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HomeMy WebLinkAboutItem 8.4 ECntyPlnDraftGPA&EIP .. e e CITY OF DUBLIN AGENDA STATEMENT CITY COUNCIL MEETING DATE: July 26, 1993 SUBJECT: eomments on East eounty Area Plan Draft General Plan Amendment and Draft Environmental Impact Report EXHIBITS ATTACHED: U1.- Dennis earrington, senior Planner ~. Letter dated June 16, 1993, from Adolph Martinelli REPORT PREPARED BY: ~. staff comments on Draft GPA and EIR RECOMMENDATION: IC. Portion of map of East County Area Plan showing Dublin ~A~ Receive report and authorize staff to send (\I~ comments to Alameda County FINANCIAL STATEMENT: None DESCRIPTION: On June 16, 1993, Adolph Martinelli, Planning Director for Alameda County, sent a copy of the East County Area Plan Draft Environmental Impact Report (DEIR) for review and comments. The comments on the DEIR are due on or before August 4, 1993. A public hearing before the Alameda eounty Planning eommission to review the DEIR is scheduled for August 19, 1993 at 7:00 p.m. at the Dublin city Council Chambers. The East County Area Plan is proposed to supersede the Livermore Amador Valley Planning Unit General Plan and Open Space Element adopted by the Alameda County Board of Supervisors in November of 1977. The planning area consists of 418 square miles including the cities of DUblin, Livermore, Pleasanton, a portion of Hayward and surrounding unincorporated areas. Attached are the Staff comments on the Draft GPA and Draft EIR for review and comment by the City Council. /ECAP2 CITY ~;;;-;~~~;~---------------~~;~;;-;~;-----;~~i~;-Pl~~:r . Agenda File . Housing &- Community Devdopmalt · Policy Planning &- RestaTCh · Zoning Administration &- Enfarcanalt ~: ~' f f c:. F r .0 ' ALAMEDA CO~TY PLANNING rtPARTMENT . Devdopmalt Planning 399 Elmhurst Street, Hayward, CA 94544 (510) 670-5400 FAX (510) 785-8793 June 16, 1993 RECEIVED' J U N ,-lX 1993 OUBLlN PLANNING ;' , :;", Interested Parties: We present for your review and comment the Draft Environmental Impact Report (DEIR) for the East County Area Plan. The Draft East County Area Plan was published in February, 1993, and is summarized in the "Project Description" o~ this DEIR. This document is intended to serve as the DEIR for the proposed revision of the General Plan for the East County Planning Area (formerly the Livermore-Amador Valley Planning Unit) of Alameda County, for the amendment of the Alameda County Open Space Element, and any other changes required in the functional elements of the existing Alameda County General Plan to maintain consistency with the East County Area Plan. This DEIR is a public information document which analyzes the significant environmental effects of the proposed project, identifies alternatives, and discloses ways to reduce or avoid the possible environmental effects. As a program EIR, this DEIR may be used as basis for the environmental review of subsequent projects in the planning area. However, proposals for specific areas or development projects may require further, more site-specific, environmental review. Your written comments on this document are welcome. There is a 45-day period during which you may respond to the DEIR. To be considered in the Final Environmental Impact Report, comments must be received by this office on or before August 4, 1993. A public hearing before the Alameda County Planning Commission to review the DEIR is scheduled for July 8,1993 at 7:00 p.m. at the Dublin City Council Chambers, 100 Civic Plaza, Dublin. Subsequent hearing date(s) will be announced at the hearing on July 8th to review the Final EIR and the Plan itself. If you challenge any of the foregoing described actions in court, you may be limited to raising only those issues you.or someone else raised during the review period and public hearing described in this notice, or in written correspondence delivered to the Planning Department prior to the end of the public review period. . If you have any questions, please call Deborah Stein at (510) 670-6512. 