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TO:HONORABLE MAYOR AND COUNCILMEMBERS
FROM:DIRECTOR OF PLANNING, BUILDING & CODE ENFORCEMENT
DATE:DECEMBER 3, 2002
SUBJECT:BORDER ISSUES STATUS REPORT
Staff Coordinator:Kit Fox, AICP, Senior Planner
Review the current status of border issues, and provide direction to the City Council Committee and Staff.
The following is the regular monthly report to the City Council on various "border issues" potentially affecting the residents of Rancho Palos Verdes.
Current Border Issues
Rolling Hills Covenant Church Expansion, Rolling Hills Estates
On November 7, 2002, Staff forwarded the attached comments on the draft Environmental Impact Report (EIR) to the City of Rolling Hills Estates. At the Mayor’s suggestion, Staff added comments regarding the traffic analysis for the project. We noted that the trip generation assumptions for peak-hour Sunday traffic were based upon a single observation nearly three-and-a-half years ago. We also asked for the analysis of affected nearby intersections to be expanded to include the intersection of Palos Verdes Drive North and Western Avenue. The 45-day public comment period for the draft EIR ended yesterday (December 2, 2002), and we expect that a draft Final EIR will be available for review some time after the first of the year.
San Pedro Facility Restoration Advisory Board, US Navy/Los Angeles (San Pedro)
At the November 5, 2002 City Council meeting, Staff reported that the impasse regarding the transfer of the former Navy housing sites to the City of Los Angeles had been broken. We also noted that the Harbor-UCLA Research and Education Institute (REI), which was slated to redevelop approximately 46.5 acres of the Western Avenue housing site, had withdrawn its plans for the site. Councilmember Clark asked Staff to investigate what would become of this portion of the property under the terms of the 1999 reuse plan with the withdrawal of REI.
Staff contacted Los Angeles City Councilwoman Janice Hahn’s office since Councilwoman Hahn was instrumental in breaking the impasse to allow the property transfer to proceed. Councilwoman Hahn’s Staff informed us that, with the withdrawal of REI, the 46.5 acres and 190 dwelling units previously allotted to it would be put up for bid sale by the Navy, perhaps as soon as early 2003. Staff confirmed this with Navy personnel. Staff will continue to monitor the transfer and future development of both former Navy housing sites.
New Border Issues
There are no new border issues on which to report at this time.
Joel Rojas, AICP, Director of Planning, Building and Code Enforcement
Les Evans, City Manager
Border Issues Status Report
EIR comments for the RHCC expansion project
BORDER ISSUES STATUS REPORT
Revised December 3, 2002
CONSTRUCTION OF A RECREATION FACILITY AT HARBOR HILLS (COUNTY OF LOS ANGELES AND CITY OF LOMITA)
The County has proposed construction of a 12,650 square foot recreation facility for the Harbor Hills Housing area. The $2.3 million project will consist of a gym, two multi-purpose rooms, a recreation office, sports equipment storage, a child care area for 36 pre-school children, a sheriff’s patrol office, a full service kitchen, restrooms and locker rooms. It will also include a 75-space parking lot.
Homeowners in Peninsula Verde were not offered adequate opportunity to comment on the project and have turned to the City to intercede on their behalf. A community meeting took place at the Harbor Hills Community Center on August 27, 2001 and was attended by then-Mayor Lyon and then-Mayor Pro Tem McTaggart as well as homeowners from Peninsula Verde. In addition to strong objections to the County’s notification process for the project, the homeowners expressed concerns about lighting intensity, times of operation, children crossing PVDN, traffic, unsavory activities near the Lomita water tower and location of the recreation facility. A second meeting took place on September 12, 2001 to allow the County Regional Planning Department to go over the environmental approval process conducted for this project. The then-Mayor represented the City at this meeting. Issues raised by the homeowners included concerns about the notification process, environmental clearances and parking and grading on the hillside adjacent to their homes.
