Lilac Hills Ranch Subcommittee prepares DEIR resubmittal
July 30, 2014The Lilac Hills Ranch Subcommittee met July 16 to review the comments they compiled as the basis for the Subcommittee's recommendation to the Valley Center Planning Group.
Chair Steve Hutchison informed the Subcommittee that the county took the draft EIR from last year and modified it using strikeouts to delete type and underlining type to show what had been added.
"This helped make our job easier because we can tell where we need to be paying attention," said Hutchison. "Some things didn't change. Some sections changed more than others. The comments that we're looking at are aimed at addressing new material as well as unanswered or not responded to older material from last year. Some of the issues that we raised last year have not been addressed or responded to and all the comments that were made last year are part of the administrative record."
Only by resubmitting the comments this year, will the county be obligated to respond to them.
At the meeting the previous week, the Subcommittee recommended a letter to the Planning Group that would authorize the Subcommittee to forward all of last year's comments to the County. The goal was to make a recommendation to the Planning Group for their next meeting to submit new comments and to ask for an amendment to augment the comments from cultural resources so everything would be included that hadn't been read and reviewed.
The Chair was asked due to lack of water in California, how could the VC Water Dept. supply water to the Lilac Hills Ranch (LHR) development. Hutchison explained the water district responded saying that it's going to take some before there is infrastructure present. Because there is no sewer system in place, it's going to require time to build and enlarge and several lines that go through the project site will need to be reconfigured to accommodate the project.
Fire service is located in the Deer Springs Fire Protection District. There are four options presented in the revised Draft EIR but all are unacceptable leaving the unresolved issue of fire protection.
The school districts of Bonsall and Valley Center - Pauma Unified state that the school being offered in the LHR project isn't needed. Furthermore, the Valley Center school cannot accept the new school without filling the vacant school located next to the elementary school. The state will not finance a new school until all the existing facilities are fully used. Recently unified Bonsall didn't appear interested in the new school because it would be inconveniently located on the edge of their district.
"Either way, there's going to be a lot of traffic on the roads," said Hutchison. "These were issues brought up in the traffic comments."
It was advised to submit comments by July 28 to Mark Slovick with the County. Most importantly, it was suggested that comments be worded in question form so the question would have to be answered. A comment or opinion doesn't necessitate the County's direct response.
"If you're inclined to make comments, this is how democracy works," said Hutchison. "If you don't comment, you can't expect anything to change."
There is no time period in which the County must respond to the comments. Last year, the comments were sent August 19. Responses were expected in November or December but were never received. The County does not have to respond to the comments. They could opt to reply to the comments being submitted in another DEIR.
If it is determined that the revised DEIR didn't comport well with CEQA (California Environmental Quality Act), then they have the option of resubmitting it.
"The Draft EIR is a county document," Hutchison said. All the county staff is working on sending it, revising it. Doing this two, three, four times is very expensive not to mention the cost of time while we're waiting for approval. There's an incentive for the staff to get it right so that means we can move on to the next step. But if they didn't like this last time, there is a risk of going through this again."
It is the County's place to provide the developer with alternatives to the project to make it work. CEQA asks the County to look at the project in terms of how it matches up to good environmental development. If there are alternatives that have less impact, but still meet most of the objectives of the project, those alternatives are presented to the decision makers.
An alternative that the Subcommittee presented last year is the downtown Escondido SPA (Specific Planning Area) that the city of Escondido has established which is set up to accommodate the much larger project. The area is identified as surrounding City Hall close to transportation, including the bus terminal which the Sprinter line adjoins. The structure is already in place—water, sewer, schools, fire service. All exist as opposed to the project site where, essentially, very little of the structure exists which would have to be extended to the project site.
"CEQA has very definite ideas about that and we're trying to get the County to recognize the downtown Escondido SPA as an alternative," said Hutchison. "The County so far has said it's not feasible. The applicant doesn't own the property."
When the project is built, there would be some open space. Riparian or wetlands left as open space cannot be developed. As far as lot size, the lots aren't going to get any smaller than 2,500 feet (50 X 50). Some are larger but a lot of the houses that already exist are probably close to that lot size in square footage.
The density of the town center would be over 20 dwelling units per acre and the average of the entire LHR project is 2.9 dwelling units per acre.
It is Accretive Investments' responsibility to obtain the entitlements to build the LHR project. They are undergoing reviews and proposed processes to convince the County they should receive the entitlements. After obtaining the entitlements, Accretive could proceed to build Phases 1, 2, and 3. Accretive has committed to Phase 1, submitting a tentative map for the first 350 houses but beyond Phase 1, there is no commitment.
"One of the issues that is raised is you build Phase 1, but if the market collapses and water becomes so scarce that no one wants to buy a house in Valley Center, Phases 2 through 5 don't get built," Hutchison said.
According to the DEIR, Phases 1, 2, 4, and 5 take two years each to build and Phase 3, the largest is estimated to take four years. Accretive is not committing to any time frame to build them. One of the issues with the phasing is Phase 3 is the borrow pit for the other four phases in which about 4 million cubic yards of earth are going to be moved. Phases 1, 2,,4, and 5 are going to be borrowing the fill.
"Phase 3 is going to be the export, but if Phase 3 is one of the last to be built as suggested in the DEIR, what is Phase 3 going to look like 8, 9, 10 years from now?" Hutchison asked.
Phase 3 is where the park, school site, and water reclamation facility are located.
"The only caveat I can find in the EIR is Accretive is committed to having all the infrastructure needed for each of the phases as it's built," Hutchison said. " As the phase is completed, all the infrastructure is supported."