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Revised 1/9/96
To L.A. Department of Regional Planning
320 W. Temple St. Los Angeles, CA. 90012
By Charles Brink January 9, 1996
RE: Bee Canyon Project Draft Environmental Impact Report Project # 93-147
Comments in Summary
In summary, the Draft Environmental Impact Report (DEIR) is defective in all possible ways. LA County and the proponent failed to circulate the DEIR to the recognized community groups and the two adjudicated local newspapers. I obtained the DEIR from Transit Mix’s engineering firm.
Because of the failure to properly publish the DEIR, you cannot take any action today. It must be recirculated and revised to address the issues raised by the community.
Another major defect is that the Notice Of Preparation (NOP) failed to notice the three local school districts involved, the Agua Dulce Town Council and the Agua Dulce Civic Association.
The Agua Dulce Town Council is recognized as the elected representative of the community by Supervisor Antonovich's office. The Agua Dulce Civic Association is a 50 year old group that proceeded the Town Council as the sole representative of the community. The Agua Dulce Civic Association is now currently serving to represent the property owners in the community. The President of that organization made repeated calls to LA County for a copy of the DEIR and was told that no extra copies exist.
The DEIR should be rejected as defective and no public hearing held. But in an abundance of caution, I intend to make a record concerning the problems within the DEIR.
I will only hit the high points in my verbal comments and provide the bulk in writing for your consideration.
Affordable housing
It will not be affordable housing because the infrastructure price and mitigation costs will raise the market rental on the trailer lots to close to $900 dollars just to rent the land without the cost of a home.
View scape
The DEIR states ..."the developed area will be on the floor of the canyon...". Figures 3-5B and 3-5C, show that all of the trailers/manufactured housing will be visible from the freeway.
Fire issues
This is a class 4 fire area. Relocated mobile homes are not class 4 buildings. Most manufactured homes using " Fiberboard siding and pitched roofs" do not meet class 4 fire requirements.
Both DEIR’s need concurrent evaluation
As a quotation on page 19 says, "As these two proposals are processed concurrently, the County of Los Angeles will have to evaluate the proposals I recommend the most suitable of use of this acreage." This clearly indicates the county cannot make any decision concerning this DEIR until the Transit Mix DEIR is available for comment.
Problems to be resolved
Missing totally are the adequacy of mitigation proposed for the schools, fire, sheriff, and libraries, and the ability to provide sewer and water service for the project.
Fire and Sheriff
There is no mitigation planned, just less service and longer response times.
Low density sprawl
"The proposed project will add value as the more concentrated pattern of development which could reduce the potential for the pattern of low density sprawl, which commits more land for development.
If this is an advantage, I have a problem with it because what this project engineer calls low density sprawl is our rural environments. For the DEIR to take a shot at rural environments, claiming they are defective and high density trailer parks are preferable, is pure lunacy.
Jobs-housing balance
The jobs-housing balance in the Santa Clarita area has worsened over the last 5 years and is below standard. This zone change is negative because it converts job producing property, M-2 manufacturing property and A-2 agricultural property into residential property.
Claimed Mapping error
This is some lame argument, unsupported by any documentation, that it was a "mapping error". There is every reason to believe that the public relied upon the general plan as published by the Board of Supervisors. For you to take the word of a developer that a "mapping error" was made and allow a density based on the developer’s view of how he thinks it should have been mapped is ludicrous.
Education issues
The DEIR goes on to state that "This analysis does not take into account the reduction of anticipated students based on typically higher ratio of senior citizens and smaller families in mobile manufactured homes". This is not factually true. In the Acton-Agua Dulce District, we see a higher ratio of children coming out of trailer parks because those who need affordable housing are generally people with large numbers of children.
Fire and safety
Their mitigation is simply cosmetic saying that they will provide fire hydrants, lighting, and visible doors. They will not provide a single sheriff, a single substation or a single constructive item, therefore the impact is permanently to damage the communities. Since these people are at the outside limits of the service areas, they are a worse problem than they would be if they built the project closer to the urban areas.
Fire risk
The concept that fifty homes would be more of a fire hazard than nine hundred trailers is totally illogical, as low density construction provides less possibility of fire spreading from unit to unit. As the proposed development has lots less than forty feet in width with almost no set back from unit to unit, they would burn all nine hundred units en masse as they have done in existing trailer park fires. The likelihood, in a rural area with proper landscaping and proper fuel reduction, of even the fifty homes burning as a unit, is highly unlikely.
In conclusion
The concept that fifty homes would be more of a fire hazard than nine hundred trailers is totally illogical, as low density construction provides less possibility of fire spreading from unit to unit. As the proposed development has lots less than forty feet in width with almost no set back from unit to unit, they would burn all nine hundred units en masse as they have done in existing trailer park fires
Each comment will represent the page number and the paragraph number, when available, in the DEIR.
Summary S-1, project description
The description of the units as manufactured housing is defective, since under the County code mobile homes are used interchangeably with manufactured housing. The DEIR leaves an impression that these would be similar to conventional housing units except they are factory built instead of site built. While thirty percent of the units must be pull-outs from existing trailer parks, 100% could be pull-outs.