In response to concerns from then-Mayor Lyon and then-Mayor Pro Tem McTaggart, Supervisor Knabe became involved in the matter. At their meeting on September 25, 2001, the County awarded the construction contract for the community center. However, in response to the concerns of the then-Mayor and then-Mayor Pro Tem, Supervisor Knabe, at the October 9, 2001 Board meeting received approval of his motion to: "Extend the time period for the Executive Director of the Housing Authority to report back to the Board from 30 days to 60 days regarding the Cities of Rancho Palos Verdes and Lomita’s specific concerns related to the planned construction of a community center and childcare center at the Harbor Hills Public Housing Development; and instruct the Executive Director of the Community Development Commission to postpone commencement of any construction until the Board further review the matter."
On Monday, October 22, 2001 then-Mayor Lyon and then-Mayor Pro Tem McTaggart joined five or six Peninsula Verde residents and an equal number of Harbor Hills residents to discuss possible modifications to the Community Center plans. County Community development staff made the presentations, but Supervisor Knabe’s office was represented as well as County Counsel and the County Geologist. Harbor Hills’ staff was also in attendance. The County proposed relocating the 75-space parking lot away from the Peninsula Verde homes. In addition, they proposed reduced lighting in the parking lot. Our residents were pleased with these changes, but disappointed that the Community Center building could not be relocated further from the property line.
The City Attorney reported on her research into the environmental process in closed session at the November 7, 2001 City Council meeting. The City geologist also provided his comments on the project grading at the November 7, 2001 meeting. The City Council directed the City Manager to prepare a letter to Supervisor Knabe pointing out that the 60-day period within which the Board is expected to receive a report from the Housing Authority would expire on November 22, 2001. Prior to the expiration of the 60-day period the Council asked for assurances from the Supervisor, in writing, regarding design and operational changes. The letter, signed by former Mayor Lyon went out on November 12, 2001. So far there has been no response, although Dick Simmons, of the Supervisor’s office, has indicated that a letter is forthcoming. In addition, at the request of Dick Bruner (Peninsula Verde HOA) staff discussed the project with the City Manager of Lomita in mid-December 2001. Mr. Odom was aware of the project and said the proposed parking lot revisions were being reviewed by the Lomita Planning Department. He was not aware of any special interest in the project on the part of his Council or citizens groups.
On January 10, 2002, the City received the promised letter from Supervisor Knabe regarding design and operational changes to the project. These changes include relocation of the parking areas, the use of shorter lighting fixtures and lower illumination levels in the parking areas, limitations of the days and hours of operation for special events and child care services, dedication of two Sheriff’s deputies to the on-site field office, and adjustments to the building roof form and landscaping plans to reduce the impact of the project upon views from City residents in the Peninsula Verde community.
On April 2, 2002, the City received a copy of a memorandum from the Housing Authority to Supervisor Knabe’s office regarding the project schedule for the Harbor Hills Community Center. The project was scheduled from review by the City of Lomita Traffic Commission and Planning Commission in April 2002 and May 2002, respectively. Pending these approvals, the County intended to begin construction by early Summer 2002, with completion of the project to take approximately one year. Staff intends to monitor this project to ensure that the promised design and operational changes discussed above are implemented.
On May 13, 2002, Staff attended the City of Lomita Planning Commission hearing for the Harbor Hills Community Center (Site Plan Review No. 954). Several residents of the Peninsula Verde neighborhood addressed the Planning Commission with their concerns, including noise, geology, security and construction impacts. Staff also addressed the Planning Commission, suggested modifications to some of the proposed conditions of approval, and provided copies of letters from Supervisor Knabe and our geotechnical consultant, Zeiser Kling, to be included in the public record. The Planning Commission decided that it needed additional information from the County with respect to previous environmental analysis, noise, crime statistics for Harbor Hills and an alternate site plan suggested by Lomita Planning Staff. The matter was continued to the next Lomita Planning Commission meeting, which was held on Monday, June 10, 2002.
