Discussion of Lilac Hills Ranch Revised Draft EIR
August 06, 2014During the VC Community Planning Group meeting on July 21, members discussed comments to the DEIR resubmittal for the Lilac Hills Ranch Revised Draft EIR. Secretary Steve Hutchison informed those in attendance that the Executive Summary consisted of 20 pages, half of which is an explanation of the contents of the Revised Draft EIR with the last ten pages being a synopsis of impacts the LHR project is going to have on the site and the surrounding area.
Chapter One of the 264-page document discusses the environmental setting and description of the property. According to Hutchison, the first chapter cites the objectives of the project, which are too broad in terms of narrowing down objectives that would match the General Plan.
"It was too focused on the project as it was proposed," said Hutchison. "Consequently, everything else in the DEIR is aimed at those objectives. If the objectives aren't right to begin with, matching up everything to those objectives makes it useless. The most significant part of Chapter One is the failure of the project to meet the objectives of the General Plan as it was passed in 2011 and the existing Community Plan. He further explained the project fails to meet most if not all the objectives of the General Plan and the Community Plan not only for Valley Center but for Bonsall as well.
LEED-ND (Leadership Energy Environmental Design For Neighborhood Development) is a third-party standard for environmental consciousness requirements. In order to be certifiable, the General Plan requires any leap frog development (what LHR project is considered) to be certifiable under LEED-ND or its equivalent. Since there is no equivalent, LEED-ND is the basis. The county claims that LEED-ND is compliant with goals and objectives whereas the Committee states that clearly is not the case. Hutchison states one of the first objectives is site selection, which should not include agricultural land or green fields. Instead infield development should be considered which is development already inside the developed area and surrounding four sides such as brown fields and industrial use where infrastructure exists. The structure should not be extended into the countryside.
Hutchison defined Chapter Two of the proposal as being where the EIR belongs, the environmental element consisting of biological and cultural resources in the area. The county found there would be significant impacts as a result of the project. For instance, 1,746 houses on 680 acres with 90,000 square feet of commercial is going to have a visual impact.
"If you put that many houses on that many acres of formerly agricultural land, it does have an impact," Hutchison said.
Chapter Three of the comments addresses traffic impacts.
"It probably doesn't take a lot of imagination for most of you to understand the effect of adding 5,000 people and their cars to the roads of West Lilac, 395, and I-15," said Hutchison. This will have a tremendous impact, particularly at peak hours and in the event of an emergency."
"They're adding on the order of 20,000 average daily trips once the project is built," Hutchison said. "The proposal is to build roads that probably won't handle the traffic. The mitigations they're proposing for traffic range all over the place from East Vista Way all the way back to Miller Road in Valley Center because when you add that many people and vehicles in a very small area, they tend to have a much broader reach outside the area they're living in."
An unmitigated impact of the proposed LHR project is noise because sound can't be removed from the air to keep people from being disturbed by it. The only solution is adding structural features to the houses being built. That will minimize interior noise but have no effect on the noise generated by the project and the existing noise from I-15, which will now be busier if the project is approved.
The biological study shows neglect in failure to determine the size of the population of various animals, 13 of which are on the county's list of species of concern.
In the report, a letter from Cal Trans is included suggesting the project would impact I-15 including eight offramps originating in Riverside County down to Hwy 78.
Another issue is wastewater treatment which was determined to be insignificant. Hutchison pointed out thus could be very significant especially for residents in the area. He explained it would likely require the enlargement of the Lower Moosa Canyon Water Reclamation Facility. The facility is maintained by the Valley Center Municipal Water District very close to being at capacity now. This project would put them well over the capacity, not only in the building ponds but in the treatment capacity as well. It would most likely require upgrading to tertiary treatment from the present secondary. The difficulty remains in the expansion and laying the pipe. There are several alternative routes proposed in the DEIR, yet one has not been chosen. Due to various alternatives in the DEIR, it is difficult to determine exactly what the plan is.
Chapter Four of the document is comprised of numerous alternatives. The first three are nonspecific: No project. No development. Don't do anything. The second alternative is building out the project according to the current legal lots.
