NEVER SEEN BEFORE, EGRETS WHITE AND SERENE, CANADA GEESE, MUD HENS AND HUNDREDS OF THERS TO C&DM-2 WHICH I CANNOT GIVE A NAME. ALL MAKING THIS QUIET .BEAUTY THEIR HOME UNTIL MID-SPRING WHEN THE AREA IS PLOWED. THERE ARE GREY HERON THAT NEST IN THE EUCALAPYTUS TREES OFF OUR DECK. AT TIMES WE HEAR THE HOOTING OF AN OWL AND MOONLIGHT HAS OFT SHONE UPON COYOTES OUT FOR A STROLL. TELL ME WHAT IMPACT THE PROPOSED SUBDIVISION WILL HAVE UPON THOSE THAT HAVE MADE THIS AREA THEIR HOME FOR SO LONG AND WHERE WILL THEY GO WHEN THEIR ENVIRONMENT IS TAKEN AWAY.WHEN C&DM-3 THERE IS NO-WHERE ELSE FOR THE BEAUTY OF NATURE TO LIVE. THANK YOU FOR YOUR TIME IN THIS MATTER. SINCERELY, L CHER3iE & DANNY MARUK I 51 7 6/TORTUGA DRIVE #1 1 0 HUNTINGTON BEACH,CA. , 92649 PHONE/FAX: 714 8466789 7.2 Comment Letters on the new Alternatives to the DEIR NEW ALTERNATIVES TO THE DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 1. Southern California Gas Company SCGC#2-1 Robert S.Warth P.O.Box 3334 Anaheim, CA 92803-3334 2. Donnamarie Risse DR#2-1 -5 5422 Kenilworth Drive Huntington Beach,CA 92649 3. Department of Transportation DOT#2-1 Robert F.Joseph District 12 2501 Pullman Street Santa Ana,CA 92705 4. Eileen Murphy Erna 1-6 201 215f Street Emb 1-3 Huntington Beach,CA 92648 5. California Coastal Commission CCC#2-1 - 12 Orange County Area Supervisor Stephen Rynas,AICP 200 Oceangate, Suite 1000 Long Beach,CA 90802-4302(sent via Fax 6/15) 6. Environmental Board HBEB#2-1 - 11 Frank R. Caponi,Chairman 7. Terry Dolton TAD 1-16 17692 Soreham Lane Huntington Beach,CA 92648 8. Environmental and Project Planning Services OCPD#2-1 -21 Division,County of Orange George Britton,Manager 300 N.Flower Street, 31a Floor Santa Ana,CA 92702 i NEW ALTERNATIVES TO THE DRAFT EIR COMMENT LETTERS/RESPONSES TO COMMENTS INDEX COMMENT/RESPONSE WRITTEN COMMENT LETTERS SERIES 9. Bolsa Chica Land Trust BCLT#2-1 - 12 Nancy Donaven 207 213'Street Huntington Beach,CA 92648 10. Amigos de Bolsa Chica ADBC#2-1 - 10 Linda Sapiro Moon,President P.O.Box 3748 Huntington Beach,CA 92605-3748 11. California State Lands Commission CSLC#2-1 -6 Dwight E. Sanders 100 Howe Avenue,Suite 100-South Sacramento,CA 95825-8202 12. Resource Preservation Alliance RPA#2-1 -27 Douglas Stewart 5342 Kenilworth Drive Huntington Beach,CA 92649 13. Kenneth Feldman KF#2-1 -2 5411 Glenstone Drive Huntington Beach,CA 92649-4705 14. California Regional Water Quality Control Board RWQCB 1-6 Wanda Smith,Chief 3737 Main Street, Suite 500 Riverside,CA 92501-3348 i Southern California Gas Company Orange Coast Region The PO Box 3334 Gas Anaheim,CA 92803-3334 Company® D A XSempra Energy-company June 25, 2001 City of Huntington Beach Planning Department 2000 Main St. Huntington Beach,CA. 92648 Attention: Sandra Thornton Subject:EIR—New Alternatives to the Draft EIR No.97-2 for Parkside Estates Project. This letter is not to be interpreted as a contractual commitment to serve the proposed project,but only as an information service. Its intent is to notify you that the Southern California Gas Company has facilities in the area where the above named project is proposed. Gas service to the project could be served from an existing main as shown on the attached atlas sheet without any significant impact on the environment. The service will be in accordance with the company's policies and extension rules on file with the California Public Utilities Commission at the time contractual arrangements are made. The availability of natural gas service, as set forth in this letter, is based upon present conditions of gas supply and regulatory policies. As a public utility, the Southern California Gas Company SCGC*2—1 is under the jurisdiction of the California Public Utilities Commission. We can also be affected by actions of gas supply or the condition under which service is available, gas service will be provided in accordance with revised conditions. Estimates of gas usage for residential projects are developed on an individual basis and are obta-u-led tLioui tiie Resideraiai Market Services Staff by calling 1,1800; 427-2000. We have developed several programs, which are available upon request to provide assistance in selecting the most energy efficient appliances or systems for a particular project. If you desire further information on any of our energy conservation programs, please contact this office for assistance. Sincerely, Robert S.Warth Technical Supervisor lag eirres.doc 2 ,� C c � 3 g tr t 3j r $ F rf r3 pp :�.i-5 .kiss �r VM�i ron 3 sy �y T�sty s t .ali t,N7r'N s y Al 3i ,xia�� rc �435v.� �t9 TflF �B s _ y ys Ew e 4 "M F > TRfPt .<n f S 27 of i 4 t Af%T g _ z e L, M60, -t' J•5. �e�;G` �'Kc2" 5 { a �,s� �s�l� 02 rg } �v .���.�iR' f Era �m� ".` 47 ,�'a•, t dy�xf��}�a �4 •4. 31,.!,�s. iff 1S�s {S+'t•.-4 v ? '44.rrr' t s. { � ISK" s„{ras tz to T ta. -pig r<4}j, q i77 i fY Zri a< Yl f} sr� t t �'a , t ^� i�`r 4...�, a bf • f`i tyYl '� Donnamarie Risse 5422 Kenilworth Drive Huntington Beach, CA 92649 July 3,2001 Sandra Thornton,Project Planner City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Dear Ms. Thornton: I am responding by letter to the Parkside Estates Project of Shea Homes because I will be out of �DR#2 — 1 town on July 25, 2001. #1 I found the plan as I interpret it on the accompanying copy acceptable except that it shows my land elevation the same as that of Paseo Park.. It is not. My property is 14"to 18"dower than the field's elevation. Last winter, my patio,which is the lowest portion of my backyard was flooded 1" DR#2 —2 deep in water for over a week and my flower beds in places were 34"deep in water. It is not Shea Homes fault that my elevation is so low but I would not want to exacerbate the problem either. #2 If the wall dividing my property from Paseo Park is going to be built at the elevation of the D R#2 —3 present road,will the new wall be reinforced enough that I am guaranteed that my wall will not have to withstand the force of the additional earth against it? #3 The water level in my backyard pool which is about 30 years old is showing subsidence at the DR#2—4 end that is closer to my home so I would like careful attention to the dewatering process as I know that our soil being river bed is very unstable. #4 I could accept a plan that places the proposed homes as shown in the illustration that I copied from the report available in the library. I did not see the section that you referred to as a possible I F DR#2 —5 elevation above my home. I would be opposed to this because I feel it would increase the flood danger to my own residence with the sheet flooding to which this area is prone. Sincerely, Donnamarie Risse 3 STATE OF CALIFORNIA—BUSINESS,TRANSPORTATION AND HOUSING AGENCY GRAY DAVIS, Governor _ PARTMENT OF TRANSPORTATION `&STRICT 12 3337 MICHELSON DRIVE,SUITE CN380 IRVINE,CA 92612-1699 July 12, 2001 Sandra Thornton IGR/CEQA City of Huntington Beach DEIR No. 97-2 2000 Main Street SCH# 97091051 Huntington Beach, CA 92648 Log # 935 Dear Ms. Thornton: Subject: Parkside Estates Project Thank you for the opportunity to review and comment on the New Alternatives to the Draft Environmental Impact Report (DEIR) No. 97-2 for the Parkside Estates Project. The proposed project is to construct up to 171 single-family homes and a 14.4-acre park/open space area. The proposed project site is located on approximately 49 acres west of Graham Street, north of the East Garden Grove — DOT#2—1 Wintersburg Channel and south of Warner Avenue in the City of Huntington Beach. Caltrans District 12 is a reviewing agency and has no comments. Please continue to keep us informed of projects that may potentially impact our State Transportation Facilities. If you have any questions or comments, please contact Lynne Gear at (949) 724-2241. Si cerely, Ro ert 4F. os p Chi Advance Plan ing Branch cc: Ron Helgeson, HDQTRS Terry Roberts, OPR 4 -� July 26,2001 City of Huntington Beach % Scott Hess 2000 Main Street HB CA 92648 RE:Public Comments on Parkside Estates EIR 97-2 This project will bring disaster to the community of Huntington Beach when the inevitable 100-year storm happens. This project is a man made disaster. When will we learn that nature does not dance to EMa— 1 our tune? Here is an area over 40 acres which is a wetland and has been for thousands of years and will be reclaimed when the inevitable happens. This project wants to bring in 9 feet of dirt to cover the project sight and because of FEMA must be raised out of the flood danger elevation. The houses will be surrounded EMa—2 by homes which will be 9 feet below the 161 houses being built here. Another egregious part of this boon dazzle project is there is ONE EXIT and ENTRANCE for the 161 projected houses. That means this project will put at a EMa —3 minimum 644 car trips in this one street which is already at peak use from the surrounding houses. Where does the urban run-off go from this monster towering over the existing neighborhood? I doubt if the promised 120-inch pipe will be able to collect all the run- EMa—4 off from the first and following big rains we have in the area This project needs a new completely recirculated EIR for comments not a piecemeal- circulated part of an old EIR —5 IEMa This project should not be allowed to happen. I EMa—6 ileen Murphy 201 21't Street PS CA 92648 August 13, 2001 Scott Hess Project Planner City of Huntington Beach Planning Department 2000 Main Street Huntington Beach, CA 92648 Re: New Alternatives to the Draft Environmental Impact Report No. 97-2 For The Parkside Estates Project Dear Scott, Thank you for the opportunity to comment on the above referenced EIR. Bolsa Chica Land Trust has submitted previous comments to Draft EIR No. 97-2. We would like to make the following comments: EMb— 1 I have two items which I did not see addressed in the New Alternatives. 1. The traffic from the proposed project has only one in and out road IThis street is already overburdened by the people using it who already EMb—2 are living on the one street or around it. This will be gridlock for all the residents if this isn't solved. 2. The project is going to pay to shore up the Wintersberg Channel on EMb—3 the side closest to the project. In my opinion this is a dangerous thing for the city to agree to because it EMb—3 leaves the people on the un-shored up channel vulnerable to severe (cont.) flooding if and when the 100 year flood occurs. Sincerely i leen Murphy v�(; � 201 21st Street HB CA 92648 5 STATE OF CALIFORNIA-THE RESOURCES AGENCY GRAY DAVIS,Govemor CALIFORNIA COASTAL COMMISSION South Coast Area Office 200 Oceangate,Suite 1000 g Beach,CA 90802-4302 " 2)590-5071 July 31 , 2001 Sandra Thornton Planning Department City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648-2763 SUBJECT: New Alternatives to the Draft Environmental Impact Report No. 97-2 for the Parkside Estates Project Dear Ms. Thornton: Thank you for sending Commission staff a copy of an updated draft (Draft) to the Parkside Estates EIR which includes four new alternatives not previously considered by the original document (dated April 1998). Commission staff commented on the Notice of Preparation on October 24, 1997 and the original Draft on June 15, 1998. This new Draft analyzes the environmental impacts of four new alternatives when compared to the original Parkside Estates EIR. The CCC#2 - 1 four new alternatives incorporate reduced density and new floodplain analysis. The new alternatives reflect a total residential unit count of 171 or 161 (depending on the alternative) for the entire project site (City and County parcels), an increase in floodplain elevations, and 14.4 acres of park/open space. This draft was received by Commission staff on July 2, 2001 . Below are the comments by Commission staff on the updated Draft. INACCURATE STATEMENTS The purpose of the environmental review process is to provide the public and the decision makers with all relevant factual data, in an objective form, in order to facilitate the decision making process. Commission staff is of the opinion that the draft EIR is inadequate in this respect as not all relevant factual information is CCC#2 - 2 provided, and some of the statements are misleading. Conclusions are often based upon incomplete factual data. Had all relevant data been presented, different conclusions may have been reached. ♦ For example, on Page 1-5 of the Draft a statement is made that "... the US Army Corps of Engineers declared the site as "Prior Converted Cropland," ICCC#2 - 3 Sandra Thornton July 31, 2001 2 eliminating any concern that the site contained wetlands." The conclusion that all concerns relating to wetlands has been resolved solely because ACOE jurisdictional wetlands do not exist on the City parcel may be premature for the reasons cited below. Moreover, the assertion that the site does not contain wetlands is misleading as the designation of "Prior Converted Cropland" may not apply to the entire site, but only to the portion of the site that was determined to meet Federal Clean Water Act jurisdiction by the EPA' in 1989. Also, it is our understanding, that the designation of "Prior Converted Cropland" does not mean that wetlands do not exist, only that if wetlands do exist that the ACOE would_ not be able to assert Federal jurisdiction under the Clean Water Act. The principal concern of Commission staff is that the wetland definition and methodology of the ACOE is being used as the standard for determining the CCC#2— existence of wetlands. However, the Commission relies on a different and more (cont.) inclusive wetland definition for determining the presence of wetlands2,3. Commission staff recommends that an updated wetland delineation using the Commission's wetland methodology and criteria be undertaken for both the County and City parcels. Additionally, Sections 30241 , 30241 .5 and 30242 of the Coastal Act contain provisions for preserving existing agricultural use. Section 30222 of the Coastal Act establishes that residential development is a lower priority use than agricultural use. Section 30233 of the Coastal Act prohibits residential development in wetlands. Next, it is possible that the U.S. Army Corps of Engineers, other Federal agencies, or other State agencies could still consider portions of the area as a wetland. For example the ACOE could still consider the area as a wetland ' U.S. Environmental Protection Agency: Geographical Extent of Clean Water Act Jurisdiction at Bolsa Chica, Orange County, CA, February 10, 1989. 2 The Commission uses the "Classification of Wetlands and Deep-Water Habitats of the United States" by Cowardin, et al (December 1979) as guidance for conducting wetland delineations. 