Please note these pull-outs do not have to be owner occupied. Under the proposed specific plan a trailer park populated with substandard pull-outs used as rental trailers, owned by the developer, could be built. These pull-out units usually are obsolete and in substandard condition. They consist of the worst of the trailer park residences and are urban blight waiting to happen. They have been "evicted" from their existing parks, indicating that they are considered substandard and a blight where they currently reside.
Summary S-1, fourth paragraph
States that "... the developed area will be on the floor of the canyon...". With reference to illustrated figures 3-5B and 3-5C, which are illustrative of the view from the freeway, particularly 3-5C, show that all of the trailers/manufactured housing visible from the freeway (view B) are on the hillside, and the bottom of the canyon is left undisturbed because that is the habitat of the endangered species.
View A shows the pull-out trailers coming up the side of the mountain, but the drawing does not represent that these are pull-out trailers, but instead represents them as manufactured or stick built homes. The majority of the units are located up the side of the far mountain, therefore the statement in the summary is completely false and misleading.
As to the amount of open space that will remain, the open space is made up primarily of slopes exceeding 50% grade, endangered species protective areas, and other areas that are totally unusable as open space.
What in fact is open space here are areas that cannot be built upon or used for a number of reasons. Residents are restricted to their little trailer park lots and small open areas without any real usable space.
For it to be open space for people to use for recreational purposes, it must be usable for recreation not just simply be space without buildings.
As this is a class 4 fire are, it requires all construction to be class 4, and it is doubtful that relocated mobile homes will meet the class 4 requirement. It is similarly unlikely that manufactured homes using " Fiberboard siding and pitched roofs" would meet the class 4 fire requirements since these are generally restricted to masonry materials and masonry or tile roofs.
Summary affordable housing
It seems the main thrust of this project is affordable housing. While the houses may be cheap modular houses, at no point does the DEIR address the extensive infrastructure requirements and factor them into the total cost.
We have determined by reading the DEIR and talking to the service providers that:
All of these expenses are sizable compared to other alternate sites that are located within areas that have existing water and sewage service. The actual connect fee is independent of the location and therefore is not part of the calculation, but the off-site improvements listed above are important to consider.
These extra site specific costs will raise the price of each trailer site by $68,367. This will price these houses out of the marketplace of anyone in the area because there are other projects that will be far less expensive.
This would increase the space rental just to pay for the mitigation and offsite improvements to $600 per month, in addition to the proposed rental fees of $300 for space and another $500 for a manufactured home. This totals $1400 a month for so-called affordable housing. Housing can be procured in the Palmdale and Lancaster areas for under $600 per month with full ownership.
Mobile home spaces are renting for under $200 in most areas.>
Summary S-2 project objectives
As for providing affordable housing, it will not be affordable housing because these infrastructure and mitigation costs will raise the market rental of the trailer lots to close to $900 dollars just to rent the land without the home cost. This certainly is not affordable housing. Nowhere in the DEIR is there any discussion of how it will be affordable housing. Are we to believe the proponent’s claim that it will be affordable, without any data?
Therefore, the project fails to meet the primary objectives.
Summary S-3 objective, protect and enhance natural landforms
This project does not protect and enhance natural landforms as claimed. Instead, it cuts them down by five million cubic yards of grading. Most of the landforms that exist in the area in view A and view B, previously referred to, are cut down and re-manufactured into home sites using the mega pad concept. The reason that it looks so good on paper is that the areas that will be cut down due to surface mining for sand and gravel are shown as left natural in these views. If this project was coupled with the sand and gravel views, the entire mountains visible are cut away and all that would be left is a ridgeline of mobile homes.
Summary S-3, 2nd paragraph
In reference to the five hundred foot buffer zone, the DEIR states "there will be no grading within the buffer zone, allowing a transitional zone from the developed portion of the site to the natural hillsides". Again, in reference to the proposed Transit Mix project, the buffer zone would exist between where Transit Mix had artificially filled in "fines" on the hills and in no way would the buffer site be the natural hillside. /p>
Summary Page S-5, areas of controversy to be resolved
This does not even state the problems to be resolved. Missing totally are the adequacy of mitigation proposed for the schools, the ability to provide sewer and water service for the project, whether or not it is an affordable housing project or whether it's infrastructure costs would push it out of this realm.
Summary S-6, 2nd paragraph
It makes reference to a trailer park in the general vicinity on the other side of Soledad Canyon Road. That is, in fact, a non residential recreational vehicle park with limited stay that has been allowed by the County. To argue that this facility is a trailer park would violate the LA County code. The claim of an illegal trailer park which somehow condones this as a trailer park is completely incorrect.
Additionally, the DEIR fails to mention the project is next to the community of Agua Dulce which has a Standards District. While this is not within their Standards District, it certainly borders the district. The Standards District requires 2 1/2 acre parcels as a minimum, with all sorts of other restrictions to maintain a rural environment. This project is not even remotely compatible with Agua Dulce’s rural environment. To characterize Agua Dulce as "Vacant land" is an attempt to make their project look better.
Summary S-8, consistency with regional and local plans
While it is consistent with the modified Santa Clarita plan, consistency requires it to also conform to environmental issues. This plan amendment was rushed through without any public hearing on the various changes to it.
It is inappropriate now, as it was then, to locate this type of high density urban development in a rural area without adequate infrastructure or access.
