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Item 25 - Draft EIR for Proposed WYROC, Inc. Quarry/Asphalt Plant OperationAGENDA REPORT of Q 'CITY'OF POA' t TO-: Honorable Mayor and Members of the City Council FROM:,James L.-Bowersox, City Mana INITIATED BY Reba W. Touw,: Director of Planning Services z;e- James R. Nessel,, Associate Planner DATE: September 2, 1986 SUBJECT: Draft Environmental Impact Report for the Proposed WYROC, Inc'. Quare fAs halt Plant Operation BACKGROUND As Council. is aware, the Planning Services Department.has been tracking the proposed project since the spring of 1985.. The City has corresponded with the County on several occasions in order to identify Poway's concerns regarding the project. Attachments 2. 3, 4, and ` 5 contain the subject correspondence. It should be noted that abouttwo thirds of the project area is within Poway°'s adopted Sphere of influence, and the balance is within a. LAFCO-designated special study area at this time' (See Attachment 1) . The City° of Powa 's adopted land use and y p pre-zoning for the sphere: area is Rural Residential AAI DU/4, 8 20, or 40 net acres). Staff has reviewed the project's Draftr EIR and has 'prepared a number of comments for Council's consideration.. The official com- ments from; Poway are due to the County by Thursday, September 110, 1986. PROJECT'DESCRIPTION The: proposed. _project will be located on a 237-acre parcel. It. con.-- sis s of an original 143 acres where the asphalt plant operation and, quarrying will take .place, and 94 acres on the west, which are being added as a buffer and source of additional water.; The site is situated on the west side of Highway 67, approximately 1.5 miles south of the intersection of Highway 67` and Poway Road.; It fronts the highway for approximately 1,300 feet.. The project requires the approval of the Mayor Use!Permit and. Reclamation Plan. ®■® SER 2 1986 ITEM 25 )j Agenda Report September 2, 1986 nage 2 The project proponent proposes to operate a borrow pit operation for commercial purposes The objective is to mine approximately four (4) million cubic yards of material highly suitable for use in construction quality materials such as asphalt, concrete, base, and other rock products } The project would be in operation for approximately 25 years,- upon 3 completion oftheproject, the site would be ready for development in accordance with existing zoning and land use requla:tions. The. County's land use under the Lakeside Community Plan is (18) Multiple -Rural Residential (I DU/4, 8, or 20 acres) _SIGNIFICANT ENVIRONMENTAL EFFECTS OF THE PROPOSEDPROJECT/STAFF'S DRAFT COMMENTS Visual Impacts The project site varies in elevation from approximately 1,320 feet along the eastern boundary at Route 67, to about 1,687 feet in the central portion of the property.. This represents an elevational 'relief of nearly 370 feet..' The property is presently viewed directly from 12 existing homes located on the east side of Route 67 and situated at an equal or higher elevation than the project site: The subject property contains five; significant knolls which range in elevation from 1,506 feet to 1,687 feet. These natural topographical features, as a result of the proposed proj.ect,� would be topped and lowered a distance of. between 100 and 20`0 feet. The proposed operation would topographically alter more than 60 acres' of the: project site.. Proposed excavation not only calls for the removal.of the existing knolls, but also the creation of manufactured. -fill slopes which would completely encompass the impacted area. The proj;ec�t' s end. result would appear like Aman- made mesa surrounded by natural topographic features, Draft Comment The City of Poway is extremely concerned about: the significant ..visual impacts the proposed project would have on existing.and planned rural residential. land-usessurrounding the project site, and: from Highway 67 The proposed project is not con- sistent with the current and future land use and character of the surrounding properties_. It would result in a significantly altered landform which appears extremely unnatural amidst the natural topographic features in the area. The Draft EIR concludes that the project would result in visual impacts which are significant and cannot be mitigated., 2 of 21 x SSP 2 1986 ITEM. 25 i. =r 1 Agenda Report September 2r 1986 Page 3 In addition to the grading activities, the sight of large. amounts of construction-related equipment stored and moving on site, will impact the site's visual quality over the 25-year life of the project. While the visual aspects of the proposed project are significant and'unmitigable,"the project would also cause irreversible landform alteration. The City of Poway requests that the. Draft EIR be modified to include a thorough discussionof the potential adverse affects: of landform alteration. The proposed project could cause significant adverse impacts on surrounding properties for the life of the project and. beyond. Environmental. effects