3 Tom Dodson and Associates (December 17, 1997), an environmental consulting firm, concluded that the City parcel did not contain any wetlands based on the Commission's wetland criteria. The Department of Fish and Game (March 16, 1998) evaluated the work performed by Tom Dodson and Associates and concurred with this assessment. However, Commission staff has received additional letters (two of them more recent than the original assessments) asserting that wetlands may exist on the City parcel (Douglas Stewart (January 19, 1998), Scott White Biological Consulting (April 5, 1998), and Jan Vandersloot (July 29, 1998)). The observation of potential wetland values warrants additional study and evaluation based on the Commission's wetland methodology to determine whether wetlands exist or not. Sandra Thornton July 31, 2001 3 under other Federal statutory provisions such as the "Rivers and Harbors Act". Since Commission staff can not speak for the U.S. Army Corps of Engineers, CCC#2 — 3 other Federal agencies or other State agencies such as the Department of Fish (cont.) and Game, Commission staff recommends that the affected agencies be contacted. ♦ Page 1-5 of the Draft contains statements relative to the City parcel which do not fully disclose the regulatory decision making process for approving development, which may leave the reader of the Draft believing that proposed residential development of the site would necessarily.or automatically be appropriate simply because the area is zoned residential. The Draft states: "The Conservation designation of the City"s Coastal Element Land Use Plan was never taken forward by the City to the Coastal Commission for approval." and "It should be noted that the zoning designation of the portion of the property that is proposed for residential development has been R 1 or RL (Single Family Residential) since 1971." Additionally Page 2-5, which discusses Alternative 6, concludes that "The alternative is consistent with the adopted City of Huntington Beach General Plan land use designation of RL (Residential Low Density) and with the City of Huntington Beach applicable goals and policies of the General Plan." The foremost concern of Commission staff with the land use consistency CCC#2—4 narrative above is that the effect of the Coastal Act on the City's land use planning process has not been appropriately discussed. The City parcel has been designated an area of deferred certification, which means that the City's land use and zoning designations for this area have not been approved by the Commission. Integral to this concern is the fact that the Commission deferred certification of the City parcel to allow the City time to develop a land use plan for resolving allowable development with wetland protection. Because the City parcel was deferred certification due to outstanding issues, the fact that the area has been zoned by the City for Residential Low Density should not be used in a manner which implies that final approval for this type of development exists. The fact that the Conservation designation was never taken forward by the City to the Commission for certification does not mean that anything consistent with the existing zoning would necessarily be approvable under the Coastal Act. The appropriateness of zoning the City parcel Residential Low Density still necessitates further review since the Commission deferred certification of this area. A local Coastal Program amendment has not been submitted to the Commission for certification by City to tackle the issue of the most appropriate Sandra Thornton . July 31, 2001 4 development for this area. Therefore, above and beyond any City requirements, any proposed development on the City parcel must conform to the Chapter 3 policies of the Coastal Act since a local coastal program for the area has not CCC#2 —4 been certified by the Commission. Unless the City submits a local coastal (cont.) program amendment to the Commission for certification, the actual appropriateness of the proposed residential development will be evaluated through the coastal development permitting process of the Commission. ♦ On page 1-5 the Draft also discusses the land use designation for the County parcel. The Draft states: "This action by the Coastal Commission was challenged in court on January 12, 2001 by the owner of the Bolsa Chica Mesa, therefore, the land use designation of Medium-Low Density remains in effect." The preceding sentence presents a misleading characterization of the result of the litigation. It leaves the reader of the Draft with the impression that zoning which would allow residential development to proceed is formally and finally in place. This is not the case. Similar to the land use discussion on the City parcel above, the County portion is subject to the Coastal Act. Therefore, as discussed above, any proposed development, even if it is consistent with existing land use and zoning designations of the local government, still requires review by the Coastal Commission and there is a potential that the proposed development may not be CCC#2—5 considered approvable under the Coastal Act. The Commission, through its November 16, 2000 decision, because of the resource values present, proposed that the land use of the County parcel be designated as "Conservation" based on Section 30240 of the Coastal Act. Consequently, from the Commission perspective, any proposed development on the County parcel must be consistent with the "Conservation" designation. The County, however, on May 8, 2001 declined to accept the Commission's suggested modifications4. From the County's perspective, this means that the Commission's "Conservation" land use designation is not operational. Though the County may not have accepted the Commission's suggested modifications, any proposed residential development, before it can be undertaken, must nevertheless be reviewed by the Commission either through the coastal development permitting process or through the local coastal program process. Since Commission review of proposed development is mandated by the Coastal Act, and the policies of Chapter 3 of the Coastal Act govern the Commission's 4 Additionally, the Commission's certification lapsed on May 16, 2001 pursuant to Section 13537 of Title 14 of the California Code of Regulations. Sandra Thornton July 31 , 2001 5 review, the County's land use designation "Medium-Low Density" is not binding upon the Commission. Finally, the statement that the land use designation of "Medium-Low Density" remains in effect because a lawsuit was filed is not appropriate. The lawsuit is still pending which means that the outcome is not known. Until a final judicial CCC#2—5 decision is rendered it is premature to conclude that "the land use designation (cost.) of Medium-Low Density remains in effect." The examples above are selected examples. Commission staff recommends that the Draft be reviewed (in light of the examples above) and that all relevant information be added to the Draft to assure that the reader can make an informed decision. BIOLOGICAL CONCERNS ♦ A major concern with the proposed residential development has been the appropriateness of allowing residential development in an area containing wetlands and other environmentally sensitive habitats. Commission staff recognizes that the purpose of this Draft is to present new alternatives which were not previously considered. Nevertheless, new biological data obtained since the release of the original draft in April 1998 has not been incorporated in developing the new alternatives. Commission staff notes that new floodplain information was incorporated for developing new alternatives (page 1-1). The availability of new biological data also constitutes "new information" which was not known at the time of the original draft in 1998. New biological information could have a significant effect for establishing why one alternative is superior to another. Section 30240 of the Coastal Act establishes that environmentally CCC#2—6 sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on those resources shall be allowed within those areas. Since the release of the original Draft in April 1998, new biological data has been collected and analyzed which would assist the decision makers in evaluating the appropriateness of residential development based on the requirements of Section 30240 of the Coastal Act. This information is relevant and should be included in the new alternatives analysis. The Commission's Bolsa Chica staff report of November 2, 2000 contained new habitat data. The Chambers Group prepared the "Draft EIR/EIS for the Bolsa Chica Lowlands Restoration Project" (July 2000). Commission staff has requested that both Sandra Thornton July 31, 2001 6 Shea Homes and Hearthside Homes' prepare additional biological/habitat studies. Some of these requests have been undertaken. For example Shea Homes retained LSA Associates, Inc. to prepare "Habitat Analysis, Parkside Estates Tentative Tract No. 15419 (County Parcel), Orange County, California." (December 8, 2000). The Bolsa Chica Land Trust has also supplied new CCC#2 —6 biological information as part of the Bolsa Chica LCP planning process. For (cost.) example, the Bolsa Chica Land Trust retained Tierra Madre Consultants, Inc. to prepare a raptor assessment for Bolsa Chica. This assessment was released on December 5, 1999. These new biological/habitat studies are relevant as they may provide the factual data necessary to evaluate which alternative should be selected for implementation. ♦ Commission staff notes that new graphics such as Exhibits 47a, 47b, 49, 50, and 51 (as well as others) have been added. These exhibits, as well as others, do not fully disclose the resource values present. Especially troublesome are Exhibits 47a and 47b which limit the display of environmentally sensitive habitat areas on the County parcel to the Department of Fish and Game ESHA determination of June 3, 1982. Furthermore, the portion of the County parcel known to contain ESHA has simply been identified as "Passive Open Space" on the exhibits which obfuscates the underlying resource values. The lack of full disclosure of the areal extent of environmentally sensitive habitat areas, including wetlands, deprives the reader of the Draft with the opportunity to make a fully informed decision regarding the proposed residential development. CCC#2—7 Exhibits 47a, 47b, 49, 50, and 51 (as well as others) are not accurate representations of the habitat values currently present. For example, the 0.2 acre pickleweed patch (page 2-1 1), which is a wetland/ESHA, is not shown on either Exhibit 47a or 47b. The presence of the pickleweed patch was shown on a graphic which is in the Commission's files prepared by Frank Hovore (January 14, 1997) which could have easily been incorporated into the exhibits. Next, this area was the subject of the LSA Associates study conducted from September 1999 through August 2000 which updated the earlier evaluation on the areal extent of the wetlands by Hovore. This information is newer than the Department of Fish and Game study and would provide the reader with a better understanding of where ESHAs such as wetlands exist. Additionally, Exhibit 47b (as well as Exhibit 63) is inaccurate. In reference to alternative 6, the Draft states that "the alternative provides a 464-foot buffer e Hearthside Homes is the residential developer proposing residential development on the Bolsa Chica mesa. Sandra Thornton July 31, 2001 7 from the closest residential unit to the 0. 13 acre on-site ESHA" (page 2-6). The 464-foot distance is incorrectly applied based on the Department of Fish and Game ESHA determination of June 3, 1982. When the Department of Fish and Game made its findings in 1982 the study area apparently terminated along an imaginary extension of Bolsa Chica Street to the Garden Grove Wintersburg Channel. Based on the fact that the majority of the County parcel was not within of the Department of Fish and Game's study area, a claim can not be made that this area was not ESHA. In fact, as previously mentioned, the County parcel contains wetlands as documented by a variety of sources including: Frank Hovore, LSA Associates, Hunsaker and Associates', and the U.S. Environmental Protection Agency'. Based on the LSA Associates, Inc. analysis, the site appears to contain CCC#2 —7 approximately 1 .2 acres of wetland ESHA plus 0.9 acres of Eucalyptus (cont.) woodland which is significantly greater that the 0.13 acres of ESHA identified above. Based on the LSA Associates evaluation of December 8, 2000, the nearest residential units appear to be approximately 260' from the Bassia Scrub wetland community which is an ESHA. Additionally, in this area, eucalyptus trees are considered ESHA as they provide habitat for raptors. Exhibit 49 implies that residential development will be setback approximately 100' from the Eucalyptus trees. Based on recent biological data cited above, the ESHA is much larger than shown on the exhibits and the proposed residential development provides a 100' buffer not a 464' buffer. ♦ Commission staff reiterates that the Commission (at its November 16, 2000 meeting on the Bolsa Chica LCP) proposed a suggested modification that the CCC#2—8 entire County parcel be designated as "Conservation". The effect of this decision, consistent with Section 30240 of the Coastal Act, is that residential development would not be an allowable use on the County parcel. PUBLIC ACCESS One of the major policy issues of the Coastal Act is the provision of public access. The Draft contains several graphics (such as Exhibits 49, 52, 57, as well as others) CCC#2—9 which show parks and trails. Exhibit 57 provides some clarification as to which areas will be public parks versus private parks. However, this distinction is not 6 Figure 2.1 from the Bolsa Chica EIR (County Project No. 551) dated June 24, 1997 7 Geographical Extent of Clean Water Act Jurisdiction at Bolsa Chica, Orange County, CA dated February 10, 1989. Sandra Thornton July 31, 2001 8 made regarding the trail system. Commission staff recommends that the private/public components of the trail system be clearly identified. CCC#2—9 Commission staff notes that Lot "0" on Exhibit 57 is identified as a Home Owners (cont.) Common area with a trail through it. Will the public have access through this lot? SITE DRAINAGE AND WATER QUALITY Consistent with the Section 30240 of the Coastal Act, the Commission proposed that the County parcel be designated "Conservation" due to the presence of environmentally sensitive habitat, including wetlands. The proposed residential development will alter site drainage. Exhibit 58 (Exhibit 71 also) is one of the graphics showing how the proposed storm drain system would function. Based on this graphic, storm water would be discharged into the East Garden Grove Wintersburg Channel. This discharge can have two effects. First, the effect of CCC#2— 10 routing storm water flows to the East Garden Grove Wintersburg Channel may deprive the wetlands of a needed source of water. Second, the water discharged into the East Garden Grove Wintersburg Channel will carry urban runoff and eventually flow into the Pacific Ocean. This could have an adverse effect on the health of the coastal waters and wetlands. Section 30230 and Section 30231 of the Coastal Act require that the biological productivity and quality coastal waters and wetlands be maintained and where feasible enhanced. Please address the issue of how the functionality of the existing ESHA (including wetlands) on the County parcel will be protected and how coastal waters will be protected from urban runoff. SEAWALL/RETAINING WALL Exhibit 64 is one graphic which shows a proposed seawall. The rationale and necessity for this seawall was not discussed in the New Alternatives to the Draft. Commission staff assumes the seawall has been proposed to raise the height of the residential building pads above the flood plain elevation. Commission staff is consequently concerned regarding the seawall's conformance with the Coastal Act: Section 30253(2) of the Coastal Act states "Assure stability and structural CCC#2— 11 integrity, and neither create nor contribute significantly to erosion, geologic instability, or destruction of the site or surrounding areas or in any way require the construction of protective devices that would substantially alter natural landforms along bluffs and cliffs." Section 30251 states, in relevant part, that "The scenic and visual qualities of coastal areas shall be considered and protected as a resource! Sandra Thornton July 31, 2001 9 of public importance. Permitted