While the plan policy "Encourages the development of manufactured housing and mobile home parks as a means of augmenting the availability of affordable housing", even though it does specifically authorize Bee Canyon providing a specific plan is adopted, it fails to recognize that this cannot be affordable housing because of the extremely high infrastructure costs required to establish the project.
I believe a detailed analysis needs to be prepared showing how any affordable housing could be developed from this site with the infrastructure costs and that should be made part of a revised DEIR before any action is taken on this DEIR.
Summary S-12, flood hazard
The proposed mitigation for flood hazards are inadequate. The SETAC Committee for L.A. County Regional Planning has taken a position that there should be no modification whatsoever of the Santa Clarita River drainage area. This would provide a modification which would not only increase the 100 year flow amount shown under flood hazard, but it would also increase the flooding under lighter rain conditions, as well as increase the speed and ferocity of water entering the river area. This changed flow into the riverbed would seriously endanger the Unarmored Three Spined Stickleback fish. Therefore, the residual impact would still be unmitigated and significant.
Summary S-13, noise
There is no mitigation proposed for the pull-out mobiles which will be located directly next to the freeway. It is also unlikely that their windows will be kept closed constantly, to eliminate the noise as proposed. It is an unreasonable assumption that all windows will be kept tightly shut during summer periods requiring expensive air conditioning. Therefore, the mitigation is not adequate and units close to the freeway would have significant and unmitigated residual environmental impact. Other forms of mitigation such as trees, sound walls and eliminating older units should be used.
Summary S-14, biotic resources
Most of the so-called mitigation is to educate the people not to kill the plants, not to walk in the open space, not to dump stuff on the streets. As a practical matter, people will routinely kill "wild" animals, complain about animals coming into their homes from the wild area, and think nothing of dumping their trash into the storm drains. Some of the mitigation required should be:
Summary S-18, visual qualities
The 30% used for pull-out mobile trailers is claimed to be sited on the down slope from the freeway, as to not be visible from the potential scenic highway. It is my understanding the Antelope Valley Freeway has been designated as a scenic highway and it has been so designated for a long time.
These pull-outs are fully visible as the proposed drawings show, because the entire down slope from the freeway is now currently visible from the freeway.
As to the statement "the project will not remove any knolls or rock outcroppings within the Antelope Valley Freeway right-of-way", I find it difficult to understand how they could remove anything within the freeway right-of-way.
As far as the claim that no ridgelines will be modified by the project, I would suggest a brief look at the drawings showing major modification of the ridgelines in the area. Further, a cumulative impact study must be concluded that would show the look of the project combined with the mining project. It misrepresents the fact that the hills rising above their project will remain in their pristine glory, when in fact most of those hills will be cut down and filled in by the surface mining project.
This will convert the area from a pristine rural view scape, but I am sure they would claim an advantage that you will now be able to see the mountains behind the mountains they will knock down. This will remain an unmitigated and significant impact.
Summary S-22, educational facilities
The entire discussion of educational facilities is inadequate and incorrect as I am sure both the Hart District and Sulfur Springs District will point out to you. The DEIR calculations of number of students per unit are incorrect.
The comments about inter-district agreements is completely inaccurate because a direct quote from the Hart District is that they have never allowed inter-district transfers. The DEIR statement to the contrary, without backup, saying that they have indicated an interest, is at best intentionally misleading.
The mitigation providing it's share of fees under AB-2926 provides less than 5% of the cost of building the additional schools.
The second proposed mitigation is not a mitigation but only an agreement to develop an agreement and it does not qualify as mitigation. It states that "the project component will work closely with the Acton-Agua Dulce Unified School District to provide the necessary permanent buildings".
That is yet to occur, and this does not indicate that they will provide full funding for the necessary buildings and land. The proper mitigation should be that they would pay 100% of the entire cost of facilities required for their new students in this district.
The DEIR has not addressed the additional transportation costs required because the only way between the school and this trailer park is by sending buses three miles into the Sulfur Springs District and doubling back to the site.
Without full mitigation it would double the number of students at the Agua Dulce School and require the district to go immediately to half day sessions and other alternatives. This would provide an inferior education to these students and the local residents. Proper mitigation would be a boundary change for the School District relocating the entire project in the urban Hart and Sulfur Springs Districts with all the costs of the new classrooms paid for by the developer. Bussing would not be a problem, as part of the project is now in those districts.
Summary S-23, fire and sheriff
There is no mitigation planned. The effect of the project is simply to have less protection and longer response time until "A new funding method is obtained". The needed mitigation is very simple, the developer should pay 100% of the costs, on a permanent basis, for the additional Firefighters and Sheriff’s officers required for his development. That is the only thing that would result in proper mitigation.
If the developer wants to use cheap land where there are no facilities, he cannot argue the cheap land will allow affordable housing when it is crime ridden housing.
The taxes on mobile homes are essentially zero, since they are not subject to property taxes, but pay vehicle registration fees.
When one looks at the assessed valuation of trailer parks compared to the amount of services they require, it makes them a liability to a community. This probably explains why they want to pull the trailers out from where they are now located.
The community could have better policing if it had no trailer parks and no apartments, but just single family residences. If you watch many of the realistic cop shows, whenever they go to the scene of the criminals' homes, it is typically a trailer park.