in the areas of surface drainage/run-off, erosion/siltation,, downstream sedimentation,. and affects on local groundwater quality should be more adequately addressed, and appropriate: mitigation measures identified. Biological Resources The proposed project would result in the direct loss of existing vegetation and wildlife habitat over 61 acmes of the 237-acre pro- ject site (nearly a 25 percent loss) vegetation types consist of chaparral, grassland, sage scrub>r and oak woodland. The.oak woodland occupies about two acres of the site and extends to the north of theproject site into the riparian habitat of Penasquitos/Poway Creek. The lossi of wildlife, including mammals, reptiles, sensitive birds, and several raptor species, would result directly from the removal of vegetation and rocky hillside environments. Mitigation measures include: the development of a revegetation plan,- -the stock piling of native top-soil, and the avoidance of impacts to off-site canyons (especially Penasquitos Creek) -Even with the - proposed mitigation measure, wildlife in the area would either not' survive or have to relocate because of the presence of noise (.vehicles, machinery, blasting, etc.), and dust over a period of 25 years.. Draft Comment The proposed mitigation measures to reduce the impacts to existing 'biological resources to a level of insignificance would not, in the City's opinion, lessen the cumulative impacts` to biological resources. A n SEP 2 1986 ITEM 25 Agenda Report September 2, 1986 Page 4 r The "no pro7ect" alternative would result in rural residential development of four -acre minimum lot sizes. Therefore, this x alternative provides the highest level, of protection to the resources in question. The Biological Report in the appendix concludes that the project would result in a negative -biologi- cal impact, even with the mitigation measures identified. The City of Poway recommends that a discussion of the cumula- tive biological effects of the proposed -project be included in the Draft EIR. This is believed to be especially significant because of the long duration of the proposed projects Water Supplies The 237 -acre site is not served by a water district, and therefore, will be dependent on.on.-site water r s.our. es forplant opera tion. a I The project, when in full operation, will use approximately 1,650 gallons per day for operational needs including dust control. As originallyproposed, the project -included the production of concrete and would have required five times as much water.. The concrete plant,, according to the Count has: been deleted ;from the � P g y. project. A test well was established near the southwestern corner` of :the project. Test data contained in the appendix to the DEIR indicates that the well yielded 30 gallons per minute, and this is sufficient,to supply the needs of the proposed project. Existing off-site wells, east of Highway 67' were monitored for drawdown conditions. A total of three off-site wells; were accessible and were observed. The observations indicated that the three wells .did not reveal negative drawdown conditions. The testing did not, however, take into account other existing wells in the area whish are either in use or not at the present time. Future groundwater demands of surrounding undeveloped properties are not discussed. Draft Comment The DEIR states that the water demands of the proposed project would not have a.signifi.cant impact on the existing off-site wells. However, the drawdown observations were limited to three existing wells in the area which are currently in use, and did not include all other wells in the area which serve both the domestic and irrigation needs of the residents east of Highway 67. In addition, the statement of 1°adequate" water supply for the project is based on an annual recharge rate and does not consider the non -rainy season or even dry years. Adjacent planned rural residential properties will also place additional demands on groundwater resources, since it is unlikely that water service will be extended to these areas in the future, A n SEP 2 1986 ITEM 25 Agenda Report September 2, 1986 Page 5 The City believes that the DEIR does not adequately address the existing and long-term demands for groundwater in the subject area both east and.west of Highway, 67. Cumulative impacts to this resource should be discussed in terms of the ultimate growth in the area and the availability of water. supplies. The 25-year duration of the project could result in insufficient water supply for other planned residential land uses in the project area.. Traffic Impacts The proposed project-would generate 2.65 trip ends (round trips) for the first two years of operation, and increasing to 345 round trips for the succeeding years of the quarry operation. These trips would consist of product sales (loaded trucks leaving and empty trucks returning), employee traffic, and miscellaneous deliveries:. The sales (truck) traffic would equal 200 round trips for the first two-years