development shalt be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the character of surrounding CCC#2— 11 areas, and, where feasible, to restore and enhance visual quality in visually (cont.) degraded areas." Commission staff requests that the final El explain why the seawall/retaining wall is necessary and to evaluate its conformance with the policies of with the Coastal Act. CONCLUSION Commission staff appreciates the opportunity to have reviewed this Draft. Before, residential development can proceed, the Commission must approve the development either through the coastal development permit process or through the local coastal program process. The project proponent will need to address the concerns that Commission staff has identified including the need for a current comprehensive wetland delineation based on the definitions in the Coastal Act and CCC#2— 12 the California Code of Regulations. We hope that these concerns will be addressed in the Final EIR for this project. This information will be crucial for evaluating the appropriateness of residential development and, if appropriate, how impacts from proposed residential development can be mitigated. Should you have any additional questions please do not hesitate to contact me at 562-590-5071 . Sincerely, A Steph n Rynas, AICP Orange County Area Supervisor \\HAMMERHEAD\srynas$\Letters\Shea Homes\shea12.doc s CITY OF HUNTINGTON BEACH ENVIRONMENTAL BOARD August 2, 2001 Ms. Mary Beth Broeren, Senior Planner City of Huntington Beach Planning Department 2000 Main Street, 3rd Floor Huntington Beach, CA 92648 Subject: Parkside Estates—New Alternatives to the Draft Environmental Impact Report#97-2 Dear Ms.Broeren, The Environmental Board(Board) of the City of Huntington Beach is pleased to submit its comments and recommendations on the Parkside Estates—New Alternatives to the Draft Environmental Impact Report 497-2 (EIR). The Board provided comments on the original EIR, June 1998. These comments are attached for your reference. The Board HBEB#2—1 discussed the adequacy of the new alternatives at its regularly scheduled meeting on August 2, 2001. The comments included below were approved by Board action at the same meeting. Where possible,the Board's comments tried to focus on only the new alternatives;however, the Board determined that some issues were important enough to repeat in this series of comments. The following represent the Board's comments: General The original EIR process, including a public comment period,began over three years ago. Since then a number of significant changes have occurred that have caused four new alternatives to be evaluated and a separate document prepared exploring their environmental impacts. The authors should be complemented on their thorough presentation of the information supporting the new alternatives. In review of the EIR HBEB#2—2 though,the Board found it difficult at times to understand how the new information related to the older alternatives. Thus,the Board suggests that the final EIR provide a complete list of all alternatives in a tabular form that would summarize, for each alternative, the environmental issues,the environmental impact, the mitigation measures, and level of significance after mitigation. Preferred Alternative Of the four new alternatives evaluated, the Board finds Alternative No. 9 the preferable alternative for this project. Alternative,No. 9 minimises visual impacts to the greatest HBEB#2—3 extent possible,while maximizing the amount of open space and protection of sensitive areas. The EIR evaluates the impacts of four alternatives (Nos. 6,7,8 and 9), each of which are in response to requested changes by the City of Huntington Beach Staff, as well as new floodplain information provided by FEMA. The Board believes that the greatest impact of the new alternatives will be the potential visual impact of the increased building pad elevation, at between 4.5 to 11.5 feet. To mitigate this visual impact, when compared to the original EIR, the developer has instituted a number of changes. For example, the setback distance of the homes from the existing homes has been increased, a park strip has been added between the proposed development and the existing homes, and the proposed homes in direct line-of-sight have been re-oriented so that the more attractive HBEB#2—3 front of the house would be seen, instead of the backyards. The developer's intent is to (font.) create a view that is similar in overall impact to the originally proposed alternatives. The Board agrees that the incorporation of a greater setback distance, inclusion of a park strip and reorientation of the homes into the design represents an improvement compared to the original alternatives. However, at the higher pad elevations,the Board.is concerned that the project may not be compatible, visually or aesthetically with the existing neighborhood. This concern is the basis for the Board's choice of Alternative No. 9 as the preferred alternative. Site View The EIR presents visual simulations from the rear fence of existing homes on Kenilworth looking toward simulations of the new alternatives to determine the extent of the project's visual impact. The unique feature of the new alternatives is the increased elevation of the building pads as a result of the new flood plain information,placing the project at a higher elevation relative to the existing homes in the area. To more fully determine the impact of the project,the Board recommends that a visual simulation be HBEB#2 —4 presented that looks down from the proposed home sites to the existing homes. So for example,the simulation will determine if there will be a line of sight from the project, at street level and from the second story window, down into the backyards of the houses along Kenilworth. Although this type of analysis is not required under CEQA, it is the Board's opinion that this will provide a more complete presentation of the proposed project's visual impacts. Flood Control The proposed project will incorporate upgrades to the East Garden Grove—Wintersberg Channel to account for 100-year storms. Exhibit 6b-1 indicates that a vertical channel wall will be added along the channel's edge adjacent to the project in order to prevent flooding in the event of a severe storm event. It appears though,that the improvements HBEB#2 —5 will only span the length of the project. What is not clear in the current document however, is if the addition of a higher channel wall adjacent to the project, would cause the surrounding areas to flood more severely then if the project were not constructed, since floodwaters would be directed away from the project. The Board request that this issue be addressed. Storm Water Quality The proposed project will be built close to the Bolsa Chica Wetlands. The Coastal Commission has previously expressed concern over storm water runoff from the Bolsa Chica Mesa property to the wetlands. Based upon that finding,this should also be a HBEB#2—.6 concern for this project. Therefore, the Board request that the EIR more fully determine the level of storm water runoff that may impact the wetlands,the quality of this runoff and if treatment should be required. Buffer Areas The EIR addresses buffer zones from the Environmentally Sensitive Habitat Areas (ESHA) in Exhibits 47b and 63. The Coastal Commission in November 2000 designated the open space in the County portion of the proposed project as Conservation. This decision has been appealed. Of concern to the Environmental Board with this HBEB#2 —7 designation is if the Conservation Area would now be considered part of the ESHA. The Coastal Commission recommends approximately 100 meters in order to buffer coastal landforms and various habitat areas, including eucalyptus trees, from development. If this area is considered part of the ESHA, at question in this project is the level of buffer needed, and what constitutes the boundaries at which the buffer would begin. The Board request clarification of this issue. Eucalyptus Trees The EIR describes that Arborist will decide what dead or dying trees will be removed from the project area. The Board recommends that qualified wildlife personnel also be HBEB#2—8 consulted. Dead or dying trees may have significant habitat value to the area. Project Fill Material The original project anticipated that fill material would be transported from the Bolsa Chica Mesa on dirt roads between the Mesa and the project site. In the New Alternatives Document, the required dirt volumes for each alternative are presented, but the source of the dirt is not discussed. Since the Bolsa Chica Mesa may not be available for borrow fill material, it appears that the entire dirt would now be imported to the site across City streets. This could result in over 140 truck trips per day traversing to the project site on HBEB#2—9 Graham, and away from the project site along the same street. This would occur over the course of one year. The Board believes that this has the potential for an adverse impact to the exiting traffic circulation in this area. Furthermore, as discussed in the Board's comments on the original EIR, if dirt is obtained from borrow pits on the Mesa, this can adversely impact the natural habitat of that area. The Board request that two items be addressed: 1)the source of the fill dirt be clarified; and, 2) the level of significance of the truck travel impact on the surrounding area be specified. Traffic The Board addressed traffic concerns in its earlier comment letter;however, the importance of this issue makes it worth repeating. We hope to provide here additional focus to our concerns. The proposed project will have only one inlet/outlet onto Graham Street. The Board believes that this project may create an adverse impact on traffic flow leaving the site during peak times, as well as an impact to the entire area. Graham is heavily used in the morning and afternoon because it is one of the major access routes to Marine View Middle School. Traffic regularly backs up over the channel waiting to make the left turn HBEB#2— 10 into the street leading to the school. Also,with the construction of the project,three signals or stop signs will be placed within less than one half mile that will further constrict traffic flow. Furthermore,the intersections of the proposed development to Graham, and Kenilworth to Graham may suffer congestion or safety problems. The proposed development outlet/Graham intersection is on a downward slope of Graham as it crosses over the Wintersburg Channel. The intersection comes into view within a short distance of the intersection leaving little opportunity to see traffic backed up at the intersection. This will create a safety hazard unless the signal is designed correctly allowing visual access for vehicles approaching the hill. Also,the Kenilworth outlet/Graham intersection may also be difficult because of the increased traffic and visual access problems. The Board request clarification of these issues. The Environmental Board appreciates the opportunity to comment on the project. Please contact the undersigned with any questions or comments regarding these comments. HBEB#2 — 11 Sincerely, ENVIRONMENTAL BOARD Frank R. Capon Chairman 7 City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 Attn.: Mary Beth Broeren RE: PARKSIDE ESTATES EIR Since the original EIR was prepared and responded to a number of significant changes have occurred-FEMA flood elevation changes, Court Case decisions with regards to the Bolsa Chica and ESHAS, and the Decision of the Coastal Commission in November TAD—1 2000 with regards to the Bolsa Chica. The following comments related to various segments of the EIR: Flood Control Since this is probably the last project to be built in this area of the lowlands, the new FEMA base elevation requirements can have significant impact upon various properties TAD—2 adjoining the Wintersburg Flood Control Channel. Also, these existing residential developments cannot be retrofitted to meet these elevation requirements. From Exhibit 6b-1 it indicates that in the addition of the vertical channel wall to increase the capacity of the channel, the new wall will extend above the height of the existing berm of flood control channel. This means that the North side of the channel would be higher than the berm on the South side adjacent to existing residences. The channel improvement ends near the County portion of the project and would appear to end near TAD—3 Graham Street. This means that the new homes are protected from floods and that any water than might have spilled over could flow into other residential neighborhoods or open space property. The project itself at whatever elevation greater than the surrounding developments means there is potential that during a major flood event, water that could have spread out on this project will flow to other surrounding properties. In addition to the higher channel elevation, the higher the fill the higher the wall separating the development from the channel. This can give even higher protection of the TAD—4 proposed project and cause any over flow to go away from the project. By comparison, the tract wall on the opposite side of the channel is well down from the top of the berm Of particular concern in connection with the Bolsa Chica. Mesa property at the Coastal Commission hearing was the treatment of storm runoff to assure that the quality of the TAD—5 runoff was improved before it entered into storm drains. Filtration, debris removal, and diversion to sewage treatment were some of the alternatives discussed. Since this project's storm drains enter the channel close to the Bolsa Chica wetlands, this should be I TAD— 5 of major concern. ((cont.) The route of these storm drains crosses over lands not owned by the applicant, so the viability of this project rests on obtaining rights from other including the City of TAD—6 Huntington Beach as owner of the Slater pump station and flood control channel property- Views The views shown do not show the impact of the development on the privacy of the adjoining residential developments to the East or across the channel to the South. The report does show what the families along Kenilworth would see from their own TAD—7 properties looking at the new development. But of concern to the existing residences is the view from the path, roadway and proposed homes into their backyards and residences. Wetlands, Oven Space and ESHAS The open space in the County was designated by the Coastal Commission in November 2000 as Conservation. The buffers proposed are from ESHAS located near the Southerly end of this County portion of the project. One of the significant points addressed at the Coastal Commission meeting was the need to properly buffet coastal land forms and various habitat areas,including eucalyptus trees, from any development. Buffers of up to 100 meters were recommended for protection of these land form and habitat resources. TAD—8 Since several groves of eucalyptus trees are near the Westerly end of the project, these groves should have a buffer of up to 100 meters to protect them from the impacts of development. Like wise the Conservation designated property should have a buffer from its edge to protect it from development. This buffer should be free of streets and other improvements related to the residential development. Lot 113 and other lots along the channel in Alternatives 8 and 9 are to close to the Conservation designated property. The eucalyptus groves in the bluff area should have adequate buffers from the active park I TAD—9 area. An Arborist should not be the person controlling