This will have a significant long term unmitigated impact on the community.
Summary S-25, traffic and access
The mitigation measures are totally inadequate. All they are is adding a group of left and right hand turn lanes allowing Soledad Canyon to jog from a two lane highway, to a three lane highway, to a four lane highway, and back and forth. This will only confuse drivers and cause more traffic accidents. LA County recommended that Soledad Canyon Road be increased to a four lane road, along with left and right hand turn lanes. The cumulative impacts of this project and the sand and gravel project must also be considered.
Summary S-35, solid waste disposal
The cumulative impact does not take into account that the Antelope Valley landfill is now accepting outside trash from other areas. The twenty-three year life span for the landfill is incorrect because depending upon how much trash they accept from outside areas, it could be filled in five years. Therefore, included in this DEIR should be whether the landfill will be adequate at it's current utilization and it's proposed utilization.
Summary S-38, library services
This is a breath of fresh air, as it shows that this particular project requires a specific investment of $377,988. Based on the payment per parcel of $10 per year, this will only cover partial operating costs. No mitigation is called for to pay the construction and book costs.
Summary S-40, project alternatives
Of the seven proposed alternatives, every single one of them are preferred from an environmental impact basis.
The seventh alternative, the alternate site, is particularly flawed. They claim the only parcel in the entire Santa Clarita Area that was considered available was a site on the other side of the freeway.
The evaluation of the alternate location failed to state that even this location is less costly to develop because it is closer to existing services. The traffic access is hardly different from the existing project.
Further, a cursory glance at projects available in the entire Santa Clarita Valley would indicate that hundreds of parcels are suitable for this type of development. These other parcels are in areas that have access to water, are within water districts, closer to jobs, and closer to existing transportation. A number of alternative locations should have been evaluated based on the fact that these areas already have the linear services necessary to support high density urban developments.
Summary conclusions S-42
The conclusion that the project will provide affordable housing is just not factually supported by the DEIR. With the high costs of bringing linear services to the site, there can be no affordable housing at this location.
Affordable housing isn't suitable at this location since there are no services or facilities for low income people. Persons living in this development would have to have access to at least two good cars to drive into the community for all types of supplies and services.
As for the proposed project's providing need for relocated mobile homes, one would have to look at an alternative of simply not relocating the mobile homes. It would seem that these older mobile homes could be kept more cost effectively where they are now in existence.
The greed of the mobile home parks, who want to turn their property into a higher value usage, are evicting the units. Mobile home parks are generally used as an interim project to hold and carry property for better use.
The fifth position claiming that the "The proposed project will have greater value as a more concentrated pattern of development, which could reduce the potential for the pattern of low density sprawl, which commits more land for development". If this is an advantage, I have a problem with it because what this project engineer calls low density sprawl is our rural environment. For the DEIR to take a shot at rural environments, claiming they are defective in some area and high density trailer parks are preferable, is pure lunacy.
The claim that traffic improvements will be realized with this alternative is also ludicrous, since there would be no need for improvements if the additional traffic is not produced by the project. The improvements the project is providing will still lead to higher levels of usage on the roads and higher traffic congestion. Even with "mitigation" all traffic is worse than without the project and its mitigation.
To claim this project is economically feasible for the developer because he bought the site cheaply and any alternative is not, is frankly none of our concern. The environmental issues are important, not the profitability of the applicant.
As for arguing the alternate project of low density transitional homes between the half-acre Shadow Pines development and the 2.5 acre Agua Dulce Standards District will not provide long term maintenance is again a slap in the face of private residential homes. On what theory is the claim made that private residents are not maintained over periods of time. Urban mobile home parks are urban blight just waiting to happen and are not a satisfactory buffer between rural and semi urban private homes.
The main report
Page 1
This repeats the statement that "The developed area will be on the floor of the canyon, minimizing grading..". This is factually not true.
Page 5
The method of providing more open space is reducing the size of lots to virtually postage stamps. Most of the lots will be 45X70 feet and are so narrow that only tandem style parking can be provided.
The big lots will be 50X80 feet, or approximately 4000 square feet. A significant number of homes in the adjoining community of Agua Dulce have homes larger than 4000 square feet.
This project will become an untenable urban ghetto and will have insignificant play areas for children and even make life inhabitable. This is the worst type of housing outside of some public housing.
To claim they resemble conventional single family homes is ludicrous because in the urban projects adjacent to this project homes are on 1/2 acre parcels of 23,000 square feet, approximately 5 times larger. In Agua Dulce the lots are 117,000 square feet, approximately 25 times larger.
To argue that urban trailer parks need to get out of areas that are becoming urbanized is highly unlikely, because what is really occurring is greedy developers are closing trailer parks because they intend to convert these into commercial properties as they become necessary. Basically, mobile home parks are a pariah that are disliked in every community because they are not a quality type of housing. >
Page 18
This is an extensive discussion of the overlapping projects for sand and gravel removal and the trailer park. It would seem logical that any approval of this DEIR should be stopped until the DEIR for the sand and gravel project is heard. There is no way that the community or the county agencies could evaluate the projects separately.
As a quotation on page 19 says, "As these two proposals are processed concurrently, the County of Los Angeles will have to evaluate the proposals I recommend the most suitable use of this acreage." This clearly indicates the county cannot make any decision concerning this DEIR until the Transit Mix Company (TMC) DEIR is available for comment.