2639P ;f~IY yours, -Mq; Adolph ~ Planning Director n.rA e e CITY OF DUBLIN Po. Box 2340, Dublin, California 94568 . City Offices, 100 Civic Plaza, Dublin, California 94568 July 22, 1993 Mr. Adolph Martinelli Planning Director Alameda County Planning Department 224 w. winton Avenue Hayward, California 94544 SUBJECT: Comments on the East County Area Plan Draft General Plan Amendment and Draft Environmental Impact Report. Dear Mr. Martinelli: Thank you for the opportunity to comment on the Draft GPA and Draft EIR. Comments on the Draft East eounty Area Plan (ECAP) GPA and Draft EIR will be made separately in this letter. DRAFT GENERAL PLAN AMENDMENT The Draft GPA contains several policies which interfere with Dublin's ability to determine land uses within its Sphere of Influence and are therefore unacceptable. Policy 1. This policy states that lithe eounty shall identify and maintain an Urban Growth Boundary that defines areas suitable for urban development and open space areas for long-term protection of natural resources, agriculture and other productive resources, recreation, buffers between communities, and public health and safety. The Urban Growth Boundary circumscribes an area inside of which urban development will be encouraged and outside of which urban development will be prohibited. II The placement of an Urban Growth Boundary around the City of Dublin which prohibits urban development within the City's Sphere of Influence is unacceptable. The Dublin General Plan states with regard to the Extended Planning Area, which would be impacted by Policy 1, that it would consider residential development proposals whose location, extent and density would be determined when municipal services could be provided and through General Plan refinement studies. These studies would permit the eity of Dublin to determine the appropriate land uses within its Sphere of Influence. The placement of an Urban Growth Boundary should properly be made by the City based on such studies. Program 3. This program indicates that the County shall prepare and" adopt a countywide regional element of the County General Plan to promote consistency among local general plans. The element shall be developed in cooperation with cities and shall include a common land use and environmental database, transportation model, and performance standards for new development. The eity of Dublin is concerned that policies may be promulgated that would interfere with local land us~__c;:ontr01L~_!L_ Administration (510) 833-6650. City Council (510) 833-6605. Finance (510) 833-6640. Buill Code Enforcement (510) 833-6620 · Engineering (510) 833-6630 · Planni~ Police (510) 833-6670 . Public Works (510) 833-6630 · Recreation (5, e e addition, land use and environmental databases and transportation models are quite costly. How would the costs of these be borne? Policy 11. Policy 11 states that the County shall monitor the densities and intensities of development approved by the County and cities. If development is being approved at densities lower than what is needed to achieve buildout, the County shall increase the densities for unincorporated lands designated for urban development, rather than modify the Urban Growth Boundary. This policy is unacceptable to the City because it interferes with the land use planning process of the City and puts the city at a disadvantage when negotiating with potential land developers who say they can get a better deal from the eounty. The function of eounty government with regard to land use is to provide a comprehensive, long-term general plan for the physical development of unincorporated lands outside of the spheres of influence of cities. Lands which lie within the spheres of influence of cities should be planned by the cities to which they belong, not the County. Policy 25. This policy supports the development of a Major New Urban Development in Eastern Dublin with a holding capacity of approximately 16,000 housing units and approximately 20,000 jobs consistent with the Draft Eastern Dublin Specific Plan as this plan is proposed to be modified by the East eounty Area Plan. The eity has several concerns about this policy. 1. The Eastern Dublin General Plan Amendment and Specific Plan were adopted by the City Council on May 10, 1993. The project as approved would have 13,941 dwelling units and 22,785 jobs in the year 2010 and 13,941 dwelling units and 31,369 jobs at buildout. This should be reflected in the ECAP. 2. It is not appropriate for the East eounty Area Plan to "modify" the Eastern Dublin GPA/SP. The GPA and SP were approved after several years of studies and public hearings and meetings and represent the efforts of hundreds of concerned citizens of Dublin and surrounding areas. Program 8. This program would encourage Dublin to modify its general plan when it is being updated to achieve consistency with the ECAP policies regarding holding capacity, affordable housing and