and increasing to 280 thereafter. It is projected that 70 percent of the total truck traffic will go north of the project, and 30 percent south. Nearly 80 percent of the northbound traffic is projected to travel to and from westerly destinations via Poway Road. During the first two years, truck traffic added. to Poway Road would equal 120 round trips per day, and would increase to 157 round trips thereafter. This truck traffic would impact Poway Road at peak hours since the quarry, would operate.between 6 a.m. and 6 p.m. daily. The DEIR states that this traffic would only incrementally increase the existing total volumes on Route 67` near Poway Road. It does not however, adequately discuss the actual increase or percentage of "truck"traffic on the subject highway and Poway Grade, in the foreseeable future. Draft Comment The DEIR. states that no significant adverse traffic impacts have been.identified a result of the project. The City strongly urges County staff to reassess, the issue of traffic impacts on regional roads, especially Poway Road and Route 67. The addition of up to 1.60 truck trips (round. trips) per day on Poway Road alone is a significant impact, considering that loaded trucks would be using Poway Grade during morning peak hours when traffic congestion :and safety is already a sign.i.fi cant problem, } SEP 2 1986 ITEM 25 Agenda Report September 2, 1986 Page 6 The. City recommends that the DEIR be supplemented with addi tional. information which clearly identifies the potential truck traffic impacts of the proposed project. This critical infor- mation should be focused on the following areas: ` 1. Actual Increase in Truck Traffic The truck traffic generated from the proposed WYROC pro- f° ject represents a significant increase in the present volume of truck traffic on. Highway 67 in the vicinity of Poway Road. Traffic counts produced by CalTrans'in 1984 on Route 67 south of Poway Roadi indicate: that nearly 600 truck trips per day exis already near, that major inter- section. Of these 600 -daily trips, nearly 100 consist. of trucks of four axles,, and up to _ five axles or more . - `- The i DEIR, should include a thorough analysis of the: actual increase in truck traffic and associated impacts. Also, the DEIR states that the necessary Route 6T highway impro- vements have to be approved by CalTrans The DEIR should j include correspondence from CalTrans which confirms the F timing and feasibility of the required improvements. The Draft EIR should provide an analysis of horizon -year traffic volumes on Route: 67 and Poway Road. The analysisj should discuss the level of service (LOS) at the intersec- tion of Highway 67and Poway Road, and. the percent of truck traffic should be emphasized (at horizon -year) Since the truck traffic would also pass through the City of Poway enroute to Interstate 15, the significantI i`ncr.ease in truck not a would greatly impa°sresi ct Poway` dential areas Of paramount importance, the curve design, safe -speed limit, grade, and physical conditon of Poway Grade should be highlighted. The horizon -year traffic analysis should accurately address the future capacity and timing of regional road improvements, including a discussion of the status of Poway Grade widening, State Route 125, the South Poway Arterial, and the ultimate improvement to Highway 67. The 25 -year duration of the project warrants this analysis The environmental consultant that prepared the traffic impact analysis of the project failed to contact the City of Poway fon information regarding the long-term regional traffic: circulation impacts of the 'project and the timing of regional road improvements. The D'EIR should include a statement from the City of Poway which clarifies the: status and timing of the regional road improvements which, would be necessary to serve the project for its duration. SEP 2 1986 ITEM 25 3 Agenda Report f tit September 2, 1986 Page 7 2 Site Visibility The traffic study in the appendix of the DRIR states that; no significant impacts would result -from the project. This assumes that adequate site distance is provided at 3 the project entrance for both trucks and vehicular access. Also, this assumes that Highway 67into be widened to pro- vide a southbound right-turnla a the project, and northbound left -turn lane into the site:. The DEIR states that the 660 feet of site distance is ade quate, but this does not seem to take into consideration heavily laden a trucks which start from the site's entrances cross the highway, and proceed north on the uphill grade of Route 67 to the Poway Road intersection. - The statement regarding 50 mile -per -hour traffic ontoute 1 6.7 during peak hours is not accurate. An actual traffic speed analysis should be performed and included in the DEIR. Slow moving trucks on highway 67 during morning peak hours would decrease road capacity by increasing congestion 3.. Traffic Safety Both Route 67 and Poway Grade: have a. history of serious injury accidents involving trucks and other