It also seems quite interesting that the same land owner, a Mr. Curtis owns the property for the trailer park and the TMC project. It would seem, unless both are heard simultaneously, and the Transit Mix project is later approved, it could create an environmental problem for the trailer park. The mitigation for Transit Mix should also include the knowledge whether or not the trailer park would be located adjacent to the property. Therefore, it only reinforces the position that both of these projects must be evaluated together in a single planning decision.
Page 27
The DEIR, shows that the jobs-housing balance in the Santa Clarita Valley has decreased from a level of 0.8 jobs per housing unit in 1984 to a level of 0.66 jobs in 1990. This clearly indicates there is no need for additional housing and particularly for low cost housing because there are no jobs for the people.
Low income families cannot afford the massive commute costs to the jobs available in other areas. In Santa Clarita, with its declining jobs-housing ratio, there is no reason to develop more housing in the area.
From a jobs-housing balance, this zone change is negative because it converts job producing property, M-2 manufacturing property and A-2 agricultural property, into residential property.
Their statement on page 30, the admission that "While individually the proposed project does not improve the jobs-housing ratio...", goes on to make a self serving remark that "considering the county's plan for the sub region as a whole, the proposed project is not inconsistent with the regional growth management plan", when in fact it is inconsistent because it makes the jobs-housing ratio worse.
Page 29
It talks about a regional ability plan with mitigation by the State adding additional lanes to the 14 Freeway, building State Route 126, adding HOV lanes on 14 Freeway and State Route 126, and installing inter-city rail facilities along the I-5 freeway corridor.
All of these save the HOV lanes on highway 14 are pie-in-the-sky programs, not budgeted and not planned with any certainty. The inter-city commuter railway facilities on the I-5 freeway are the high speed rail line which is inter-city only in the sense that it goes from L.A. to Bakersfield non-stop. The discussion here is inadequate and provides no mechanism for financing of this required mitigation.
Page 31
A serious fault appears on page 31, which claims that the Santa Clarita land use element map has an error in it. The land on the map which the public saw and was passed by the Board of Supervisors in 1990 as open space the developer claims is now designated as high density urban space.
This is some lame argument, unsupported by any documentation, that it was a "mapping error". There is every reason to believe that the public relied upon the general plan as published by the Board of Supervisors. For you to take the word of a developer that a "mapping error" was made and allow a density based on the developer’s view of how he thinks it should have been mapped is ludicrous.
In the table starting on page 32, they have a different density allowance for hillside management within a quarter mile of "urban" and outside a quarter mile of urban. It seems to be inappropriate for densities in the calculation and there is no reference to county code sections to allow this density. This area needs to be explained at greater length. Further, the general plan contains language that if this specific plan is not approved, the underlying designation reverts to hillside management.
Page 40
While it points out that Parks and Recreation cannot demand any mitigation because it does not require a subdivision, it does effect the load on county parks because the park facilities in this trailer park are totally inadequate. These units would use the already overcrowded county parks. Vasquez Park has almost no facilities for anyone. It would seem that mitigation for other parks be a contribution to the county parks fund. Further, since there is no subdivision of land it would be assessed a very small fee for Proposition A.
Page 42
The discussion of the undocumented artificial fill fails to recognize this has historically been stated in the community to contain toxic materials and other dumping on site, and this area should be investigated before this DEIR is allowed to continue.
Page 50
There is an inadequate discussion of the Agua Dulce Fault which crosses the site. As a minimum, there should be a 200 foot buffer zone on either side of the fault because it would seem inappropriate to allow weak mobile homes in a fault area. Considering the result of the Northridge fault, large numbers of trailers were set afire due to lack of structural stability. Particularly since their would be a large number of older trailers in the park, locating these old trailers on an earthquake fault would produce an extremely high environmental risk which is not even discussed in the DEIR.
Page 55
This urbanization and conversion of an essentially natural canyon to an urban storm drain, like the L.A. River, would provide a modification in both flood flow and amount of flood in the area. This section contains the normal L.A. County fraud that it's better to develop an area and strip all the vegetation because in a Q-50 storm it would produce less flow if you totally stripped all vegetation from the walls of the canyons.
These only works in the County's warped view, because in the real world environment everyone knows that vegetation keeps a hillside from sliding.
In the County's warped world and their warped calculations that have been thoroughly attacked in other projects proposed in the County, most recently being the Upper Topanga Canyon project called Canyon Oaks, shows that the County's calculations are both defective and inadequate.
The sections under drainage must be completely revamped because any logical person would recognize that there would be more runoff in nearly every possible condition from an area which has been urbanized and compacted to prevent water from settling. The roads carry the water into concrete channels which then rush it by concrete to areas downstream. To argue that this design would produce less flow than the natural state is just unbelievable and would never be sustained in a court. The project fails to take into effect the fines from the mining project which would be stored by the sand and gravel project upstream from the project and would radically increase the amount of runoff of the fines.
Page 60
The claim will have no impact on the river because the Q-50 flows are hardly changed. It does not evaluate the effect of Q-1 flows or Q-2 flows or Q-5 flows which will have a vastly increased speed and arrival of water which will increase flooding downstream. Even though all the developments downstream have been designed to Department of Public Works standards, each year flooding downstream becomes worse, worse and "worser" because their standards are inappropriate for rural communities.