At the June 10th Lomita Planning Commission meeting, the Planning Commission heard additional testimony from the County and from Rancho Palos Verdes and Lomita residents. As a result, the Planning Commission conditionally approved the project, including conditions of approval that were recommended by the City of Rancho Palos Verdes. The Lomita Planning Commission was scheduled to adopt a resolution finalizing this decision—and starting the 15-day appeal period—on July 8, 2002.
On July 8, 2002, the Lomita Planning Commission adopted Resolution No. 2002-2 conditionally approving the site plan review application for the Harbor Hills Community Center. This action was almost immediately appealed by a Lomita resident. The Lomita City Council conducted a de novo hearing on the matter on August 5, 2002, denied the appeal and upheld its Planning Commission’s conditional approval of the project. The Lomita City Council subsequently adopted a Resolution conditionally approving Site Plan Review No. 954 on August 19, 2002.
RE-VITALIZATION OF THE GARDEN VILLAGE SHOPPING CENTER ON WESTERN AVENUE AT WESTMONT DRIVE (CITY OF LOS ANGELES)
The Garden Village revitalization project was approved by the Los Angeles City Council on June 8, 2001. The project, located on Western Avenue north of Westmont Drive, will add 2000 square feet of retail space to a reconfigured shopping center to be anchored by a "super" Albertson’s.
The Border Issues Committee was particularly concerned about the underlying soils and drainage conditions in the project area that includes both the City of Los Angeles and the City of Rancho Palos Verdes. Therefore, at the meeting of June 16, 2001 the ad hoc committee recommended that the City Council authorize a study of these geologic conditions and whether or not the Garden Village revitalization project will have any adverse impacts on existing properties in our City. The Council authorized the study and funding of $10,000. In addition, City Staff researched the issue of the adequacy of the environmental process for the project.
The statute of limitations has run on the environmental documentation prepared for the Garden Village project. The City Attorney advised us that we have no recourse from that avenue. Bill Cotton, the geologist who reviewed the geology and soils information provided as part of the project design, has completed his review of the geotechnical reports associated with the Garden Village project. Mr. Cotton is concerned that there are inadequate long-term geotechnical measures to mitigate the impacts of future settlement on existing storm drain and sewer lines on the Garden Village’s property. Mr. Cotton’s concerns were also voiced by the developer’s geologist during the project planning phase.
City staff has attempted to find out which Department or person in the City of Los Angeles hierarchy has been assigned the responsibility for inspection and monitoring conditions of the development related to settlement and possible storm drain damage. Although we have talked with many City of Los Angeles employees and have been treated courteously, no one has accepted the responsibility. Accordingly, Staff prepared letters to:
Andrew Adelman, General Manager
Department of Building and Safety
Vitaly B. Troyan, City Engineer
Con Howe, Director
Department of Planning
The letters were all similar in that they expressed the City’s concern over the repair and inspection of the storm drains and asked who is responsible for ensuring that the lines are properly monitored. Should we not receive an appropriate response we will recommend that the City Attorney take up the matter. The letters were mailed on November 29, 2001. We did receive a telephone call from Tom Stevens from the office of the General Manager of Building and Safety on December 19, 2001 offering assistance. A follow-up call to Mr. Stevens on January 2, 2002 was made in which we were assured that he was still working on a response to our inquiry.
In addition, Staff has maintained contact with the San Pedro Office Manager of the Department of Building and Safety and the Plan Checker for the Albertson’s market. No building permit for the market has been issued, although the plan checker has approved the plans.
On January 16, 2002, the City of Los Angeles Department of Building and Safety, Grading Section required that the developer of the Garden Village Shopping Center agree to the following condition in order to proceed with placing caissons:
Prior to commencement of structural framing, all underground utilities located within or adjoining the site shall be inspected, repaired or replaced, and sealed to prevent infiltration, as recommended.