vehicles. The increased truck traffic generated by the proposed project could jeopardize the traffic safety of motorists traveling these roads. The Draft 'EIR does not address this issue... The City recommend tkat-the DEIR include a discussion of . this issue. Statistical data, such as'accident records from at least the past five years, should,be provided as well. Emissions Emissions consisting of dust, truck diesel -fuel exhaust, noise (emitted from machinery, and vehicular and truck traffic),, and blasting operations would be generated by the proposed project. ` Draft Comment The DEIR states that the noise emissions. from the project would, be significant based on the proximity of existing and future residences. The City recommends that the project emissions, includirig noise, dust, blasting vibrations, and fumes be ana- lyzed in terms of direct and cumulative impacts. These effects should be quantified for the duration of the project, and should be based on ultimate residential growth in the area. I ' SEP 2 1986 ITEM. 25 i ..r �� L Agenda Report` September 2, 1986 Page , ,8 i- Archaeological Resources The DEIR indicates that no significant archaeological resources were identified on the site based on a surficial investigation.- Draft Comment r_ _ C `While the DEIR states that no significant resources have been . identifiedfrom an initial surface investigation., it is recom- mended that mitigation measures for the project include the following: In the event that a resource of archaeological. signifi- cance is unearthed or otherwise discovered during grubbing or grading operations of the proposed project, such resources should be professionally analyzed for their significance prior to the continuance of grading opera- tions. :Emergency Medical/Safety Services The Draft EIR does not address the provision of safety services including fire, police, and paramedic service. i Draft Comment The Draft RIR does not provide information regarding the provi- sion of emergency medical/safety Services including: fire pro" tection, police, and paramedic service. The City recommends that these crucial services be identified and that: information regarding the service agency, level of service, and emergency response times to the project site,be discussed in detail. RECOMMENDATION It is recommended that the City .Council accept this report and direct Staff to prepare official comments as discussed ,herein 'on the subject Draft EIR. JLBRWT:.JRN:pn Attachments: 1. Project Site/Adopted Poway Sphere of Influence 1' 2. Correspondence- to -Supervisor George Bailey 3. Correspondence to County Board of Supervisors 4. Correspondence to Director of Planning and Land Use 5. Correspondence to County Environmental Staff SEP 2 1986 ITEM : 25 k 8 of -21 r k ' 2 tWAl— R0 -.•moi. :$•:l${':{'•>i: i{:Y....Te: Y . .- i rq.• Y-.� L `' ':;:;{cry:, All '� ':{\]:i:'•? 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District Supervisor San Diego County Board of Supervisors 1600 Pacific Highway San Diego, CA 92123 s Subject: Proposed Material Extraction Project Located Along the t Highway 67 Corridor, Wyroco, Inc. ;II Dear Mr. Bailey: . =i - n behalf of the members of the Cit Council of the City of Poway, 0 Y Y please accept this letter as the City's position paper in regard to the subject matter. Since the Spring of 19850, we have been aware of the subjectproject which is proposed for establishment along the Highway 67 corridor, between.the cities of Poway and Santee. This project is currently being processed by the Department of Planning and Land. Use. were understand that the project requires the preparation of an environmen- tal impact report aid approval of a major use permit and reclamation plan. We also understand, from our review of available project information, that a project of this type has the potential to cause adverse environmental impacts in the following areas o utilities and public services o- land. use and planning considerations o water quality/groundwater resources o agricultural resources - o land form alteration/visual~ aesthetics y o downstream sedimentation o, archaeology resources o- truck traffic-and noise impacts While it is generally the attempt of the lead agency to impose miti- gation measures which reduce these potentialimpacts to a level of insignificance, there is substantial evidence throughout the County of i San Diego that projects of this type cannot be fully-mitigated. Most material extraction operations which exist today are large in magni- I tude and long in. duration. ATTACBNM l ..City Hall Located at .13325 Civic Center Drive `-ling Address: P.O. Box 789, Poway,: California 92064 ' (619) 748-660 _p♦W` } J?