Page 68
The noise discussion on page 68 is particularly defective because it is the engineer's opinion, without any documentation, that modular homes are capable of meeting a 20 DB attenuation requirement. Even though a 20 DB attenuation requirement, as stated earlier, requires 2X4 construction with heavy insulation and double paned windows, most modular homes do not meet that requirement. A specific mitigation which would prohibit any modular homes not meeting a 20 DB requirement should be included.
Also, since it admits that the relocated units are highly unlikely to have the same attenuation, their suggestion is forcing them to keep all windows closed and adding air conditioning. These sorts of costs, compared to the existing value of the mobile homes, make it far cheaper simply to leave them in place than attempt to re-utilize them since they would not meet the noise requirements. Further, affordability would be drastically reduced by requiring 24 hour a day air conditioning without opening windows.
Page 94
It is our belief that both Sierra Highway and Soledad Canyon Road are designated as scenic highways and appear, at least in the Antelope Valley master plan, as designated scenic highways. It would seem illogical that the same route a few miles to the South would loose it's scenic designation in an identical area.
Page 95,
Visual characteristics of the surrounding areas are entirely inadequate. It describes Agua Dulce as a center supporting commercial and industrial establishments. It does not. It refers to the area around as scattered rural residences and narrow canyons near the freeway.
The surrounding area is in fact an attractive rural area, maintained by the first Standards District of L.A. County, to keep it rural and to keep it looking rural.
To an urban developer and an urban engineer it may look like "scattered residences" but it is actually a well-planned community.
The other views in the area are damaged because of the lack of County and BLM control and inappropriate mining. The description of the view simply makes it sound like an urban nightmare. In fact when one makes the turn off the freeway towards Agua Dulce, all these areas become invisible and what is a pristine undeveloped area is the only view visible. The area is now burnt off due to a suspicious fire occurring at the sand and gravel operation just before the environmental hearing was to be held on the project.
The discussion concerning the visibility of the project and what also is in the view path, is completely incorrect. The Bee Canyon Project is located around a bend on Highway 14 from the existing urban areas. It is screened by four mountain ridges before the closest development is visible. The argument that the visibility of their project is urban is fraudulent because any location that can see the project is totally screened from existing urban development by mountains and ridgelines.
Page 96
Their assumptions, that the BLM land or government land will stop future development, are highly unlikely since BLM routinely sells land to developers for development. The areas to the North are in the Agua Dulce Standards District, which would prohibit any urban development and require what has been degradingly called "scattered rural development".
Page 97
The description of the views do not match the simulations in later exhibits. It would appear that the project will be fully visible from the freeway and will convert a pristine natural area, which only eyesore now is the house that should have been knocked down as substandard years ago, into an urban nightmare of trailers.
Page 101
To argue that urbanization has occurred to the South and it should continue forever on the freeway is inappropriate, because the entire purpose of an environmental impact study is to try to minimize the impact.
This project is at the gateway to the two rural communities of Acton and Agua Dulce, who fought an effective battle to keep their communities rural. Therefore, the assumption that this urban creep will continue on uninterrupted is defective and does not represent the fact that the projects to the north have all been designed to deal with the scenic highway element of the Antelope Valley Master Plan, and to deal with the fact that these areas designated as rural in the General Plan. The claim that no guidelines have occurred to the "study route" is completely false, because located up the freeway less than two miles from the location, the highway is designated as a scenic highway.
Page 103
The DEIR does not take into effect that the NOP letter from the Santa Clarita Water District clearly indicates that they cannot serve the project as they have no water available. It further fails to go into a discussion of the improvements necessary to bring water to the site, which includes improving a pipeline for some five and one half miles, plus installing a larger turnout. The cumulative impact of water in the area has not been resolved and AB901 needs to be addressed.
Page 112
There are similar problems for sewage disposal. The mitigation in this case is based only on projections of future expansions that are neither funded nor feasible. The sewage outfall line would have to be enlarged for nearly five miles, which was disclosed in the DEIR because the outfall line is not owned by L.A. County Sanitation. At the moment they are over capacity, there is no relevant location to dispose of the solid wastes which should be examined in this issue. There is no funding to pay for these improvements to the sewage or water plants at the current time.
Page 115
It particularly fails to disclose the nearest connection point at Mountain View East Development is inadequate in size to support the outflow from this project.
Page 123
The educational sections are the most deficient in the entire report. It contains a statement, not backed up by any documentation, indicating that the school districts have agreed in forming inter-district agreements for all students to attend the schools of their choice.
In a discussion with the Hart District, Hart clearly indicates they will not allow and have a practice of not allowing transfers into the district for any reason.
The DEIR goes on to state that "This analysis does not take into account the reduction of anticipated students based on typically higher ratio of senior citizens and smaller families in mobile manufactured homes". This is not factually true. In the Acton-Agua Dulce Unified District, we see a higher ratio of children coming out of trailer parks because those who need affordable housing are generally people with large numbers of children.
In the more expensive homes in the communities of Acton and Agua Dulce, there is a reduction in the average number of children per home over urban homes.