open space protection and acquisition. The eity is encouraged that the County seeks a measure of cooperation in land use planning on a regional basis but would point out that the process works both ways. The cooperation of the County and the eities within the ECAP should be mutual with the views and policies of the cities holding equal weight with those of the eounty. policies 70 and 71. These policies would encourage the city of Dublin to designate Western Dublin for agricultural or open space uses to serve as, a community separator and to reserve a regional trail corridor connecting the San Ramon wests ide hills with Pleasanton Ridge where consistent with the ECAP. These policies conflict with Policy 1 and the ECAP Land Use Diagram which provide an Urban Growth Boundary which prohibits urban development beyond the boundary. The spirit of cooperation of Policies e e 70 and 71 is belied by Policy 1 which interferes with Dublin's ability to determine its land uses within its sphere of Influence. Policy 72. This policy would designate approximately 3,200 acres in Eastern Dublin as "Resource Management" (agriculture, grazing, open space) towards the establishment of a continuous open space system in East County. To accomplish this, the County would: a. Encourage the City of Dublin to re-designate in the Eastern Dublin Specific Plan and General Plan Amendment all Rural Residential land east of Fallon Road, as well as Doolan eanyon as "Resource Management", consistent with the EeAP. Allowable uses may include agriculture, grazing, recreational, and open space. b. Encourage the City of Dublin to work with the Alameda County Open Space Land Trust to acquire parcels designated Rural Residential in Eastern DUblin, through purchase of fee title or easements with open space fees, by means of dedication and/or through density transfer or other funding mechanisms. c. Require that land use activities conducted within this area adhere to management guidelines developed for the protection of biological resources. This policy conflicts with the adopted Eastern Dublin General Plan Amendment and Specific Plan and with Dublin's ability to determine its land uses within its Sphere of Influence. Policy 172. This policy states that the County shall prepare a Congestion Management Plan in accordance with Congestion Management Program (CMP) guidelines. The CMP guidelines will allow the removal of though traffic and low income family traffic from the traffic counts of congested roadways. That means in reality the road could have an LOS of F but be shown as having an acceptable LOS in the deficiency report. This allows an unrealistic representation of roadway impacts and their mitigation. Policy 179. It is stated that the eounty shall insure that new development is phased to coincide with roadway improvements to insure that traffic volumes on major arterials do not exceed LOS D and that traffic volumes on Freeways do not exceed LOS E. How is the eounty going to insure if the LOS reaches D that no additional building permits will be issued? Figure 6. This figure shows Hacienda Road as extended north of Gleason Drive to Contra Costa County. The figure should be corrected to show Hacienda Drive as extending from I-580 to Gleason Drive only. The TVTC model shows that Tassajara Road and Fallon Road need to be 6 lanes nortq of Dublin Boulevard and eight lanes from Dublin Boulevard to I-580. Based on the TVTC model and your EIR, 1-S80 from Tassajara to Vasco Road needs to be 10 lanes. State Route 84 or a four to six lane arterial generally following the proposed path of the Toll Road should be shown on figure 6 from I-S80 to Antioch. Please correct Figure 6 and any other figures or tables referring to these facilities. e e DRAFT ENVIRONMENTAL IMPACT REPORT The City is concerned about inaccuracies in information in tables, mitigation measures which propose land use programs unacceptable to the city, and transportation issues. Table 3-3. This table should be corrected to show 13,941 housing units rather than 16,473 and 31,369 jobs rather than 20,572 for Eastern Dublin. Table 3-4. The total population, housing and employment figures in this table should be revised to reflect the corrected figures for Eastern Dublin in Table 3-3. Table 5.1-1. It is unclear if this table refers to the year 2010 or buildout for Eastern Dublin. Households should be shown as 13,941 for either year 2010 or buildout. Jobs should be shown as 22,785 for the year 2010 and 