&,4 r { George F. Bailey July 28 1986 t Page 2 Amon . g the impacts mentioned above, the City of Poway is extremely con cerned about the ultimate effects on local land use planning, and truck traffic and noise generated from the subject project. Approximately.two-thirds of the Wyroc project.area is within' adopted Sphere of Influence and is generally Poway's 9 Y Planned for resi- dential use under the Poway General Plan. It is conceivable that the balance of the project site could be added to our sphere pending the outccaYe of the LAFCO-designated "special study area" between Santee. Poway and The City of Poway is geographically situated between the Highway 67 corridor and the rapidly developing Interstate 'I5 corridor a Poway is traversed by a three. and one-half mile: segment of Route .67 It is obvs.ous, based on the existing regional transportation network, that truck traffic originating on the Highway 67 corridor would utilize Poway Road enroute west to I-15. It is the City of Poway's contention that the truck traffic generated from the proposed and future extrac ,tion projects utilizing the subject corridor would adversely impact the physical integrity and traffic safety conditions of Poway Road and Highway 67. In addition, the increased. truck traffic and associated noise would also exasperate: the existing traffic conditions on Poway Road as it traverses the City's business and residential areas, e As you know, the City of Poway, following its incorporation in 1980, assumed the maintenance responsibility from the County for the segment of Poway Road between Espola.Road and Highway 67. Prior to this assumption, that road segment commonly referred to as "Poway Grade" was neither designed or built to County road standards, and as a City - maintained road, it still remains inadequate by City standards. Originally intended as a truck pass route, the grade was first constructed using unsatisfactory structural standards and grade and curve design. Over the years the grade has been thinly resurfaced, patched, and repaired from damage caused by erosion and poor road bed composition. Over the past -five years, Poway has expended con- siderable funds to keepthe grade in s passable e P� condition.. At peak a.m./p.m. hours the two-lane gradeis heavily congested, and it is not proposed to be improved to its ultimate width and alignment in the foreseeable future. Any increase in heavy truck traffic on the sub- ject grade would cause further degradation of the road and would have a substantial adverse effect on traffic safety as well. For these reasons, the City has considered closing the grade to all truck traf- fic due to its poor condition. George F. Bailey July 28, 1986 Page 3 In terms of land use and planning considerations, the: City of Poway strongly supports the recently approved recommendations of the SAMAG r Board of Directors in regard to the region's Development Strategy, Relative to the subject matteri, the ` SANDAG Board , at its November 1985 } meeting, endorsed the strategy. It is SANDAG's recamiendation that the rural area located between the Cities of Santee and Poway, and west of San Vicente Reservoir to the San Diego corporate boundary be maintained in its present rural state for the foreseeable future. This support for maintaining the subject rural area is in recognition of the development pressures similar to those which presently exist in the San.Dieguito Valley, which could occur in the near future between Poway and Santee, _ It is our belief that material extraction projects proposed along the Highway 67 corridor would only speedup, the process by negating other. viable planning considerations and by`causing the land to be prema- turely converted or reclaimed for other -than -present adopted land uses. The potential truck traffic alone would impact the subject corridor in the sante manner as if the corridor was in a development made. In conclusion, the City of Poway is strongly opposed to projects of r this type proposed.for location along the Highway 67 corridor, as they would -result in unmitigable environmental impacts to Poway and other communities which are common to the Poway highway. The Cit Council, Y �'' f. therefore, urges your office to strongly consider the 'long-term impactsassociated with this project, and to investigate other areas f within ,the County for the establishment of material extraction operations. S cerely, 41, Carl R. Kruse ' Mayor ,a CRK : mn SEP 2 1986 ITEM.. 25 12 of 21 eiwN `,ITY OF POWA. CARL R. KRUSE, Mayor MARY SHEPARDSON, Deputy Mayor BRUCE TARZY, Councilmember LINDA ORAVEC, Councilmember BOB EMERY, CounciImember December 10, 1985 Walter C. Ladwig, Director County of San Diego Department of Planning and Land Use 5201 Ruffin Road, Suite San Diego, CA 92.123.