Further, what is not discussed in this section is the relationship of special needs children to regular children. It has been seen in the Acton-Agua Dulce Unified District, that the special needs children come from the trailer parks and from foster care homes. Since the State fails to adequately fund special education, these suck down the funds available for regular students in the area and lower the quality of education within the community.
The comment about the Acton-Agua Dulce School Unified District is again wrong because a full four year high school will be in place by 1996, not 1997. They claim that there are adequate facilities to house the students when in fact there is not. The school district is suffering from a budget shortfall of some four hundred thousand dollars and with no State money to build classrooms, has become extremely crowded and does not have sufficient facilities for the current students.
Page 127
The student generation numbers do not make any sense because the ratio of number of students per manufactured home in the Acton-Agua Dulce District approaches 1.2 as opposed to the 0.8 number quoted.
Page 130
The mitigation measures are entirely inadequate because AB-2926 Fees, represents about 5% of the actual costs of building structures. Their weasel worded statement that they had "Worked closely with the school district to provide the necessary permanent buildings," needs to be changed to the developer will pay the entire cost of the necessary buildings and land.
As to the "In cooperating to form inter-district agreements," all of the three districts serving the project are overcrowded and would prohibit students from transferring into the districts.
Page 131
Fire and Sheriff's protection is simply described as we need a lot more firefighters and sheriff's but this development will mitigate nothing. It would seem the development, to mitigate, should be required to locate and pay for the cost of additional an additional fire station and additional Sheriff's protection. The project, with it's proposed 2.88 persons per dwelling unit would generate the need for at least three new sheriff's officers and an equal number of firefighters.
Their mitigation is simply cosmetic saying that they will provide fire hydrants, lighting, and visible doors. They will not provide a single sheriff, a single substation or a single constructive item, therefore the impact is permanently to damage the communities. Since these people are at the outside limits of the service areas, they are a worse problem than they would be if they built the project closer to the urban areas.
Page 144
It describes the Soledad Canyon Road as needing widening to four lanes to mitigate the existing LOS-E during the mid-morning peak traffic. This project apparently does not intend to widen the road and clearly fails to fully mitigate its impact. The additional traffic caused by this development would cause the need to widen the road to four lanes.
The ingenuous argument that they are not responsible for the existing traffic is meaningless because they produce the additional traffic that causes the area to become a service E or F condition. Without their project it would not be in an E or F condition. Therefore from a mitigation standpoint, they must correct the problem totally, even though it does involve correcting existing traffic conditions.
Page 200
This information is defective on the history of the community. The town of Ravena is a freight siding that currently exists. The community moved from Ravena closer to the gold strike in Crown Valley and named the town Soledad. Soledad was later named Acton to distinguish it from the town of Soledad in Monterey County.
Page 201
It identifies that Bee Canyon was utilized as an illegal public landfill. What the rest of the document does not disclose is that the public landfill includes toxic materials and toxic wastes from other local activities. The admission here in the history section that it was a public landfill is not supported by research throughout the document. Proper investigation of the level of toxicity that exists in the material filled on the site is needed.
Page 205
Along with the qualified Archeologist, a qualified native American Indian of the area should also be employed to observe the operations for appropriate treatment of native Indian finds.
Page 211
Mitigation measures, environmental waste. As the area is sited directly over an aquifer feeding into the sensitive SEA areas of the Santa Clarita River, the specific plan should prohibit automotive repair and maintenance on the site, prohibit oil changing and anti-freeze changing, and prohibit storage of fuel and gasoline in the area to minimize impact to the aquifer.
Page 215
The library discussion here is inadequate because the data has fully changed since this report has been issued, as a fee has now been established per lot. The fee on the lot would need to be compared with the actual usage in determining the shortfall and the shortfall should be made up by additional fees paid by the developer over the life of the project.
Page 220
Summary of Environmental Impact due to the proposed Bee Canyon project. This table is totally inaccurate and inadequate. Clearly both sewage and water service will have a significant impact unless massive improvements are made to these facilities which are not included as a mitigation measures.
There is no mitigation for the educational facilities necessary, only a half constructed statement that they will try to work out the differences.
There is no mitigation for fire protection and for Sheriff protection and inadequate mitigation for traffic access.
This along with the items already admitted to have permanent impact, such as biotic, visual, Sheriff, air quality, and library services, shows this project is not mitigated to an insignificant level.
The alleged benefits are illusionary. An alternative should be considered of using an existing mobile home park to take the used mobile homes.
There is no proof that these would be less costly housing because of the excessively high infrastructure required to locate this urban facility beyond linear services in a rural area. The fees for the 126 Bridge and Thoroughfare Benefit Assessment District would be paid no matter where the project was located therefore, it has no particular advantage for this project.
Page 223
No project alternative. The allegation that this project would be beneficial because of roadway improvements over no project, is illogical since the roadway improvements do not bring the roadways to any better standard than they exist today without the additional project traffic. Therefore, the analysis that the no project alternative would not have the road improvement "benefits" is illogical.
Page 224
The schedule says it all. Of all the alternatives possible, the project itself comes up least desirable. More desirable in the two most important areas are large family single lot which is the current usage in the area.
Alternative 6 and 7, alternative fine storage sites and alternative locations are totally invalid because there has been no effort to really search alternative locations within the entire Santa Clarita Valley, but it refers to an illusionary property which is even more rugged and more rural than this property.