the decision as to whether eucalyptus or other trees within open space or ESHAS should be removed. Dead or dying trees may TAD— 10 have habitat value for these areas. Qualified wildlife agency personnel should make decisions relating to these trees. There are also still significant questions of the prior existence of wetlands within the project area within the City of Huntington Beach. There has been raised the issue of prior converted croplands and these wetlands. But favoring agriculture should not include TAD— 11 favoring development if the owner decides to stop farming and develop the property. It should be viewed in the same manner as a conditional use permit, which allows an activity to continue as long as the permitted activity exists. When it no longer exists, previous conditions relating to its use are reapplied and have to dealt with in connection TAD— 11 with the new use. (cost.) Traffic Graham Street with the construction of this project would have three signals or stop signs within less than half a mile. There are few areas in highly developed areas of the City TAD— 12 where this type of traffic control is required. The proposed intersection is on the downward slope of Graham Street as it crosses over the Wintersburg Channel. The intersection only comes into view within a short distance of the intersection. There is little opportunity to see traffic backed up at the intersection TAD—13 regardless of whether it is green or red. The signal would have to be high enough to be seen from the other side of the channel. Graham Street is heavily used in the morning and afternoon because it is one of the major access streets to Marine View Middle School. Traffic regularly backs up over the TAD— 14 channel waiting to make the left turn into the street leading to the school. Access out of Kenilworth would be impacted because of the signal stopping traffic at the opening of Kenilworth at Graham Street. It would be particularly difficult to turn left on TAD—15 to Graham Street between the West bound traffic and to see any East bound traffic. During the construction of the project, major impacts would occur due to the large number of vehicles accessing the project at the same time as children are either being TAD— 16 dropped off or picked up from school. Sincerely, Terry A. Dolton 17692 Shoreham Lane Huntington Beach, CA 92648 8 -J ' THOMA.S B. MATFIEWS U` = County o,f Orange DIMC11OR ]00 N, ri oviER ST. in Plann & Development Services Department SANTA ANA.CALIFORNIA °�lfio4� g evelo P MAILINO ADDF,05: P O. BOX 404S SANTA ANA.CA 92702AO42 NCL 01-53 August10,2001 Mary Beth Broeren City of Huntington Beach Planning Department Huntington Beach, CA 92648 SUBJECT:New Alternative to the Draft.EIR for Parkside Estate Project Dear Ms. Broeren: The above referenced item is the New Alternative to the previously circulated Draft Environmental Impact Report(EIR)for the subject project. The project site is located on approximately 49 acres west of Graham Street,north of the East Garden Grove-Wintersburg OCPD#2— 1 Channel and south of Warner Avenue.The four new alternatives incorporate a reduced density concept and.new flood plain information and analysis. The county of Orange has reviewed the New Alternatives and offers the following comments: FLOOD 1. The"Drainage/Hydrology"sections of the alternative discussions indicate that there is a zero(0)to negligible increase in water surface elevation from the project because the "drainage improvements(shown in Exhibit 58)to be made as conditions of development more than make up for displacement by fill of storage volume on the project site and closure of the connection to Bolsa Chica lowlands draining the property to the west." This statement seems to imply that the only water surface impacts that were studied were OCPD#2—2 due to the placement of fill material and closure of the connection to Bolsa Chica lowlands. Since development of the property,construction of new drainage improvements,and upgrading the pumping capacity of Slater Pump Station will all incrcase the amount of runoff that is delivered to East Garden Grove-Wintersburg Channel(C05),the impact on the downstream reaches of C05 must be discussed. If the project causes an adverse impact on C05,then the Elk must discuss what mitigation measures are proposed to offset the impact. 2. The attached letter from Herb Nakasone,Manager,.PFRD/Program Development OCPD#2—3 Division outlines the Orange County Flood Coatml District's(OCFCD)position that the t Conditional Letter of Map Revision prepared by the project proponent needs to be signed off by the City of Huntington Beach. The new hydrology used for the CLOMR needs to 0CP0#2—3 be approved by FEMA as the County of Orange already has approved hydrology for the cont.) C05 channel system. 3. PFRD review and approval is needed for any proposed improvements to C05. OCPD#2-4 Encroachment permits will be required for any work within OCFCD right-of-way. 4. Levee certification from FEMA will be required for any portions of the levee that are OOCPD#2-5 improved as apart of the project. WATER QUALITY 5. The comments provided in our prior comment letter(October 15, 1997),have not been addressed within the revised document. Therefore the DEIR still needs to examine the following: a) Existing conditions of Receiving Waters as identified in the Water Quality Control Plan—Santa Ana Basin(Basin Plan),with its goals and objectives for surface water quality; b) Water quality impairments in the downstream receiving waters, as reflected in the Clean Water Act 303(d)list and the 1998 California Water Quality Assessment Report,notably the impairments within the Huntington Harbor complex. CPD#2-6 c) The potential surface water quality impacts of the project including but not limited to:construction activities,long-term runoff impacts of new impervious surfaces,pesticides and fertilizers applied to landscaping,future spills from accidents and/or improper business management of chemicals, as they relate to a. and b.; and d) Mitigations for project water quality impacts,which should include: 1) Preparation of a construction Stormwater Pollution Prevention Plan under State NPDES requirements; 2) Development of a long-term post-construction water quality management plan,describing commitments to installation and maintenance of structural facilities and conduct of non-structural Best Management Practices (BMPs) consistent with the DAMP New Development Appendix. Given the size of the development,the need for the incorporation of"special' structural BMPs,as defined in the Countywide Drainage Area Management Plan(DAMP) should OCPD#2 —7 be evaluated with respect to the size and nature of the development and the proximity to a waterbody. 2 This consideration could include the following resource documents: a) Incorporation of Federal FPA/NOAA guidance measures for coastal,nonpoint source pollution; OCPD#2—7 (cont.) b) Incorporation of measures from the State Municipal BMP Manual.; e) Incorporation of other measures from the State Urban Runoff Technical Advisory Committee Report and Recommendations; Furthermore,Alternatives 6-9 all include a basic statement that the":alternative would result in increased surface water.runoff duc to the covering of surface soils with impermeable structures and surfaces..."yet the mitigation.measures cited on page 8-15 OCPD#2-8 only include storm drain improvements(#1),the submittal of proof of an NOI(#2)and a water quaJ.ity management plan(0). It is recommended instead that the DEIR be revised to List the routine BMPs from the DAMP,assess the known effectiveness of each,address which pollutants may be expected to be reduced below a level of significance by incorporation of that measure, OCPD#2—9 and then assess whether the measures together would likely reduce alJ potential surface water quality-related impacts to a level of insignificance or whether additional "special" BMPs(as defined in the DAMP Appendix G)would be required. OPEN SPACE/RECREATION 6, Exhibit 5b,Conceptual Trails and Bike Path;we recommend this exhibit be renamed "Conceptual Trails and Bikeways". Moreover,the Legend should clearly differentiate OCPD#2—10 between proposed trail and bikeways. 7. Exhibit 6c, Site Cross Sections, Section"O"-"O";subject section should revise the"Class �OCPD#2—11 I Bike Trail"to correctly read"Class I Bikeway". 8. Page 8-9,Aesthetics Mitigation Measure#4;please revise to read as follows: "Prior to approval of building permits,the applicant shall submit a bikeway plan OCPD#2—12 to the City of Huntington Beach Planning Department,in consultation with the Manager,County,PFRD/HBP Program Management&Coordination,for approval of consistency with the Orange County Bikeway Plan." 9. The regional Class I(paved off.-road)bikeway along the Wintersburg Channel is included in.the Commuter Bikeways Strategic Plan for Orange County. We recommend that the OCPD#2—13 bikeway be discussed in the Recreation and/or Transportation sections. 10.The project should be conditioned to design and build the regional bikeway. This would IOCPD#2— 14 include providing at least 16 feet of width for the bikeway (this includes clearance on each side of the bikeway tread). 3 11. A setback for landscaping should be provided between the regional bikeway and any fencing or wall along the bikeway. Otherwise,bikeway users would sec only the asphalt bikeway and a long,high,straight wall,with no greenery. Furthermore,walls with no OCPD#2-15 landscaping invite graffiti. 12. we recommend Class I bikeway,linkages to Graham Street be addressed in the subject `OCPD#2 —16 New Alternatives document. 13. A metal handrail may be required on the channel side of the bikcway. Contact Gene Holum of PFRD(714) 567-6243.regarding this. Also, any drainage ditch or. swale OCPD#2—17 proposed to be parallel to the bikeway should be located outside the clearance area of the bikeway. CULTURAL RESOURCES 14. We encourage the City of Huntington Beach to follow the Board of Supervisors example in determining that cultural resource artifacts found during the development of the site should be donated to a suitable repository that will,maintain the eollectiov for future OCPD#2 — 18 scientific study and exhibition within Orange County. Donated finds should be prepared to the point of identification. 15. The project proponent should be prepared to pay potential curation fees to the County or other suitable.repository for the long-term curation and maintenance of the artifacts. OCPD#2—19 WASTE MANAGEMENT 16. The California Integrated Waste Management Board requires that ail counties have an approved Countywide Integrated Waste Management Plan (CIWMP). To be approved,the CIWMP must demonstrate sufficient solid waste disposal capacity for at least fifteen years, or identify additional available capacity outside of the county's jurisdiction. Orange County's CTWMP,approved in 1996,contains future solid waste disposal demand based on the County population projections previously adopted by the Board of Supervisors.TWMD's database shows that the Orange County landfill system has capacity in excess of thirty(30) years. This is well above the fifteen-year threshold established by the California Integrated Waste Management Board. OCPD#2—20 The County of Orange owns and operates three active landfills. The Frank R. Bowerman Landfill is the closest facility to the project, and will likely be the solid waste facility receiving the waste. Notwithstanding, the City of Huntington Beach is under contract to IWMD to commit all of its waste to the County landfill system (not to a particular facility) until the year 2007. At the same time,the landfill system is accepting additional waste from outside Orange County. Under these circumstances, it has been agreed that should the cumulative effect of development cause the daily tonnage ceiling of a particular facility to be exceeded, the waste being imported to that facility will be reduced by a corresponding amount. Consequently, it may lie assumed that adequate capacity for the subject project is available for the foreseeable future. 4 Notwithstanding the availability of landfill capacity in the County system,the State of California has required that by the start of this year,each city and county demonstrate a ,reduction of at least 50%in the amount of waste from that jurisdiction that had gone into landfills in the year 1990. Also,the State requires that this level of reduction be sustained in perpetuity. Waste.haulers are expected to contribute by recycling residential. and commercial waste they have collccted,and project developers are expected to employ measures to reduce the amount of construction-generated waste.IWMD OCPD#2—20 reconunends that the project developer contact the city recycling coordinator to ensure (font.) that the proposed project is in compliance with the city's program. At this time, IWMD does not have information on solid waste generation rates in Orange County. Any questions about solid waste generation rates should be forwarded to the California Integrated Waste Management Board in Sacramento, Further information about the County of Orange landfills can be accessed at httJ2Wwww.oc.ca.aov/iwmd If you have any questions regarding waste management, Tony Deconinck can be reached by email at any. oninck@o.iwmd.ocgov.com, or by phone at(714)834-4107. Thank you for the opportunity to respond the proposed new alternatives. Please send one complete set of the DEIR to me at the above address when it becomes available. If you have OCPD#2—21 any questions,please contact me or feel free to call Grace Fong directly. Grace may be reached at(714)834-2708. Very truly yours, 496 Ocorgc Vnfton,Manager Environmental.and Project Planning Services Division Attachment 5 t , VI L Mon,1)kma. it o COUNT?" O 7 ORANGE 300 �C& PA.B=4048 V o P Soon Aea,CA 9=-4048PUBLIC FACILITIES RESOURCES D ter EPART1�fE1VT ��lPoB� TekpBow (714)834-23M Faye (714)834-5188 dot ii Ronald C. Metzler Vice President, Planning and Development SHEA HOMES P. O. Box 1509 Brea, CA 92822-1509 Subject: Parkside Estates-Tentative Tracts 15377 and 15419 (Huntington Beach) Dear Mr. Metzler: The following is in response to your letter dated July 3.2001 and our meeting on the same date. Your letter requests two things: 1)my signature on FEMA Form 81-89 and 2)our approval of the CLOMR hydrology. Regarding item 1. per FEW$own instructions, "if more than one community is affected by the change,the community official from the community most affected should sign the form and letters from the other affected communities should be enclosed." Since unincorporated County areas are not affected by the subject floodplain study,only the City of Huntington Beach is affected. Thus,we believe that only the community official from the city needs to sign the form. This letter is intended to serve as our response for attachment to the form signed by the city. Regarding item 2,we believe that since the County of Orange already has approved hydrology for floodplain purposes,any changes to the defined floodplain caused by deviations from the already approved hydrology needs to be approved by FEMA. Please note that although we have neither reviewed nor approved the hydrology and hydraurics for the CLOMR submitted by your firm,we will accept the decision made by FEMA on your submittal. "if you have questions regarding the above, please do not hesitate to contact me at (714)$34-3719. Since , H. a no, anager. P m Development Division KW-.c&pwW05&20015M 0T1301Pa MiftEslatm cc: Robert F. Beardsley, Huntington Beach Director of Public Works 9 -� Jai 0 sa L A- N D T R U S T August 12, 2001 OFFICERS Sandra Thornton, Project Planner City of Huntington Beach Planning Department EVAN HENRY 2000 Main Street PRESIDENT Huntington Beach, CA 92648 STAN KRUTSICK VICE PRESIDENT Re: New Alternatives to the Draft Environmental Impact Report No. 97-2 For The MARINKA HORACK Parkside Estates Project SECRETARY NANCY DONAVEN Dear Ms. Thornton, TREASURER Thank you for the opportunity to comment on the above referenced EIR. Bolsa Chica Land Trust has submitted previous comments to Draft EIR No. 97-2.We BCLT#2- I would like to make the following comments: BOARD OF DIRECTORS 1. The New Alternatives document, if it is a"Recirculated Draft EIR", should CONNIE BOARDMAN contain the previous EIR as well, as was done with the Draft Bolsa Chica EIR DEBBIE COOK NANCY DONAVEN when it was recirculated in 1996(The 1996 Draft Bolsa Chica EIR was SANDI GENIS recirculated because of a public noticing provision relating to the tidal inlet). The MARINKA HORACK public who is now reviewing the"New Alternatives"does not have an up to date FLOSSIE HORGAN document to review, even though much has changed from 3 years ago when BCLT#2 —2 PAUL HORGAN comments on Draft EIR 97-2 were submitted, June 15, 1998. The whole EIR STAN KRUTSICK should be art of one package that is recirculated. The New Alternatives is not a GENE MATHIOWETZ P P 9 LAURA MATHIOWETZ stand-alone document because it was developed, in part, from the old EIR, as KAREN MERICKEL indicated in the Background Section, 1.3 on page 1-2. This old EIR is now dated, EILEEN MURPHY because of new information. JOELSHELDON JAN VANDERSLOOT,MD 2 public Notice is deficient, as the public does not have the opportunity to review all the issues in Draft EIR 97-2. The public is now only allowed to comment on the New Alternatives, not the other issues, including other Alternatives, Environmental Assessments, Land Use, Aesthetics/Light and Glare, BCLT#2—3 Transportation/Circulation,Air Quality, Noise, Earth Resources, Drainage/Hydrology, Biological Resources, Cultural Resources, Public Services and Utilities that are not provided in Draft EIR 97-2. 