-1665 1 CP r'- a OF PO ip Subject: Proposed Material Extraction Projects Located East of the City of Poway (Wyroc, Inc. and Woodward Sand and Material Co. Applicants) /T IN THE c Dear Mr. Ladwig: On behalf of the members of the City Council of the City of Poway, please accept this letter as the City's firm oppositon to the subject proposed projects. The City has maintained close contact with your Staff for the past several months_ in regard to these projects. Pursuant to our request, all available project -related information, to date, has been provided for our review. Based upon our review of the Project applications, and supportive planning and environmental documentation prepared by. your. .Staff thus far, the City of Poway believes that these projects, if authorized, would cause long-term adverse environmental impacts. These impacts would not _manly be deleterious to the neighboring communities of Ramona and Lakeside, but would'be significantly more detrimental to Poway's resources, facilities, and residents. The following paragraphs discuss the obvious adverse effects which`would occur as a result of the proposed projects. 1. Wyroc Inc. Application (P85-049 and RP85-05) This project proposes quarry, asphalt plant, and concrete plant operations which would ultimately impact approximately 240 acres of land for a period of 25 years. City Hall Located at 13325 Civic Center Drive ATTACHMENT 2 Mailing Address: P.O. Box 789, Poway, California 92064 • (619) 748-6600, (619) 695.1400 ern 9.tsar ITFM i Mr. Walter C. Ladwig December 10, 1985 A Page 2 The subject land, located about one-half mile south of Poway's corporate boundary on Highway 67, is almost entirely within Poway's adopted Sphere of Influence. The balance of the project area, or the easterly one third of the site, is currently under special study by LAFCO' It is conceivable '= that Poway's sphere would be revised by LAFCO to include the entire project site. Since annexation of these lands to the City of Poway could ultimately occur, the City desires to F see the property maintained in its present rural natural state. It should be noted that both the Poway Comprehensive Plan and the Lakeside Community Plan designate the property for "Rural Residential" land use. This obvious consistency of the planning objectives of the involved jurisidictions further supports the retention of the site in its natural state for future rural residential development, The City is well aware of the adverse environmental impacts which a project of this magnitude would result in of major concern to Poway are the _impacts of land form alteration, and heavy truck noise and traffic on Poway Road and Highway 67. The project proposes the extraction of 45 million cubic -yards of material and the on-site production of asphalt and concrete. The construction materials produced by the project, in the 'City's opinion, would most likely be 4 transported to the rapidly developing 1-15 corridor just west of Poway. It is apparent that the only available transportation route in the foreseeable future: would- be Poway Road.. This heavy truck traffic would not only have a negative impact on the physical integrity and traffic safety of Poway Grade, but would also exasperate the existing traffic conditions on Poway Road as it traverses the City's business and residential areas. To further compound this impact, the project is proposed for a duration of 25 years, and would operate daily (exceptSunday) from 6 a.m. to 6 p.m. 2. Woodward Sand and Material Co.- Application (P85-042 and RP85-04) This project proposes the extraction of about 450,000 cubic yards of material from the floodplain of the Santa Maria Creek. While this project is physically located within the Ramona Community Planning area, and not within the Sphere of Poway, the project's operation would result in significant traffic impacts which would affect the City of Poway for the project's proposed duration of five years. Specifically, the proposedproject would generate a minimum of 28 heavy ^s; truck trips (round trips) per day. These trips would be between the project site in Ramona and the applicant's processing plant located in Lakeside. a SEP 1986 ITE 25 4fz Mr. Walter C. Ladwig December 10, 1985 Page 3 The 28 round trips would represent an average of 56 additional trucks using Highway 67 eight hours each day for six days per week. This activity would continue for a period of five years. As you know, Route 67 is a difficult roadway to negotiate, especially by trucks heavily laden with extracted material. Recent traffic studies indicate that Route 67 is already reaching congestion during peak hours. Accident' statistics for Highway 67 wouldprovide evidence of existing unsafe conditions for motorists. Additional truck traffic on this route would substantially worsen these conditions. We understand that the project would create three sizable borrow pits affecting approximately sixteen acres of floodplain area. Excavation of this magnitude in the proposed location could result -in long-term sedimentation and drainage problems on downstream properties. In summary, the City believes that the subject projects would cause substantial degradation to the natural resources in the project areas, and would also result in unmitigable traffic impacts on Highway 67 and Poway Road. The City of Poway respectfully requests the Department of Planning and Land Use to consider the long-term adverse impacts associated with these projects and to recommend that the applications be denied. rely,. Carl R, Kruse Mayor CRK: js 15of21` SEP 2 1986 ITEM }¢ NI.ITY OF owl y CARL R. KRUSE, Mayor G MARY SHEPARDSON, Deputy Mayor BRUCE TARZY, Councilmember LINDA ORAVEC, Councilmember BOB EMERY, Councilmember �y c January 22, 1986 Honorable Chairman and Members of the San Diego County Board of Supervisors. 