For the significant alternatives 1 through 5 the ratios of improvement range from:
14 to 0 for no project,
13 to 0 for large family lots,
12 to 1 for reduced development,
12 to 1 alternative without the Curtis property,
and even surface mining comes out 8 to 2 better.
Page 225
Large lot alternative. The large lot alternative is clearly the preferred alternative since it provides a reasonable amount of housing which also could be manufactured housing in place, as there is no prohibition prohibiting manufactured housing to be located on single family lots. It would maintain the M-2 zoning to help balance the job to housing balance, and it would not require any channelization of the water eliminating flood control problems. In this way the wash is undisturbed along with the designated protection area for spine flowers.
It produces no traffic problems, and although it does not increase the population to the density desired by the developer, it is a logical development in the area and would form low cost housing for the community. It further eliminates grading from about five million cubic yards to probably less than one hundred thousand cubic yards.>
Page 229
The discussion concerning the schools is improper and inadequate because the reduction of units would also result in either larger units which would pay more dollars per unit because the fee is based on the square footage and it would still provide enough units to make bussing reasonable. The proposed project with it's five hundred kids would require a fleet of ten buses exclusively to itself, whereas the reduction to fifty small houses could be dealt with a single bus.
The discussions concerning fire and sheriff resources are completely inadequate and incorrect.
The concept that fifty homes would be more of a fire hazard than nine hundred trailers is totally illogical, as low density construction provides less possibility of fire spreading from unit to unit. As the proposed development has lots less than forty feet in width with almost no set back from unit to unit, they would burn all nine hundred units en masse as they have done in existing trailer park fires. The likelihood, in a rural area with proper landscaping and proper fuel reduction, of even the fifty homes burning as a unit, is highly unlikely.
Each home has it's own defensible space that can be defended under current fire department philosophies. The nine hundred units tightly spaced would amount to elbow to elbow, and they cannot be defended because there is no defensible space.>
Page 240
This alternative location discussion is defective because SEQEA demands reasonable alternatives to be investigated and there are numerous pieces of property throughout the community which would serve as mobile home parks. There is no requirement that it be a nine hundred unit mobile home park. Two four hundred units or four two hundred units would serve adequately, and in some cases be superior, reducing the impact.
Page 249
All the discussions under section 81 regarding the selection of this project over all alternatives, are totally defective because the assumptions taken are wrong. There is no proof that this will result in any reduced housing costs. There is no proof that there is any demand for this type of housing in the community, and it is clearly indicated that this project produces massive damage to the environment and to the communities that surround it. Simply arguing that they may produce some low density housing without any proof is not adequate.
Page 251
The assumption concerning the relationship between local long time uses that manufactured homes would have a 50 to 75 year life span is incorrect. Most manufactured homes have a lifespan in the 10 to 20 year range because they are built to lesser quality standards than stick homes.
Additionally, the relocated homes are already substandard and already below current energy efficient construction designs. One must assume this project would only have this 50 to 75 year life span with the continued turnover of relocated manufactured homes onto the site and would generally produce more of an environmental impact than stick built homes owned by individuals.
To argue that it is only a "short term irreversible commitment of the land," is completely fraudulent. The land will be destroyed as rural land forever by this project and will be committed to obsolete, high density manufactured housing. This is the type of housing which now forms blight and decay quickly in a community, and over it's life span will range initially from a poor and substandard project compared to private individual residences, to ultimately an urban ghetto that will have to be destroyed.
Page 256
Growth inducing impacts. No discussion is made of the fact that the water facilities and sewer facilities will extend into the community of Agua Dulce which will have a great growth inducing impact. Agua Dulce now is a community protected by a standards ordinance requiring 2 1/2 acre parcels because of the lack of water and sewers. By bringing water and sewers to the border of Agua Dulce, which this project does, an evaluation of the growth enhancement which will occur in the Agua Dulce community by converting it to an urban environment because these linear services are now available, must be included as part of this DEIR.
Page 258
The conclusions are completely inadequate because the only thing limiting urban improvements in Agua Dulce is the availability of water and sewers, and therefore this project, by bringing them into the area, will be growth enhancing and all of it's effects must be included in this project's DEIR.
Page 261
It shows the inadequacies of the DEIR because under organizations and agencies consulted you will note that not a single local community group in the communities of Acton and Agua Dulce were consulted.
In fact, neither of the three school districts operating in the area were consulted either. The consultants primarily were Sikand Engineering Associates, who apparently are the engineers who designed the original project.
Their bias exhibited in this document for the developer is marked and pervasive throughout. The document must be prepared by an independent agency who is not working as the arm of the developer and who would not have made such gross errors as have been made in this report.
It is quite obvious it is biased towards the developer, and does not fairly represent a true understanding of the environmental impacts of the project.
It goes on constantly about how this low cost housing is needed but does not have the consultant show any financial expertise demonstrating that it will be low cost housing. It assumes the large family houses cannot be low cost housing for some incredible reason.
It is so marked with flaws and inaccuracies and out right lies, it should not even be considered and should be immediately rejected. A brief look through the attached letters indicates that both the sewage and water suppliers will not provide service to them. Until they overcome this basic requirement, this project should not even be considered for one millisecond.
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