Before proceeding with the caisson work the developer was required to sign an Affidavit guaranteeing the maintenance of the Albertson’s building site. The Affidavit states:
I am (We are) fully aware of Settlement and Cracking may occur in the parking lot and hardscape areas due to underlying fill and alluvial deposits and assume full responsibility for periodic inspection, maintenance and repair.
The shopping center developer also agreed that he/they would inspect, or arrange for the inspection, of the public storm drain and sewer line on the property during the course of construction. The developer does not agree to assume responsibility for any repair of these utilities. Prior to commencement of structural framing, all underground utilities located within or adjoining the site shall be inspected, repaired or replaced, and sealed to prevent infiltration, as recommended.
According to Mr. Richard Fortner, Senior Building Inspector for Special Projects, the developer has completed the inspection, however, the report has not yet been submitted. It was Mr. Fortner’s position that any deficiencies in the subsurface utilities will have to be repaired either by the City or by the developer prior to occupancy of the new market.
On May 20, 2002, the City received notice from the City of Los Angeles of the approval of a zone boundary adjustment (ZBA) for the Garden Village shopping center. Apparently, the conditions of approval for the shopping center renovations included the requirement for the adjustment of the boundaries between the three zoning designations that cover the shopping center site. The purpose of ZBA is to adjust the existing zoning boundaries—which are based upon the previous configuration of the shopping center—so that they conform to the footprint of the renovated shopping center. The Planning Director for the City of Los Angeles approved the ZBA on May 17, 2002, and the appeal period for this action was set to expire on May 31, 2002. However, on May 28, 2002, Rancho Palos Verdes resident April Sandell appealed the approval of the ZBA.
On June 20, 2002, the City received confirmation from the City of Los Angeles Building and Safety Department that all of the underground utilities on the site were "in good condition, with no repairs needed." The letters from the City of Los Angeles to the developer noted that the storm drain and sewer lines under the shopping center had been repaired by the City of Los Angeles. Staff subsequently confirmed that these lines had actually been replaced, rather than simply repaired. As such, consistent with the discussion above, the developer will be able to obtain a certificate of use and occupancy for the new market once it is complete.
At the July 2, 2002 City Council meeting, the City Council considered its position with respect to April Sandell’s appeal of the ZBA, and decided not to take an official position on the matter. The Harbor Area Planning Commission considered the appeal on July 16, 2002, denied it and upheld the City of Los Angeles Planning Director’s conditional approval of the ZBA for the Garden Village shopping center.
PROPOSED EXPANSION OF ROLLING HILLS COVENANT CHURCH, 2222 PALOS VERDES DRIVE NORTH (CITY OF ROLLING HILLS ESTATES)
In late 2001, the project was still in the information-gathering phase. According to our information, the applicant was making changes to the project so the exact proposal had not been finalized. Generally, the project involves the construction of a new sanctuary building that would accommodate 2,250 seats, along with a new 3-5 level parking structure with 500 parking spaces. The Church also proposes to convert the existing sanctuary to a gymnasium/multi-purpose room for events such as wedding receptions. The preparation of the Initial Study was still underway to determine whether the project will necessitate an EIR or Negative Declaration. We expected to receive a notice when either document was prepared and circulated to the public.
On February 9, 2002 an article appeared in the Palos Verdes Peninsula News regarding an EIR scoping meeting for the Rolling Hills Covenant Church expansion project. Although Staff did not attend the scoping meeting on February 12, 2002, we did download a copy of the Notice of Preparation (NOP) and Initial Study from the Rolling Hills Estates’ web site (www.rollinghillsestates.com). The Initial Study identified a number of potentially significant environmental impacts in the areas of air quality, noise, public services, utilities, aesthetics and transportation/traffic. The deadline for public comments on the NOP was February 28, 2002, so on February 22, 2002 Staff forwarded comments to the City of Rolling Hills Estates. We expected that a draft EIR for the project would be available for further public comment some time in Summer 2002.