3. New information includes the appellate court decision on April 16, 1999. This decision was important, not only because it did not allow incompatible gCLT#2—4 development in an ESHA in the Coastal Zone(Section 30240 of the California Coastal Act)but it also did not allow incompatible development in a coastal LOCAL ENDORSEMENTS: GARDEN GROVE EDUCATION ASSOCIATION, 0 HUNTINGTON BEACH TOMORROW,ORANGE COAST LEAGUE OF WOMEN VOTERS NATIONAL ENDORSEMENTS: THE IZAAK WALTON LEAGUE,THE NATIONAL AUDUBON SOCIETY, THE NATURE CONSERVANCY,SIERRA CLUB,SURFRIDER FOUNDATION r L A N D T R U S T wetland (Section 30233). This would impact the Shea property because evidence BCLT#2—4 exists that there are more wetlands on the Shea property than are delineated in the Draft EIR or the New Alternatives. (coat.) OFFICERS EVAN HENRY 4. New information also includes more evidence of water ponding on the property PRESIDENT after rainfall. Enclosed are photographs taken on January 31, 2001, showing how STAN KRUTSICK water ponds in the same areas as were shown in photographs submitted by VICE PRESIDENT Bolsa Chica Land Trust Board Member Jan Vandersloot in his comments to the MARINKA HORACK 97-2 EIR.Additional serial photographs of the water ponding on the Shea SECRETARY property with dates of March 14, 2001, March 18,2001, March 23,2001, March NANCY DONAVEN 25, 2001, and March 28,2001 are enclosed. These should be correlated with TREASURER rainfall records to confirm that water ponds on the property for more than 15 days, confirming the water criteria for delineation of the property as a wetland. In BCLT#2—5 addition, Bolsa Chica Land Trust submitted a letter to the City of Huntington Beach dated October 12, 1999, enclosed, addressing this issue. The basic concept of using state standards for wetland delineation, rather than federal BOARD OF DIRECTORS standards, is key, as state standards require only one parameter of wetlands CONNIEBOARDMAN delineation, rather than three parameters required for federal delineation, namely DEBBIE COOK water, vegetation, and hydric soils.An alternative that avoids the wetland areas NANCY SANDI G NIS depicted b thephotographs and submitted evidence should be resented as a SANDI GE1�rIS P� Y p MARINKA HORACK New Alternative. FLOSSIE HORGAN PAUL HORGAN 5. A New Alternative that not only leaves the project area as open space, but STAN KRUTSICK GENE MATHIOWETZ also restores it as a wetland, including use as a detention basin, should be LAURA MATHIOWETZ included in the EIR. This possibility was raised by the United States Fish and BCLT#2—6 KAREN MERICKEL Wildlife Service in two letters dated October 16, 1997 and June 15, 1998, EILEEN MURPHY attached.The sections mentioning this issue are underlined. JOELSHELDON JAN VANDERSLOOT,MD 6. Other new information includes correspondence gleaned from a FOIA request from the Army Corps of Engineers, attached, including dates of 2126/98, 4/30/98, 5/1/98, 6/16/98, 6/19/98, 8/31/98, 5/7/9, and 22 July 1999 from the EPA that should be included in the EIR.Any regulatory actions taken after the last Draft EIR Comment Period, which ended June 15, 1998, should be included. Included in these documents are issues with the property requiring a Section 10 Permit BCLT#2—7 from the Army Corps of Engineers and issues raised by ponding, plus use by migratory birds. Attached is a map depicting a tidal slough running through the Shea property in 1873, submitted May 7, 1999. Use of the property by migratory birds is confirmed by photographs previously submitted in June 1998 showing Canada Geese using the property. These issues concern status of the property as wetlands, even though they may be deemed prior converted croplands from a �I LOCAL ENDORSEMENTS: GARDEN GROVE EDUCATION ASSOCIATION, HUNTINGTON BEACH TOMORROW,ORANGE COAST LEAGUE OF WOMEN VOTERS NATIONAL ENDORSEMENTS: THE IZAAK WALTON LEAGUE,THE NATIONAL AUDUBON SOCIETY. THE NATURE CONSERVANCY,SIERRA CLUB,SURFRIDER FOUNDATION 2 ='ter 0 sa L A N D T R U S T federal standpoint, because they indicate probable wetlands by state standards, BCLT#2-7 protected by the State Coastal Act Section 30233. 1(cont.) OFFICERS 7.At recent public meetings on June 20, 2001 and July 19, 2001, the property EVAN HENRY owner expressed his willingness to be a seller of the property, a so-called'willing PRESIDENT seller".Analysis of a New Alternative that might attract a suitable buyer of the STAN KRUTSICK property should be included in the EIR.This alternative would be one showing VICEPRMDENT how the property could function as a detention basin as outlined by the USFWS MARINKA HORACK letters of October 16, 1997, and June 15, 1998, attached. This detention basin BCLT#2-8 SECRETARY would be vegetated with wetland vegetation, restoring it to its former wetlands NANCY DONAVEN condition, by allowing water to enter it in a controlled fashion from the TREASURER Wintersburg flood control channel. This alternative would be a proper response to the USFWS who requested it, but it has not been offered in the Draft EIR. Potential agencies interested in a buyout of the property might include the USFWS, FEMA, OC Flood Control, Caltrans(as a mitigation site), the Coastal Conservancy, and Southern California Wetlands Recovery Project. BOARD OF DIRECTORS CONNIE BOARDMAN 8.The New Alternatives document does not discuss the ramifications of the DEBBIE COOK Bolsa Fairview earthquake fault that traverses the property, a former tidal slough, NANCY DONAVEN on the developments described in the New Alternatives. This would make BCLT#2-9 SANDI GENTS MARINKA HORACK hazardous any fill in the property,which would be subject to liquefaction and FLOSSIE HORGAN subsidence in the case of an earthquake. PAUL HORGAN STAN KRUTSICK 9, Bolsa Chica Land Trust has concerns that traffic circulation and flood control GENEMATHIOWETZ LAURA MATHIOW&= alternatives have not been adequately addressed in the EIR. In particular,there ETZ KAREN MERICKEL is only one entrance to the project at Graham, and only one side of the BCLT#2- 10 EILEEN MURPHY Wintersburg Flood Control is being raised. This could raise a dangerous situation JOEL SHELDON for the residents of the south side of the channel in case of a flood. Flood waters JAN VANDERSLOOT,MD would tend to spill into that Neighborhood. 9.The New Alternatives should include the Response to Comments for Draft EIR 97-2 for public review. Clearly the preparers of the New Alternatives used BCLT#2- 11 comments from this draft to prepare the New Alternatives document. The public should have access to these documents as well. 10. New people have come into the area or have become aware of this issue since the last EIR 97-2 was closed to public comment on June 15, 1998, over 3 BCLT#2- 12 years ago. These new public are now not allowed to comment on any of the issues except the New Alternatives. This is essentially unfair.The whole LOCAL ENDORSEMENTS: GARDEN GROVE EDUCATION ASSOCIATION, V HUNTINGTON BEACH TOMORROW,ORANGE COAST LEAGUE OF WOMEN VOTERS NATIONAL ENDORSEMENTS: THE IZAAK WALTON LEAGUE,THE NATIONAL AUDUBON SOCIETY, THE NATURE CONSERVANCY,SIERRA CLUB,SURFRIDER FOUNDATION 0 sa L A N D T R U S T document should be opened up for anyone to comment on, regardless of where BCLT#2— 12 they were 3 years ago. I(font.) OFFJCERS Thank you for the opportunity to comment. EVAN HENRY PRESIDENT STAN KRUTSICK I rely, VICE PRESIDENT MARINKA HORACK .� SECRETARY cy aVen NANCY DONAVEN Treasurer and Past President TREASURER Bolsa Chica Land Trust Attachments BOARD OF DIRECTORS CONNIE BOARDMAN DEBBIE COOK NANCY DONAVEN SANDI GENIS MARINKA HORACK FLOSSIE HORGAN PAUL HORGAN STAN KRUTSICK GENE MATHIOWE7Z LAURA MATHIOWETZ KAREN MERICKEL EILEEN MURPHY JOEL SHEL.DON JAN VANDERSLOOT,MD LOCAL ENDORSEMENTS: GARDEN GROVE EDUCATION ASSOCIATION, V HUNTINGTON BEACH TOMORROW,ORANGE COAST LEAGUE OF WOMEN VOTERS NATIONAL ENDORSEMENTS: THE IZAAK WALTON LEAGUE,THE NATIONAL AUDUBON SOCIETY,' THE NATURE CONSERVANCY,SIERRA CLUB,SURFRIDER FOUNDATION y . � 2\ ^ ( - 7 \ \ / \ 3 it , y 6 . \` , \ . � ' Yv i I , y: i' pp7 1 {t fit. t IF r ` t •� X • r � � � ,�\y � . � "\ ! . , . . ' G \\: /\7/¥� At 4� 2\\ � ,:�. v , b.�p '�: `\ .. {� � _ b � !�d V r ,f_Z ._�6�i r111 't. N ,:i �C l' v�3r -i1:'.I v j.. �5..� e i 4y3 ,� '' W 9' ' � '� Y 11:'� � t��MJ; A � � t X " yt�'` ��G � , `�� / C,.y.,�kny. t"' I, .�f� 's� y� iyd I' J •S .:1'��:' ..,� w ti t poll , Y f a Y- r • Y l (nvcnwgr[. -�t-�ivaHl� v - �a * Ro, n °y'"1 n. ref t 3a - 1 n '�y*,tix »fig Mt+w- Y Y: T �- 'S !J i; ,Mt A 1`�' .i tl��` ♦ �.w� 1 � }�1 � I' 1 �\ •�. - • LA N D T R U S T 0MCF:ItS PAUL HORGAN PMMDF.%7 JUANA MUELI.Ett ME'PN3rDFNr October 12, 1999 MARINKA HORACK stcampy NANCYDONAVEN Howard Zelevsky r>tWVRO Secretary, Subdivision Committee aOAaDOFDIRDclM City of Huntington Beach CONNIEBOARDMAN 2000 Main Street &%NM GEM Huntington Beach, CA 92648 MARINKA HORACK STAN KRVMt= BUCICMAFtRB.PHD Re: Item No.1, Tentative Tract Map No. 15377 (Parkside Estates/Shea) KAM MOUMEL Item No.2, Tentative Tract Map No. 15419 (ParksideEstates/Shea) V&s�o:1 Meeting of Subdivision Committee October 13, 1999 WS Wcu.t MS ROOM WVICHlUL,F'HD JANVANDBRSL=.MD Dear Mr. Zelevsky, AVVZR x CavNciat. Bolsa Chica Land Trust wishes to comment on the above matters. RAMM�AY�OR I. Tentative Tract Map No. 15377, within the City of Huntington Beach MJNTINGTON BEACH boundaries. This area has a delineated wetland by the EPA, 1989, SV MTM BARSARA BOXER JANKS1.IDB.L000.CEO approximately 8.3 acres. Other areas may also qualify for wetland XILLOOO SUPPL.Y M status using State Coastal Commission standards, including a 3.3 acre viNCR KONTNY,(RM v.&FURCORPOWMN area identified by Feldmeth, 1991, areas identified by the Scott White WALMM W.NBC,DIRE+CTOR report, 1998, and areas identified by Bolsa Chica Land Trust by EXTOWAL.ANAIRS.ARCO ROBWSMTOH, photographs submitted with the Parkside/Shea Draft EIR No. 97-2 in WNSULTANT 1998. Also, the 1.5 acre area identified by the Section 10 Rivers and FAsr rRESMOM Harbors Act permit as being tidelands also may qualify for wetland N&VYDpMM.1"&19" status using State standards of hydrology, wetland indicator C01*4MBOARD&I"I"449% vegetation, or hydric soils. Bolsa Chica Land Trust finds it inappropriate F•LOSSI$HORGAN.1992-1994 that houses are proposed for these areas, and perhaps others that show wetlands by State standards, because houses are not allowed by Coastal Act Section 30233 to be built in coastal wetlands, as confirmed by the California Appellate Court, 1999. The Tract map should show these areas with an appropriate buffer, such as 100 meters, as recommended by the USFWS, 1979, and the Department of Fish and LOCAL GARDEN GROVE£DUCATM ASSOCIAT104, F WN77MOlM R&MZ TOMORROW,ORANGE COAST LEAGUE OF WGNMN VC"7AS NATMW4 L TM VA"WALTON LFsAGIJB.7M NATIONAL AMIMN SOClI W THE NATURE CONSERVANCY.SrO ACLUB.SURMrAR POUNDAnION 0 207 21 ST STREET • HUN'TINGTON BEACH • CALIFORNIA 92648 (714) 960-9939 HB Subdivision Subcommittee 1 to 0 it n •r n a a a N a a:tr►) P' a in wv.H A tj a g m m n n n ttl a . ttf to 11 ti-! to 111 w tit N n n ►i►e A .Nt 0 � 0 rt n ►t t It 01'< :r.f•tl A q tt to Ih v w A tr•r 0 ►1 th A 11 ro n tr A 0 A' p C)► .cI ?0 cLc, tt r•i It A iLn A P•r1 n 61 a ►h Ira W tt rt � ;t r! W N p.0 rnl• A w 11 •• q 1,n >< _ • to rt ►••!f it to 1: Ithf it 1) rt ►• it u rt ro O rt WA ►1 cr it H/••ro n A A H r1 c,tti O n a /••n A :ra a a :1 ;1 11 in 11 0 If tt a O 11 It• •< 1 a U HO 11 ro II Ihth 1n N• G HAAWanA roc11c10pn < 11. 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[1 0 U 14 glIS1: 0410N rlr41 gt� �roy00.t: t: ►1U UU it U ,i, Hl 0•ll (4 t td ;C (lr b U ' rWW=rays United States Department of the Interior FISHAND WILDLIFE SOMM Eoolo�w seavfas W*ad Field oSia 2M Lcka AM►MW%" CartsW,Csaifoosaia 9M JJN 15 1.998 Nt flames Barnes,Project Planner Department of Cormnuafty LVftlopoX= City of Hu ntin&=Beach 2WO Main Street Htmhvm Beach,G 92648 Re:Comments on Draft Fmtiiroammtsl.Impact Report No.97 2 for the Sbea Hnmes Pmksi& _ Estates Subdivision Dew I&Bs=w. The Fish aid wild M Service(Scrvim)has ivdawed do rrf===d do==nt and *9 following commeuta_ ?hoc Service is a Federal agency with expertise is fish and WHdUc habitatt evalustioa and mitigation and a long history of involvement in the fish and wdldtifc issues of Bolts China amd the.City of Hmdtingtnn Rraclt. we we one of time agencies imp1menfing$e Balsa Chic a Lowland Restoration Project on SWe-own+od property immediately 8480mt to 9 st�j�PmP�Y• . The Service bad provided a rtaponse,dated October 16,1997,an the Notice of Plepatsdm fat ' thin project,yet we-do not find ti,a the issues we identified have berg addressed in this dad FJR. We beii=that the subject draft EavaoaasesZtal Impact Repoli(MR)needs Cad¢aye .------cment in the following awns:tine nau=and cat---offinds an the pc*Mty� ah;rnadvcs to avoid or=tome wetiaads impacts on the property,and the rel p-of ate proposed plan to the Bola China Mat development plan,the lowland resmrsdon plan and flood chaand impruvcarwIt plans. The actw►t urine imd cc=of wcd=&en rise site continues to be somswhat in dsspume. It is . otrf Undersunding thst the Corps of Fngineers has get to confirm wbetha the"sea oaai pond"is under ked=a1jmwd=txm pu mont to Section 4(9 of the eau water ACt,or not history indicates that there is a rettular occunrnce of ponditmg and wet soil conditions,as a+eII as ftup tt dimabmee,such as discing. Evidently an obvious and recurred seasonal pond cdsb an the me on the a •end o.the p:opexty,which would seem to qualify as a under the California Coastal AcL If th:s seasonal pond we=not f%pm=ily mod,it ProbfY waddd exhibit other c of wetlands than just pondW warty,such as hydmphytie ycgetaiioat, bydrie soils,and aquatic organisms. Tbesefore,we recommend that the pr+oponew sad the City of H=tizvon Beach should consider"environmentaW pmfemble Alternatives such ss protectma die seasonal pond in place,by roduoing the devologmtnt food an the w_cA"n lied of the property. The dEM{pages 5-160&S-163)identifies proposed mitigRdctn of t'he aeknimiedged wedmds on the"County Parisi'as 4:1 mitigation within the Bolsa Chica Lowlands or an alternative site would be fouad. We recommend that this proposal be cunsi k=d as inadogaate,since 111 c proponent dots not have any evident con.