"Since Accretive has been acquiring property there, they've reorganized the lots from what it used to be," Hutchison said. "There are 59 legal lots and one dwelling for each of them. There's 16 already in place. They've intended to keep this fairly low impact. The General Plan allows 110 EDUs (Equivalent Dwelling Units) in that same space so it's just getting progressively more dense."
The last alternative listed is a Subcommittee proposal submitted last summer that was not addressed. Instead, it was dismissed by the county. The Subcommittee proposed the project be located in the downtown Escondido SPA (Specific Planning Area) which would allow 50,000 EDUs, many more than what the project proposes. It would be close to all the infrastructure such as sewage, water, schools, fire protection, and transportation, the weakness of the project. The Subcommittee's findings revealed the SPA proposal satisfies the objectives even better than the project.
The detailed Specific Plan is the last element included in the responses in which rules are discussed as well as architecture of the development, setbacks, and the HOA's control in the project site. It was noted there are many inconsistencies in the Specific Plan contrary to the General Plan and the Community Plan. As far as the project is concerned, the solution is to change the General Plan.
"This appears to be the route being taken," said Hutchison.
Discussion ensued in which Planning Group member Bob Franck asked, "Why doesn't the county protect us from this kind of development? It's their job. Why does the public have to spend hundreds of hours doing the county's job?" Planning Group member Jon Vick responded, "This is not a plan that meets with Valley Center's requirements and the only reason this is moving forward is because the developer is paying the county and the county is in the developer's pocket."
There is also the issue of eminent domain on West Lilac Road that will impact 20 properties and take two houses in the process if this project is allowed to move forward. In addition, there will be 15 to 20 slices of property taken along the Mountain Ridge stretch. Property on the east side of West Lilac will be taken for sight distance. Property will be taken between West Lilac and Rodrigues Road to make a turn radius. In response, a Group member stated there was arrogance in assuming the project is going to roll over with an amendment to the General Plan, which is there for a reason. The member added if this project is successful, it is setting a really dangerous precedence.
It was stated that the law provides four opportunities each year to make amendments and the County Board of Supervisors are taking advantage of that by allowing exceptions to the General Plan that was passed in 2011. Hutchison theorizes that the General Plan should be more sanctified than a placeholder waiting for a change.
"If you do due diligence in buying a piece of property, where do you go to find out the impacts you're facing?" asked Hutchison. "You go to the General Plan of the community. You look at zoning and land designation and reach some conclusions about everything that's around the property, but if it changes every couple years, what good is it?"
According to Hutchison, the highest density should be in the core of the village with densities feathering out to the edges of the community.
"What this project is trying to convince us is we've got two communities of Valley Center and Bonsall and we have these wide open agricultural spaces in between where we can easily put a commercial center and high density housing on 608 acres and put it in the middle of low density agriculture," said Hutchison. "Going through high density to low density meets the criteria. That's not the interpretation we see."
The Planning Group acknowledged the recommendation to the county was well thought out and well written as a document.
"Other than minor formatting and some word issues, I fully support this document and appreciate all the work that was put into it," said Chair Oliver Smith. "What we put in last August was tremendous. It had an impact on what we did. I'd like to say this has the same impact. Are we going to get everything we want? No, but we're going to get to the best of our ability that which we can justify."
Smith suggested focusing on the issues and deleting the language that doesn't belong in a professional document.
"If they're determined to say no, we can't stop them but we can get them to take the effort to read it," Smith said.
Furthermore, Smith stated an important aspect that should be highlighted is, "You can't do Phase 2,4, and 5 unless Phase 3 is done because that's the only place you're going to get dirt. I'm not sure they're even doing the first phase." Smith further explained, "The developer could sell this at any time. Everything that is not in writing or hasn't been approved has no value. Once this project is approved and it's sold to another developer, they're going to be committed to it. If they didn't put it in writing, there's nothing here to commit the developer to what he has to do. There are a lot of grand and flowing ideas but there's not much in the DEIR that commits the developer into anything."