1600 Pacific Highway San Diego, California 92123 E Subject: Proposed Material Extraction Projects Located Along the Highway 67 Corridor Dear Mr. Chairman: rman On behalf of the members of the City Council of the City of Pray, please accept this letter as the City's position paperin regard to the subject ratter. For the past several months we have been aware of at least two such projects which are proposed for establishment along the Highway 67 corridor, between the cities of Poway and Santee and the community of Ramona. These projects f (WYROC INC. and Woodward Sand and Material Co., applicants),,, are currently �z beingprocessed P by the Department of Planning and Land Use. Both projects, } as we understand, require the preparation of an environmental impact report t and approval of a major use permit and reclamation plan as. prerequisites to commencing operations. We also understand, from our review of available project information, that projects of this type have the potential to cause adverse environmental impacts in the following areas E i o utilities and public services j o land use and planning considerations o water quality/groundwater resources o agricultural resources , - o land form alteration/visual aesthetics o downstream sedimentation o archaeology resources o truck traffic and 'noise. impacts Vile it is generally he attempt of the affected jurisdiction or lead agency to rose mitigation measures which reduce these impacts to a level of insignificance, there is substantial evidence throughout the County of San Diego that projects of this type cannot be fully mitigated. Most material extraction operations which exist today are large in magnitude and long in duration. AThAG 1V= 3 City Hall Located at 13325 Civic Center Drive R-:�ing Address: P.O. Box 789, Poway, California 92064 ' (619) 748.6600, (619) 695-1400 16of, 21 - SEP 2 986 t T EM 25 _ San Diego County Board of Supervisors January 22, 1986 Page Two Among the inpacts mentioned above, the City of Poway is extremely concerned about the ultimate effects on local land use planning, and truck traffic and noise generated from such projects. Approximately two thirds of the project area is within Poway's adopted Sphere of Influence and is generally planned for rural residential use. It is conceivable that the balance of the project site could be added to our sphere pending the outcome of the 1AFC4-designated "special study area" between Poway and Santee. Zhe Woodward project, while not within the sphere of Poway, would result in a substantial increase of heavy truck traffic on Highway 67. The combined adverse effects of these projects would not only be deleterious to the neighboring communities of Ramcna, Lakeside, and Santee, but would be significantly more detrimental to Poway's resources, public facilities, and residents. 7he City of Poway is geographically situated between .the Highway 67 corridor and the rapidly developing Interstate 15 corridor: Poway is traversed by a three and one-half mile ` segment of Route 67. It is obvious based on the #. existing regional transportation network, that truck traffic originating on x, the Highway 67 corridor would utilize Poway Road enroute west to I-15. It is the City of Poway's contention that the truck traffic generated from the proposed and future extraction projects utilizing the subject corridor would adversely -impact the physical integrity and traffic safety oanditions of Poway Road and Highway 67. In addition, the increased truck traffic and associated noise would also exasperate the existing traffic conditions on Poway Road as it traverses the City's business and residential areas. As you know, the City of Poway, following its incorporation in 1980, assumed the ce responsibility from the County for the segment of Poway Road between Espola Road and Highway 67. Prior to this assumption, that road segment-comnnly referred to as "Poway Grade" was neither de- signed nor built to County road standards, and as a City -maintained road, it still remains inadequate by City standards Originally intended as a truck pass route, the grade was first constructed using unsatisfactory structural. standards and grade and curve design. Over the years the grade has been thinly resurfaced, patched, and repaired from damage caused by erosion and poor road bed composition. over the past five years, Poway has expended considerable funds to keep the grade in passable fi condition. At peak a.m./p.m. hours the two-lane grade is heavily congested, and it is not proposed to be firproved to its q1timate width and alignment in the foreseeable future. Any increase in heavy truck traffic on the subject r grade would cause further degradation of the road and would have a substan- tial adverse effect on traffic safety as well. For these reasons, the City n: has considered closing the grade to all truck traffic due to its poor } condition. 