--u==from any other Landowner that they may mitigate any wetland impacts in the Bolsa Carta Lowland. No o$site mitigation opport mity is UPP=WL We recomvcead the dEM include a diseussiem of wetland mitigation measures for all of the`we-lawr areas of the property. We further reoomnnend tbat the mitigation measum be a site specific and sttfficiendiy deudled w alluw the reader and A C=sMcrs to cva1900 Ow aliowab:eness and fcasibility of the proposed measures. The dEiR dis=tim of"Restb+ ce includes a discussion of trail alignments. ExIdU 25,page 5-4k shows an`interpretive:hail"and a class I bicycle trail along the edge of the s*ed propetty but wend mg into the Buba Cluea Wwlan & This figure ud=that the dEM p mpatmt considered the now defimct loll development plan to be relevant. In acbmbty,the pacopoaod trails may not ever exist in the forur shown on thst figure.(Our wedand sestossUon pica dEM IS will include Mternx ve trait align meaU on the State property later this year) The proponent appears to be proposing a dead-end interpretive trail sandwiched bdween a concur vertical wall biW d-n-W and perimeter wall at the back of the houm(Exhibit 6b,cross section AA,pap 3-9). We montmead that aheonfive trail alignments be considered at the west cod of&& subj ect property that would connect through the proponcofs pr+ope rty to the private IMPM9# bicycle trails,gad scenic route to the northwest of the subiect property,ndw than enW or ddrt the wrtlands of the lowLm& The trail alignment along the soutbady boundary of the p oponates pzcpaty dwuld aLso be vonski ted for a widened,landscaped 4esmnmt,name along$e Now of a "green wq'tbam a concrete chore and preferably localed on the proponent',prvpedy,lather than on the flood ebamd ed jp. Alteraalive uses for the 4.9-acre pared within County j=sdicdon sbould be aonadewd ti= would avoid houses jutting furdmw into the lowland area curreadiy being planned for restorx6cm and long-term conservation of fish and wildlife. This action would appear to allow for a scenic, nab ally landscaped(nonudal wetland and upland babiut restoration),gram WNY tuu+r.-Cliou to the proposed"taew community part/and further bmfhr the wett=d area from uftui*g influences. This action could even incorporate an it mpredve flmcdc o. As a preliminary part of the engineering analysis for out wretland restoration project,the Service is evaluating the East Garden Gmyo Wttstrssbwrg flood Lh uml fuuctious and madaquscim We are fmciincg than with some alternatives es for' m ' the flood channel 25!!Et to h odle the year flood,a de=tion basin would be necessary to avoid basing to make iinpr+ove ments to the Warner Avenue connection bem-mn niter Rolca Baby and HundqMn Harbour. Itz subject property may be considered an excellent location for such a detention basin. We rccomn=d that the MCMUMM au evaluation of the ahcmaaives for addressing this aeanoa of flood sin=their action may foreclose implernentation of otherwrse ftasible vet for solving existing Uzew Of storm vMw damage. Also as part of our preliminary analysis for our v mtland restoration 1rOjeM tlae Service has reoeived informadca from County agem6ec regarding the cragitg and coasZittmm of ttmoffia the arcs of this proposed project Some potential problems are bein;noted that probably odgiaate with suret and yard runoff. Fur==upla,high total coEiform counts have been detocted is the wetwell of the Slater pump station,large amounts of trash and urbm debris deposit in the flood channel. The proposed project$fitly would iacr=meutally co=ftze to these problems We recomnscad a dismissicm nf these.problems and measum tbaxthe proponent may implenumt to avoid i=mneatal degradation,such as Best Maztagem nt Practices,grease maps,gad vegetated swales/deamtku bmium. We look forward to vvoddng with the City of Hu=ngton Bewb and the p vpamettt on dds Im+ject. We are paeticulariy intererted in aspects to the subject project that rosy impinge on rile wetland restoration project that are are evahmdng. Please refer any question to Jade Fancbw of this offi=at(760)431-M& Ile' Sinastll, . . A EWdd Aubt=L Fiat Sgaviaoc To: Mark DurboRxJ From: Daniel j kstraGOCOM originated by: Daniel J kstraeOCeSPD Cr-: Bcc: Subject: fwd: Fenton Salt ponds Attachment: Date: 2/26/98 11:53 AM 7'ais should do it. I'm still thinking about David's question on how long a pond needs to be there. I will get back oin that next week. Dan Original text From: Daniel J Dykstra@OC®SPD, on 2/17/98 2:04 PM: To: David A ZoutendykQCOFQSPL, John M GleasonQOC@SPL, Mark DurhamaCOSSPL, Richard J Schubel@COGSPL Cc: Wade L Bakle@COOSPD Gentlemen, this is a follow up to our conversation of last week. concerning the assertion of jurisdiction over salt ponds which have been diked off from the ebb and flow of the tide since at least before the passage of the Federal Water Pollution Control Act of 1972. As I indicated if that area would still be subject to the ebb and flow of the tide in its ordinary and natural state, then we can assert Section 10 Jurisdiction even if the area is now dry. Similarly, even if it is not' subject to the ebb and flow of the 1-tide in its ordinary and natural state because of man's activities, but .tfcontains ponded water for some reasonable period of time and those ponds are .; used by migratory birds, the waters are tens of the US subject to 404 (- " ?f/a) jurisdiction. the question I did not answer at that time is how do we treat f areas that are behind dikes that are no longer subject to the ebb and flow the tide because of fill which was placed there at some point in the .St. (Presumably lawfully because we weren't regulating such activities way back when.) For purposes of this question as I understood it, but for. the fill the area would have been subject to the ebb and flow of the tide in its ordinary and natural state. In this situation, San Francisco District, back in the 70's issued a public notice which stated that for filled areas which were currently above mean high tide they would�6' assert , jurisdiction. Thus any fill placed after that point would require a permit if in its ordinary and natural state would have been subject to the ebb and ;2flow of the tide but areas all ready fill were not going to be regulated. This decision excused (if that is the right phrase) the District from regulating down town San Francisco. So if the ponds in question have been filled over time so that they are above mean high water I would probably not try to assert Section 10 jurisdiction especially if you can assert 404 '.. jurisdiction because of either wetland characteristics or pondi.ng plus use by migratory birds or some- other basis for interstate commerce. (In a recent Bench decision in_ the Northern District Judge Legge found very persuasive evidence of use by migratory birds a video of our feathered friends.) Dan To: smtp(Yocom.Thosra.. . panail.*Pa.goVJ From: Eric D SteinoCO Cc: Mark Durham@Co,smtp(jack_fancherOfws.govj Bcc: Bruce A HendersonOCOF Subject: tachment: Date: 4/30/98 4:26 PM . Tam, Thanks for you email regarding the Shea Homes site. We are in the process of re-examining the PC call on the site by reviewing recent aerial photos etc. The Wintersberg Channel has obviously eliminated tidal influence to the site, but if ppt and urban runoff provide sufficient hydrology to allow hydrophytic vegetation to grow when the area is not disked, I think we would need to re-look at the PC call. However, in the absence of evidence that there is adequate hydrology on the site under current circumstances, we would probably stick with the old call. Having said that, it is quite . possible that the ulitimate call will need to be made by MRCS, but I have yet to discuss this with them. Regarding Section 10 jurisdiction. I would say the the Wintersberg Channel has not only eliminated tidal influence on the site, but also made it unlikely that the site could be restored to tidal influence. Therefore, at this point I do not believe the Corps would take Section 10 jurisdiction over this area. Let me know if you want to discuss. :*sss•ss:ssssesssssssss:sssssssss*ssssssssssssssssss. Eric D. Stein U.S. Army Corps of Engineers Los Angeles District, Regulatory Branch esteinispl.usace.ar=y.ail. 213-452-3415 (phone) 213-452-4196 (fax) s*:sss+s:sssssssssssss:sssssssss:s:ssesssssss:*sss• a thatHOWEVER !Sr_ Gleason shoulc- weigh-in on this issue. It is po - l Bolsa was diked off prior to the implementation of the River and Harbor Act { of 1899 (although the diking at that time was across the main slough - Freeman Creek, I believe - for duck hunting purposes, and may, or may not have cut off tidal exchange to in-board areas, including the Shea Homes parcel. I believe, nonetheless, that Section 10 probably extends to portions of the Shea parcel. Let me know what you think. I am forwarding a copy of this message to Mr. Gleason and Mr. Barroll of our staff, so that they can barrage us with legal opinions.......... Tan. estein4spl.usace.army.mil on 04/30/98 03:53:14 PH To: Thomas Yocam/R9/USEPA/US CC: . jack,,,fancherffws.gov, mdurham9spl.usace.aasy.ai3L subject: ...no subject... TOM, Thanks for you email regarding the Shea Homes site. we are in the process of re-examining the PC call on the site by reviewing recent aerial photos etc. The wintersberg Channel has obviously eliminated tidal influence to i the site, but if ppt and urban runoff provide sufficient hydrology to allow i hydrophytic vegetation to grow when the area is not disked, I think we would need to re-look at the PC call. However, in the absence of evidenaa that there is adequate hydrology on the site under current circumstances,' we would probably stick with the old call. Having said that, it is quite possible that the ulitimate call will need to be made by NRCS, but I have yet to discuss this with them. Regarding Section 10 jurisdiction. I would say the the wintersberg Channel has not only eliminated tidal influence on the site, but also made it unlikely that the site could be restored to tidal influence. Therefore, at i this point I do not believe the Corps would take Section 10 jurisdiction over this area. Let me know if you want to discuss. :rr:rrrrrrrrrrrtrrrrrrsrrrr•rrrrrsr�rr�t�rrrrtsr�tsr Eric D. Stein U.S. Army Corps of Engineers Los Angeles District, Regulatory Branch estein0spl.usace.army.mil 213-452-3415 (phone) 213-452-4196 (fax) rrrrr:rrrrrrrrrrrrr:rrr�trrrrrrrr:ttrrrssrr:rt�strr. ' To: <esteinaspl.usac a My.Mil> From: Yocom.Thomas4epamail.epa.gov Cc: <Barroll.HughBepamail.epa.gov>,<jgleasonfspl.usace.army.ail> Bcc: Subject: CWA and RHA Jurisdiction at the Shea Homes Parcel Attachment: ATT'RIBS.BND Date: 511/98 8:20 AN Eric.- Thanks for your note. I have the following thoughts. First, I agree that hydrology is •the issue' regarding CWA jurisdiction, and that ponding for more than 14 days in most years would be the trigger With regards to MRCS or the Corps changing the prior-converted cropland determination for the site. Discing, per se, does not affect jurisdiction. and the absence of wetland vegetation due to discing would not be grounds for disclaiming jurisdiction, unless the soils and/or hydrology parameters were also missing. I know that locals have been recording ponding evidence for the past couple of years, and as I mentioned earlier, it may be possible to assess the likelihood of ponding *in most years• from conditions over 'the last couple of years, even though they have been wetter than normal. However, locals should not get there hopes up that observed ponding the past couple of winters is evidence of •wetlands.' I have some questions regarding your preliminary assessment of Rivers and Harbors Act jurisdiction. The Ninth Circuit Court of appeals (in the 1978 case, Froelke vs. Leslie Salt) instructed. the Corps to assert jurisdiction to the plane of mean high water in its unobstructed natural state, regardless of whether the site is presently tidal, or might be returned to tidal action in the future. The San Francisco District, for example, has asserted jurisdiction over historical slough beds behind dikes, even when there is little or no evidence of the actual slough channels presently (they may have been obscured or leveled through agricultural or salt-making ?rocesses around San Francisco Bay). To my knowledge, the San Francisco District has not based its assertion of jurisdiction on the likelihood that these areas would be returned to tidal action -- in fact, its jurisdictional determinations have often been made in cases where the i future use of the site is decidedly upland uses (housing, etc.). It was under this scenario that I assumed that Rivers and Harbors Act jurisdiction would most certainly reach portions of the Shea Homes property, given that portions of the site were historically tidal (sae EPA's 1989 jurisdictional determination for Bolsa Chica, which included an estimate of Rivers and Harbors Act jurisdiction, based upon Coast and Geodetic Survey topographic charts from the 1850's) . I had assumed that, as with the San Francisco District, the Corps would assert jurisdiction over area where tidal sloughs were present prior to the site being diked in 1899. . • .__- - _ � ,..i.w..�_ �'�.'^may�.'.p� � _ - - .� - - -------- --- J -- - Z r..D_ .��. cam_ �,•� ST ,�/- - To: Farinaz. Tabata4 1 From: Eric D StefnOCO Cc: Mark DurhamOCO Bcc: Subject: Shea HMOs JD .'achment: Date: 6/19/98 9:24 AK Fari, I spoke to Jack Fancher about the extent of tidal influence in Garden Grove Wintersberg channel along the Shea parcel. He says that the channel is tidal past Graham St. (well past the Shea parcel) and is dominated by marine organisms. The flapgates at the bottom of the channel are leaks and do not exclude tidal flow from the channel. Tom Napaly (CDFG) said that he believes the Wintersberg Channel is brackish through the Shea parcel. He said that he observes mostly brackish spp in the Wintersberg Channel. Based on this info, I think we could make a case that the Shea parcel would be "subject to Section 10 RHA jurisdiction. Eric D. Stein U.S. Army Corps of Engineers Los Angeles District. Regulatory Branch esteinOspl.usace.army.mil 213-452-3415 (phona) 213-452-4196 (fax) CI a 3 To: John M Gleason From: Farinaz Tabatabaigco Cc: Bcc: Subject: Shea Homes Attachment: Date: 8/31/98 S:11 PM John, I read the letter from McClutchen, and etc. A couple of important things for you to note before you read it and we discuss it are: 1. Construction of the Bolsa Chica. Dam did not cut off tidal influence. It was construction of the Wintersburg Channel which cut off the tidal flow. 2. According to the information provided by the Shea Home's consultant, the site is not filled as the property elevation varies between 0.3 to +2.2 ft (I am assuming it is MSL) . The consultant information also says average j elevation of the property is 1.0 (again I am assuming MSL) . 