31,369 for buildout. Mitigation Measure S.l-l(a). This mitigation measure proposes a modification to Program 1 which would state "Prior to adjusting the Urban Growth Boundary the County shall require findings that the adjustment: 1) is consistent with the policies of the plan, 2) would not promote sprawl or induce further adjustment of the boundary, and 3} would not unacceptably affect visual and open space resources. The city is concerned that development within it's Sphere of Influence, especially any development proposing a change to the Urban Growth Boundary, would be constrained by the County and subject to findings made by County legislative bodies. This policy modification would be unacceptable to the City. Mitigation Measures 5.1-1(b) and (c). These mitigation measures propose a new land use policy that would require a detailed development phasing plan and community facilities plan for Major New Urban Developments prior to approval of specific development plans for the first phase of development. The eity is in favor of phasing plans for development, however the lack of clarity about what areas would be subject to this policy is a concern to the city. Would all unincorporated areas be subject to the policy? Would unincorporated areas within the sphere of influence of a city and proposed to be annexed to that city be effected by means of unfavorable tax sharing agreements? Would areas inside existing cities be effected? The policy should be clarified to state that it would only apply to projects which are proposed to remain within unincorporated areas. Impact 5.1-2. The impact, "Implementation of the plan could conflict with adjacent land uses designated in adopted general plan of ~ neighboring jurisdictions", is shown in the EIR to be mitigated to ,a less than significant level by ECAP policies. This is an exercise in circular logic. The city feels that the ECAP policies in themselves conflict with the Dublin General Plan and in no way mitigate conflicts between County Policies and Dublin's ability to determine land uses within its Sphere of Influence. e e TRANSPORTATION ehapter 5.4, Pages 1 and 11. The text of the DEIR shows Hacienda Drive as continuing north to eontra eosta County. The City's General Plan shows Hacienda Drive extending only from I-580 to Gleason Drive. This should be changed in the text of the DEIR and on any diagrams in either the GPA or EIR. Table 5.4-2 should be changed to incorporate traffic volumes from Hacienda Drive into other roadways. Mid state Toll Road, Page 5.4-2. It is stated that SR84 will be extended all the way from I-68D to Antioch. Also in the same paragraph it is stated that a four or six lane arterial generally following the path of the toll road has been included in the transportation system analysis. Why are neither of the two roads shown in Figure 6? Table 5.4-2. This table shows Dublin Boulevard east of Tassajara Road as having an unacceptable level of service. The DEIR should show how this facility will be mitigated to an acceptable level of service. Also, the TVTC model and the Dublin General Plan show Tassajara Road and Fallon Road north of Dublin Boulevard as six' lane facilities and between Dublin Boulevard and I-S80 as eight lane facilities. This table should be corrected. Table 5.4-3. This table shows I-580 from Vasco Road to Foothill Road as a ten lane facility. This conflicts with Figure 6 of the General Plan Amendment. Figure 6 should be corrected. Page 5.4-19, fourth and fifth paragraph. These paragraphs state that because of funding, environmental, political and physical limitations on increasing roadway capacity that TDM and TRO programs will help improve regional levels of service and relieve congestion on East eounty roadways. The use of TDM and TRO is already included in the TVTC model. Therefore, any improvements to levels of service should come facility improvements or reduction of land use intensity. i.' If you have any questions regarding these comments, please contact Dennis Carrington, senior Planner; Mehran Sepehri, Senior civil Engineer or me. Sincerely yours, Laurence L. Tong Planning Director LLT/DHC cc: Richard Ambrose, city Manager Lee Thompson, Director of Public Works Mehran Sepehri, Senior civil Engineer Dennis Carrington, senior Planner Adolph Martinelli, Alameda County Planning Director .. ",..... // If /f if /~ if I!' i :~~. ~".,.a... /< /~ e " " " " "':"'~ / ;, ;"1 i .~' " . 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