17 of 21 F SEP 2. 1986 ITEM' 25 San Diego County Board of Supervisors January 22, 1986 Page Three In terns of land use and planning considerations, the City of Poway strongly supports the recently approved recommendations of the SANDAG Board of Directors in regard to the Region's Development Strategy. Relative to the subject natter, the SANDAG Board, at its November 1985 meeting, endorsed the strategy. It is SAN AG`S recommendation that the rural area located between the Cities of Santee and Poway, and west of San Vicente Reservoir to the San Diego corporate boundary, be maintained in its present rural state for the foreseeable future. This support for maintaining the subject rural area is in recognition of the development pressures similar to those which presently exist in the San Dieguito Valley, which will probably occur in the near future between Poway and Santee. It is our belief that material extraction projects proposed along the Highway 67 corridor would only speed up the process by negating other viable planning considerations and by causing the land to be prematurely converted.' or reclaimed for other -than --present adopted land uses. The potential truck traffic alone would impact the subject corridor in the same manner, as if the corridor was in a development mode. In conclusion, the City of Poway is strongly opposed to projects of this type proposed for location along.the Highway 67 corridor, as they would result in unmitigable environmental impacts to Poway and other coranunities which are commonto the highway. The Poway City Council, therefore, urges the Board of Supervisors to strongly consider the long-term impacts asso- ciated with these projects on the Highway 67 corridor, ; and to investigate oth- areas within the County for the establishment of material extraction. tions. 18 i j a CITY OF POWAY OF 1 i rBO. EMERY, Mayor L CRUSE.Deputy Ma or u t. BRUCE TARZY, Councilmember t _ LINDA QPAVEC, Councilmember MARY SHEPARDSON, Councilmember � } 11. THF Co August 26, 1985 _s Mr. Charles Lough County of San Diego Department of Planning and Land Use 5201 Ruffin Read, Suite B San Diego, CA 92123-1566 _ SUBJECT: Environmental Review of P85-049 and RP85-05, EAD Log 85-14-51 (WYROC Inc.) Dear Mr. Lough: :I YOU 9 �s Y y Poway regard Thank ou for sending the maternal requested b the Cit of Pawn an r and to the environmental review of the subject Major Use Permit and Reclamation Plan. While the City of Poway Was not initially sent the Notice of Intent to Pxepare a Draft Environmental fact Report for the proposed project, we appreciate the opportunity to now review the proposal and to respond to our concerns prior to the August 29, 1985 hearing before the Planning and Environmental Review Board. The attached map depicts the property which is the subject of the current propo- sal. Please notice that the westerly, approximately ane half of the site is j within he City of Poway °s adopted Sphere of Influence. The balance of the Property is within an. area designated by IMCO as a "Special. Study Area.n Because the subject area could someday be eligible for annexation to the City of Poway, the City is extremely concerned about the project and its potential adverse environmental impacts. The attached letter of June 27, 1985 to the prof- ect proponent, in which the concerns of the County were enumerated, covered -' several areas of environmental impact which the City of Poway is in complete concurrence with r The project is significant in that its effects will impact surrounding land uses for a protracted period. of time. For instance, the, adjacent lands within the Sphere of Poway are presently planned for rural residential use. Therefore, we are concerned about present and future impacts on surrounding land uses, as well as the proposed reclamation program over the next 25 Bears. Insummary, the City of Poway co.ncurs. with all. of the County's environmental . { concerns, but requests that the Draft Ehvirotal impact Report also addresses the following additional topics: 1. Geological Makeup of the Site .� 2 Hydrology, Water Quality, and Groundwater Resources 3. Land Use: and Planning Considerations 4. Utilities and Public Services City Hall Located at 13325 Civic Center Drive ATMaD= 4 ` ring Address::'.?. Vin;: 789. Poway, California 9246 (619) 748- 2(61 .69.��IaR i5 2 of 2 Mr.: Charles Lough August 26, 1985 Page 2 In closing, we respectfully request that a copy of the subject project's Draft EIR is made 'available to us during the public review period, and that we are notified of future actions by the County inregard to this project. Please feel free to contact rre. if you wish to further discuss this matter. Sir1cerely, It • ing Services BKH JRN:is cc: Walter C. Ladwig, Director Sonja P. Itson, Chief of Regulatory Planning James L. Bowersox, City Manager John. D. Fitch, Assistant City Manager SEP 2 1986 ITEM -.R r FF.