3. We never discussed the site in terms of commerce. our basis for { defining Navigable Waters was those subject to ebb and flow of the tides. I like to know what you think about the definition of Navigable Waters in Section 329.4. Does the •past, present, future• test apply to the tidal I influence or only to commerce? I If you are in L.A. tomorrow, let's discuss. It should be fun. Thanks., Fari J 0 J% i- J 16 �r . M V �1 n SHEA PROPERTY DEPICTING SLOUGH AREAS n PER U.S. COAST SURVEY, 1873 r •SLOUGH SURFACE AREA = 1.5 AC. PLOTTED AND CALCULATED BY: n HUNSAKER & ASSOCIATES K V I N E , 1 N C ;a MANNING • ENGINEERING • SURVEYING MAY 7. 1009 iNW 04to kvkv, CA 92618 00PH(949)f81.1010 •M.(949)1E3.O7S9 3 O:\I SJ7 7\EXHiRil\SIOUGHAREAS.OWG RECEIVED „ UNITED STATES ENVIRONMENTAL PROTECTION AGENCYAVG 0 5 1999 �lifi► � REt,10N OC 75 Hawthorne Street REGULATORY B 0(A N C H San Francisco.CA 94105-39(n 22 July 1999 Colonel John P. Carroll, District Engineer US Army Corps of Engineers P.O. Box 532711 Los Angeles, CA 90053-2356 I=: 213/452-41% Attention: Far Tabatabai RZ: Letter Of Pe=ission (LOP) No_ 98-628-T1, dated July 13, 1999, Parkside Estates PAsidential Development, Orange county, Califosssia Dear Colonel Carroll: The Environmental Protection Agency (EPA) has reviewed the above referenced LOP regarding Shea Homes' proposal to fill jurisdictional waters of the U.S. for the purpose of developing single family hooves. The proposed development is located in and adjacent to the Balsa Chica wetlands area of Huntington Beach, California and proposes to fill 1.5 acres of Section 10 habitat. These comments have been prepared under the authority of, and in accordance with the provisions of the Federal Guidelines (40 CFR 230) promulgated under Section 404(b) (1) of the Clean Water Act. EPA obiects to issuance of this oroposed LOE based on the lack-of substantive information provided in the LOP. There is no explanation .as to how and why 1.5 acres of jurisdictional waters of the Q.S. must be filled in association with proposed development of 208 residential units. Is the discharge of fill materials related to disposal of construction related materials and/or dirt? Is the discharge of fill related to building structures and/or facilities related to the development? Are there reasonable alternatives to the proposed filling which might minimize and/or all together avoid the proposed impacts? Building single family homes is not a water dependent activity. Therefore, the proposed discharge, based on. the information provided in the LOP, can not be justified in any reasonable manner. Additionally, no mitigation is proposed for the 1.5 acres of impacts. Is it not still the federal government's overall policy to obtain or achieve "no net loss" regarding federally authorized wetland impacts? It is more than safe to say that other pertinent agencies (e.g., California Department of Fish and Game, U.S, Fish and wildlife Service, National Marine Fisheries Service, etc. ) responsible for reviewing proposed projects such as this eX2ect mitigation for permanent impacts to wetlands and other waters. Proposed hwrd r.lkrtrin[rsyn• �i authorizations such as this should not be issued for public review without at least addressing our "no net loss" policy in context With t the proposed project(s) and associated mitigation for the proposed f impacts to waters. This .proposed authorization needs to be revised to meet the above concerns and then reissued, if appropriate, for public review. Please contact me at (714) 389-0365 if you have any questions regarding this letter. Sincerely, Aaron C. Setran, Biologist Wetlands Regulatory Office cc: DSFWS, Carlsbad, Miller . CDFG, Long Beach RWQCB, Santa Ana SWRCB (Balaguer) , Sacramento NM£S, Long Beach Applicant 2 10 Amigos 16531 Balsa Chica St.,Ste. 312, Huntington Beach. CA 92649-3-546•(714)840-1575 )B61S a �Mia August I3, 2001Ch ica City of Huntington Beach Department of Planning and Environmental Services 2000 Main Street Huntington Beach, CA 92648 By Fax(714)374-1648 Attn:Mary Beth Broeren RE:Parkside Estates EIR Dear Ms. Broeren: Amigos de Bolsa Chica has the following concerns regarding the Parkside Estates New Alternatives to Draft EIR#97-2. 1. All Inclusive EIR Because of the significant events that have occurred since the circulation of the initial Elk including.:hanges in the FEMA base elevation requirements,Appellate Court decisions relating to the Bolsa Chica and ESHAs, and the November 2000 action of the California Coastal Commission,we believe that a review of the entire project,its impacts and characteristics should ADBC#2 - 1 be included in one new EIR- It is unrealistic to assume that interested parties will have access to or have reviewed the prior circulated EHL We suggest that the EIR information be consolidated and re-circulated as one document package. 2. Flood Control It appears that although the proposed project will be protected from flooding,because of its elevation above that of surrounding properties,it could significantly increase the potential of ADBC#2—2 flooding in surrounding neighborhoods. Also the channel wall separating the project from the flood control channel is higher than the wall on the other side of the channel, providing greater potential for flooding on the opposite side of the channel. The EIR should evaluate these impacts. There should also be discussion of the quality of runoff water from the property entering the channel and emptying into Outer Bolsa Bay. The pollution of Outer Bolsa and Huntington ADBC#2—3 Harbor from Wmtersburg Channel is already of great concecm. The extent of increased pollution should be thoroughly addressed in the EI L 3. Views The EIR should demonstrate view plains not only up to the proposed residents but down from the project to existing residences- It appears that the elevated project will expose surrounding ADBC#2—4 homeowners to unprotected viewing from the project and roadway- Protection of privacy of surrounding for surrounding residents should be.addressed. City of Huntington Beach Page 2 4. ESHAs The project should conform to the recommendations of the California Coastal Commission in regard to buffers around Environmentally Sensitive Habitat areas and wetlands. Substantial ADBC#2-5 buffers of at least 100 meters should be provided around eucalyptus trees. Buffers must not include any uses such as sidewalks,yards, active parks or hard improvements. Arborists are not appropriate persons to determine the value of trees and plants as habitat areas. A qualified wildlife biologist should determine the habitat value of existing trees. IADBC#2-6 5. Wetlands. The area contained historic wetlands which have been degraded in recent years as the property was used for agricultural purposes. If wetland habitat area can be restored, it should not be acceptable to allow residential development on the property just because the agricultural use has ADBC#2-7 ceased. The restoration of the prior wetland condition should be explored in the EIR. 6. Public Acquisition for flood control and Ecological Preserve The alternative uses of flood control settling basin and wildlife preserve should be explored. The area could be an important component to flood control improvements being sought by the County ADBC#2-8 and City of Huntington Beach. The property could also be incorporated into the Bolsa Chiea Wetlands restoration project. Those uses should be explored in the EIR. 7. Traffic and Construction impacts The EIR contains no details regarding off site haul routes for fill material into the project at Graham Strut. Considering that as many as 140 loads of fill material may be hauled each day over a 12 month period, the impact upon traffic and public'safety in the surrounding area will be substantial. Students accessing nearby Marine View School must be adequately protected from ADBC#2-9 risks associated with the heavy construction equipment traffic. Also, the three outlets onto Graham Strcct from tracts immediately north of the project could create dangerous conditions caused by construction vehicle traffic. The EIR should address all potential impacts on the surrounding area from construction traffic and proposed mitigation measures. Post constriction traffic impacts should also be reviewed and mitigation measures detailed. ADBC#2-10 Access to and from existing tracts at Kenilworth and traffic on Graham would be adversely impacted. Sincerely, r Linda Sapiro Moon President, Amigos de Bolsa Chica 11 -� Ott CALIFORNIA CW DAVIS.Guwrnor EXFCUTIVE OFFICE CALIFORNIA STATE LANDS COMMISSION 100 Howe Avenue,Suite 100-South 4 Sacramento,CA 95815-.8202 . 4. CRUZ M.BUSTAMANTE,Lieutenant Governor PAUL D.THAYER,Execut fficer (916) 574-1800 Fax(916) 374-1810 KATHLEEN CONNELL,Controller • Califi�mia Rclry Saviufmm TOD Pimne 1-800-73-1-2922 B.TIMOTHY GAGE,Director of Finance fmm Voke Mone 1-800-735-2929 August 13,2001 Ms.Mary Beth Broeren City of Huntington Beach 2000 Main Street Huntington Beach,CA 92648 Ms. Nadell Gayou The Resources Agency 1020 9th Street,3rd Floor Sacramento,CA 95814 Dear Ms. Broeren and Ms.Gayou: Staff of the California State Lands Commission (CSLC)has reviewed the New Alternatives to the Draft Environmental Impact Report(EIR)#972,Parks-ide Estates, SCH 1997091051.Under the California Environmental Quality Act(CE-QA), the C*ity is the Lead Agency and the CSLC is a Responsible and/or Trustee Agency for any and all projects that could directly or indirectly affect sovereign lands,their accompanying CSLC#2 —i Public Trust resources or uses, and the public easement in navigable waters. By way of general background,upon admission to the Union in 1850,California acquired nearly 4 million acres of sovereign land underlying the State's navigable waterways. Such lands include,but are not limited to,the beds of more than 120 navigable rivers and sloughs,nearly 40 navigable lakes,and the three mile wide band of tide and submerged land adjacent to the coast and offshore islands of the State. These lands are managed by the CSLC. The CSLC holds its sovereign interest in these lands subject to the Public Trust for commerce, navigation,fisheries, open space,and preservation of natural environments, among others.The CSLC is particularly concerned with the natural resources and public recreational opportunities of lands under its jurisdiction. Our records indicate that by letter dated June 1, 1998,CSLC staff provided comments on the original Draft EIR.We reiterate the comments and concerns expressed in that letter as this document not only relies on the analyses of such document,but also CSLC#2—2 adds no additional information or analyses regarding the proposed Alternatives beyond that contained in the initial EIR. The subject document discusses four new alternatives that were developed in conjunction with the Parkside Estates Residential Development Project.The alternatives CSLC#2—3 reflect two different reduced density concepts that have been prepared based upon new information that became available after circulation of the original EIR in,1998. Each of Ms.Mary Beth Broeren 2 August 13,2001 Ms. Nadell Gayou the alternatives proposes flood control channel improvements (sheet pile) and storm CSLC#2—3 drain.improvements involving the installation of a pipeline under the East Garden (cost.) Grove-Wintersburg (EGGW)Channel. The nature and extent of the improvements to the EGGW Channel that could result from the original project were not described or analyzed in the initial EIR.See comment for 5.7 Drainage/Hydrology in our letter of June 1, 1998. The current document,in various places,states,in part,"However,the proposed design of this alternative, including the higher pad elevations,storm drain improvements,addition of greater CSLC#2-4 pum12 ne capacity to the Slater Pump Station,and improvements to the East Garden Grove Wintersburg Flood Control Channel,will mitigate the impacts to a level of less than significant." (emphasis added)There is no description of the improvements to the EGGW Channel and no analysis of the potential impacts of such improvements,e.g., construction,operation,etc. It appears,from Exhibit 58,that only that side of the EGGW Channel adjacent to the proposed development will be improved.How will this selective improvement affect the opposite unimproved side and the downstream portions of the Channel? Will such improvement benefit the development to the detriment of the proposed Bolsa C:hica Lowlands Restoration Project(Project) that will be adjacent to the unimproved side of CSLC#2—5 the EGGW Channel?For examp?e-,will such improvement increase the potential for or size.of Channel overflows into the Project due to additional storm water flows from the development without any corresponding increase of the Channel's capacity in this section?How would associated water quality impacts to the wetlands be mitigated? What impacts would result from and how will the proposed improvements to the Slater Pump Station exacerbate the above-cited potential impacts? The CSLC acquired ownership of the EGGW Channel,up to its intersection with Graham Street,as part of the acquisition of the 880-acre Bolsa C.hica Lowlands, pursuant to Grant Deed recorded on February 14,1997,as Document No. 19970069448, Official Records of Orange County. A copy of that document is enclosed.Upon acquisition,this property was impressed with the Public Trust for waterborne CSLC#2—'6 commerce,navigation,fisheries,open space,recreation,or other recognized Public Trust purposes. Therefore,CSLC authorization will be required for any flood control channel/storm drain improvements anticipated as part of this project. If you have any questions concerning the CSLC's jurisdiction,please contact Rick Ludlow at(916)574-1847. Sincerely, 46-34�w Dwi t .Sanders,Chief Di ' 'o of Environmental Planning and Management Enclosure Ms.Mary Beth Broeren 3 August 13,2001 Ms. Nadell Gayou Cc: Members,Bolsa Chica Wetlands Steering Committee(each-w/o enclosure) Rick Ludlow Jane Smith 12 August 13,2001 Scott Hess Planning Department City of Huntington Beach 2000 Main Street Huntington Beach,CA 92648 re: SHEA Homes-Parkside Estates Project Comments on Alternative to Draft EIR 97-2 Dear Mr.Hess: This letter contains written comments relative tothe Alternative documents for the above referenced SHEA Homes propoed Parkside Estates project. As was discussed at the public meeting last month it's RPA#2— 1 difficult to properly address this because we do not have the benefit of the responses to the original Draft EIR. Be that as it may,I have several comments regarding the latest documents. 1.) I am still concerned that there is no formal plan under review for the proposed dewatering that is anticipated for the project. This is a huge engineering effort that potentially has serious safety and structural implications for those residents on Kenilworth adjacent to the project: I believe that a RPA#2 —2 formal study/plan,by a qualified dewatering engineer should be required as part of the'fianl EIR document. 2.) Because each of the alternatives proposes fewer houses than the original draft EIR, the alternative document suggests that the traffic study and recommendations in the original document are still sound. In the 3 years that have passed since the Draft EIR was released and commented on, however,the Summer Lane development,the Sandover development and a large number of Edwards Hill properties have been completed. This has significantly changed/increased the volume and timing RPA#2—3 of traffic in the immediate area (especially on Graham). Also the"two year long"flood control channel improverment project and it's consequential traffic rerouting has significantly and-permanently changed traffic flows through the neighborhood. So there has been a"more than significant"increase in both volume and flow of traffic through the project area over the past three years. I believe that a new and comprehensive study of traffic issues for the project be required as part of the firAI EIR document. 3.) The final EIR needs to specifically adress who will be responsible for maintenance and security on the proposed pasco park aspect of the project. Also some suggestions for the park include having a level 25 foot section prior to the 50 foot slope and line either side of the proposed foot path with split RPA#2—4 rail fencing(much like that found on dedicated hones trails). This would further isolate the existing Kenilworth homes from public traffic,provide a better retention basin for winter storm runoff and discourage vandalism. 4.) The requirement for raising average pad elevations either 5 or 11 feet changes the volume of fill required at the site trenmendously relative to the original plans. If this is not all to come from the RPA#2— 5 adjacent Bo)sa Chica site, there will be a huge volume of heavy trucking through the immediate area (estimated at at least 100- I50 large trucks per day). This has significant implications and impacts on RPA#2— 5 all of the city roadbed infrastructure in the area( Warner,Graham, Bolsa Chica,etc.). It does not (cont.) appear that these impacts have been addressed in enough detail in this document. I am sure that there are many other areas of concern,however I will stop here. I look forward to hearing the responses to the original comments and on theses as well. RPA#2 - 6 Sincerely, Douglas J. art ps: I am also attaching some comments that were made by an associate of mine relative to the original Draft EIR. NOTES ON EIR 97-2 Spoke to Douglas Stewart,5342 Kenilworth Drive,Huntington Beach,CA 92649,home pltione:846-9117 and work phone:574-0800. He has been on this project for quite awhile. I spent so ne time talking to him on the phone and told him 1'd spend some time reviewing it. RPA#2—7 Spoke to Debra briefly for her input before I started reviewing it. She recommended-ibat.:I read the executive summary,page i through 4 the major issues,all of Chapter 7 the long-term implications,all of Chapter 8 and specifically portion 8.3 dealing with unavoidable adverse impacts,:sldm Chapter 5 and Chapter 6. I then started reviewing it. Spoke to Tom about the flooding potential. He indicales that based on a study that he handed to me,there has been flooding in the area but the report in December 1992 indicated that the overtopping occurred up near the 405 Freeway and really brought into question RPA#2— 8 whether the capacity was appropriate around the 405 Freeway. The possibility, being that the channel under the freeway was under capacity. Didn't see any specific indication of flooding in this area. If an area that has not flooded before or was not subject to the flooding before,then the public entity allows a development in the face of knowledge that flooding may now occur the public entity is strictly liable for losses from the flood. This could get the City's attention. This is a gross ovary simplification of it but indicates he thinks the Supreme Court may change it if it's challenged but right now it is the RPA#2 — 9 law. Remember that if this happens and the strict liability is imposed,were talking about punitive damages plus attorneys fees to the plaintiff by the City. This kind of comment to t1w City should at least cause them to look into the flood control aspects a little better than they have. Page 3-31 -They want to expand the capacity of the Winterberg Channel because of'1draiftage deficiencies. (On this site? What do they plan to do? Will this housing be subject to flooding in heavy rains? City is going to be strictly liable if that occurs! Also,liable for attorneys fees for the homeowner.) RPA#2 — 10 Page 3-31 -Drainage deficiencies on Graham-If it's a problem what does SHEA plan:to do to improve it? Do they claim building on site will improve it? Page 1-1 -49 acres-208 homes. That's four plus homes per gross acre. The parIcsitce mnaves some of this 49 acres. This doesn't sound like low density because we're really talking ablaut 8 hgia tes per gross acre and that's even without removing some of the 49 acres for a park. As to why it's 8 homes per acre, RPA#2— 11 it's because the streets, parkways,sidewalks,etc.all take up 50 percent of the laud. Study the likelihood of flooding of area homes and the liability to the City fot:,a1116wittg this �RPA#2— 12 development without some massive and effective flood control measures for tWaite. The site is low and it looks like a retention basin as it sits there today. Have developer explain what they propose to actually do—page 3-31 -expand tapacity of channel - how they going to do that? Do they have County of Orange approvals? RemewA'wif it's a drain then RPA#2— 13 it doesn't work because the channel is already full when it gets to this property... 3-21 to 3-23-Make sure they have approval for all soils to be imported from adjaCEilit j0bel so there is no use of public roads. Note that if the developer doesn't agree or guarantee he'll be getting this fill dirt he has to bring in from Bolsa Chita. If they don't then the report needs to address all the dirt,dust and degradation to the local roads by these use of thousands of dump trucks for several months. Also, what about traffic congestion because of all the goings and comings of these trucks. Don't give in on this RPA#2— 14 one'.Require a written agreement from the adjacent property owner to allow all dirt.-to conte from his site. Otherwise,you will have your roads destroyed with all these dump trucks vo.your ioc- al streets. That is not an efficient or effective use of tax funds because the roads will have t6 be repaired by local taxpayers. The reason I think you should require this is it appears that the adjacent landowners might be within the ecological area and that is all subject to a lawsuit at this time and it seems.hard for me to believe that they are going to allow you to start removing areas from this ecological area�or at least claimed ecological area with lawsuits pending. 3-21 -Have them tell you how many dump truck loads it takes to import 210,000ttxGW-yards of dirt. I submit it's probably 10,000 to 20,000 dump truck loads. When you are dealing with dWr►p trucks,the more they carry,the more damage they do. Remember the weight of these trucks cantddOubstantiai RPA#2 — 15 damage to streets that are only used to handling a very small percentage of trucks andit suddenly jumps. The road that is weakened and beat up and almost anybody can tell you that that4oecurred to them if they've ever lived at or near a place that went from being residential to one where there was heavy construction traffic. People in that situation notice that a roadway is cracked'and broken within 30 days of the time the construction project starts. TM said that this channel was not a 100 year storm drain channel. The text frorri iUut p4ge 5-136 through 5-138 seems to infer that it's a 100 year channel. It's therefore misleading. There is not likely to be any improvement in the channel. The County of Orange fil!�beeif;trying to RPA#2 — 16 improve it for 20 plus years and it can't. It doesn't do any good to improve the chanp4 iti4his area and to the east. You have to improve it to the west and that's not being allowed. The ftsa?Chica people do not want more water introduced into this area and they have fought any changes to improve the channel. Exhibit 42 -Lined pump station goes under the channel. That's a real engineering feat!`You hit water in this site at 10 feet,how are you going to build this thing. RPA#2— 17 This now storm drain system is going to drain directly to the Slater Pump Chara" Z7tat pump channel is already over capacity in a serious storm. So your pump won't help you to dispose of rWre of it. What is it they can do? Well what they will do is they'll put in their storm drains and.if it cart make it to RPA#2— 18 the Slater Pump Station it will then get pumped by the Slater Pump Station int<)•the dut ncl and after that occurs because the channel is already overtopping it will just overtop that additional water you put in which will still come back and flood you. What kind of solution is that? I can't say for certain but it appears that if houses and streets already have souLAS06diiig problems, then this tract puts in a systeeTn and that in turn either puts additional pressure on.the-sumunding homes on either the south or north of the projector if this side is lower than Graham.and:Warner then RPA#2 — 19 the water will run right down into the tract and when the drain becomes full they are going to flood in the lowest spot. If this is the lowest spot in any drainage area, this is where the'-water-is going to settle. As adjacent homeowners you want to make real sure that drainage from your property is not interfered with. In other words,you want to be higher than this new site. You better not be lower and don't let RPA#2—20 these walls they want to build around their project block the natural water course of water from your property. Chapter 7-Long term implications RPA#2 —21 Page 7-1 -Talking about flooding again. Page 8-3 -No unavoidable adverse impacts. Well that's just great! Absolutely no adverse impacts at all! We all ought to welcome this with open arms because it's also very good. Whenever they make this statement in an EIR it shows to anyone familiar with theiil that this is all RPA#2—22 hooey. They arc always some unavoidable impacts that can't be mitigated but they deny that even exists. This is a "soft spot"in the EIR. Point out one unavoidable adverse impact that icilvt or hasn't been mitigated "to less than significant"levels and the entire EIR is questionable atkd Doti get yourself a potential lawsuit if this ends up being approved. Chapter 5 -Fire and paramedic response time not up to City standards. RPA#2—23 Schools -Can't handle added students. 1 RPA#2—24 Scwcrs -Inadequate-Who is going to pay for all the improvements needed-SHEAvi tl*-City? Make sure SHEA pays for it all. If not the city officials have to be told that they are c66 tl Ag tax dollars RPA#2—25 from citizens to benefit SHEA Development and not the existing/voting citizens of this City- What are the fiscal impacts? What does the City get versus what the City spends? What is the benefit of the project? You need more police and fire and water and sewers and roaid-nse."What will RPA#2—26 this tract be in taxes that the City will get? No.6 -Project alternatives-Evidently only one alternative was considered and sosriethir%to do with a 9 hole golf course. Who says that a 9 hole golf course requires 80 acres? How ntankAcres Ji`Mcadow RPA#2—27 Lark? It's an 18 hole course. What about building homes of the size SHEA is curr pr4osing plus a 9 hole golf course? Is that feasible? Sure gives a place for the water to go if it floods! End of Comments. 13 r r L 6i\ 6L KF#2- 1 _ � � " KF#2 -2 �z _ �. � t KF#2- 2 4A 14 -J e` California Regional Water Quality Control Board Santa Ana Region Internet Address, httpJ/www.swrcb.ca_gov/rwgcb8 Winston H.Hickox Gray Davis Secretary for 3737 Main Street,Suite 500,Riverside,Califotwa 92501-3348 Governor SecreDivir tttnetttal Phone(909)782-4130-FAX(909)781-6288 Protection The energy rhallenge faring California is real. Every Cal{fbrnian needs to take intntediate action to reduce energy consumption. For a list of aunple ways you can reduce demand and cut your energy costs,see our webstre at www..5wrcb.ca.gov/twgcb8. August 14,2001 Mary Beth Broeren City of Huntington Beach 2000 Main Street Huntington Beach, CA 92648 RESPONSE TO THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PARKSIDE ESTATES EIR NO. 97-2 (SCH #1997091051), CITY OF HUNTINGTON BEACH, ORANGE COUNTY Dear Ms. Broeren: Staff of the Regional Water Quality Control Board, Santa Ana Region(RWQCB), have reviewed the Draft Environmental Impact Report(DEIR)for the above-referenced project and offer the following comments: The DEIR evaluates a number of alternatives in addition to the original project. Staff of the RWQCB supports the plans to avoid and preserve the remnant pickleweed area and the delineated pocket wetland RWQCB — 1 areas. Preservation of these areas not only saves the vegetation but also maintains the valuable functions that the wetlands provide. Furthermore,the superior alternatives are those which do not promote additional lots to be constructed outside of the City of Huntington Beach's boundaries.Keeping the development within city limits will allow for more o{en space,permeable areas for water to naturally percolate into,and limit the impacts associated with converting natural land into impermeable structures. The DEIR indicates that the proposed development will increase the amount of impervious surfaces, resulting in increased surface runoff,altering existing drainage patterns,and increased impacts related to grading. However,the DEIR does not address impacts pertaining to stormwater runoff,during and after construction. The proposed project will be changing a large parcel of land from natural and pervious to impermeable with the construction of houses,roads,sidewalks,and other impervious structures. The proposed project will result in a number of pollutants that will be introduced into the storm drain system; RWQCB -2 untreated,the pollutants may cause many downstream effects,possibly violating beneficial uses. In addition,the development is adjacent to the Bolsa Chica wetlands. Potential runoff from this site should be addressed to minimize any negative effects it may have upon the wetlands. An extensive evaluation discussing pre and post construction stormwater runoff best management practices, prevention and treatment of additional nonpoint source pollutants and runoff,protection of beneficial uses and water quality objectives, and impacts to the Bolsa Chica wetlands should be disclosed. The DEIR also indicates that dewatering will be necessary. Dewatering during construction at the site will require either a National Pollutant Discharge Elimination System(NPDES)permit for the discharge of wastes to surface waters or a Waste Discharge Requirements (WDR)permit for the discharge of wastes RWQCB —3 to land,be obtained from the Regional Board. Jun Martirez with the Regional Board's Regulation Section may be contacted at(909)782-3258 to discuss your project. California Environmental Protection Agency -• Recycled Paper Mary Beth Broeren City of Huntington Beach -2- August 14,2001 A Storm Water Pollution Prevention Plan may be required to be submitted to the Regional Water Board prior to the start of the proposed project. Proper erosion and sediment controls must be utilized to prevent RWQCB —4 runoff during excavation, construction, and site remediation. Please contact Mark Smythe(909) 782-4998 with the Regional Board's Coastal Stormwater Section to further discuss your project. Should dredge and till activities become necessary for the proposed project, either a 401 Water Quality Standards Certification (pursuant to Section 401 of the Clean Water Act) or Waste Discharge RWQCB —5 Requirements (pursuant to Section 13260 of the California Water Code) will be required. Please contact Kelly Schmoker(909)782-4990 with the Regional Board's Planning Section to further discuss your project. Thank you for the opportunity to comment on the proposed project. If you have any questions, please RWQCB —6 contact me at(909)782-4468 or Stephanie M. Gasca at(909)782-3221. Sincerely, Wanda Smith,Chief Coastal Waters Planning Section Cc: Scott Morgan—State Clearinghouse California Environmental Protection Agency �� Reryried Paper