On August 26, 2002, the City received a revised Notice of Preparation for the Rolling Hills Covenant Church expansion project. The most significant project revision was the proposed export of 30,000 cubic yards of material from the project site to the adjacent Green Hills Memorial Park in the City of Rancho Palos Verdes. With the proposed inclusion of Green Hills as the repository for the export of material from the project site, the City of Rancho Palos Verdes’ role in the review of this project was changed from "trustee agency" to "responsible agency." Accordingly, on September 6, 2002, Staff forwarded additional comments to the City of Rolling Hills Estates, focusing on the issues of soil stability, air quality, hazardous materials and noise. The City of Rolling Hills Estates expected to release the draft EIR for this project in late September or early October of 2002.
On October 16, 2002, the City received the draft EIR for the Rolling Hills Covenant Church expansion project. The revised project description included 20,000 cubic yards of export of material from the subject property to the adjacent Green Hills Memorial Park. The Rolling Hills Estates Planning Commission conducted a public workshop on the draft EIR on October 23, 2002, which was attended by Staff and more than fifty other interested persons. At the workshop, Rolling Hills Estates Staff presented an overview of the CEQA process and the draft EIR, representatives of Rolling Hills Covenant Church presented a summary of their proposed project, and an opportunity was provided for public comment on the draft EIR. The draft EIR includes detailed analysis of several potential environmental effects of the project, covering the topics of land use and planning, aesthetics, traffic, circulation and parking, air quality, noise, public services and utilities. Staff presented preliminary oral comments on the draft EIR at the workshop, focusing on the issues of soil stability on the Green Hills site, air quality impacts related to the proposed export to Green Hills, and the discussion of project alternatives in the draft EIR. The 45-day public comment period for the draft EIR ended on December 2, 2002, and Staff prepared more detailed written comments that were submitted to the City of Rolling Hills Estates on November 7, 2002. These comments included the items in the draft EIR comments reviewed by the City Council on November 5, 2002, as well as additional comments regarding the traffic impact analysis for the project, as suggested by Mayor McTaggart.
TENTATIVE TRACT MAP NO. 52666, 3200 PALOS VERDES DRIVE WEST (MARSHALL ESFAHANI AND CITY OF PALOS VERDES ESTATES)
City Staff has been in contact with the City of Palos Verdes Estates to discuss the construction traffic that will be generated from the newly-approved residential tract on Palos Verdes Drive West at the border of our City. The City of Palos Verdes Estates indicates that they will allow construction traffic related to grading to enter their city since the disposal site for the project will be within the City of Palos Verdes Estates. However, any other construction traffic leaving the site will not be permitted to travel through the City. The City of Palos Verdes Estates is insisting that a cut be made in the median to accommodate the construction traffic. The applicant, Marshall Esfahani, seems confident that he can negotiate more reasonable terms with the City of Palos Verdes Estates. So far he has apparently not been able to do so.
Public Works Staff had further discussions with the City of Palos Verdes Estates in September 2002. It appears now that, in addition to the issue of construction traffic discussed above, the City of Palos Verdes Estates objects to the design of the proposed street that would serve this tract because its construction would appear to require grading upon adjacent Palos Verdes Estates’ city property. The Director of Public Works believes that the proposed road—and possibly other portions of the approved tentative tract map—will need to be modified to avoid these off-site grading impacts. The Director of Public Works has notified Mr. Esfahani of this situation.
PROPOSED SOUTH COAST COUNTY GOLF COURSE ON FORMER PALOS VERDES LANDFILL (COUNTY OF LOS ANGELES AND CITY OF ROLLING HILLS ESTATES)
On November 26, 2001, Planning Staff attended an environmental impact report (EIR) scoping meeting for the proposed Palos Verdes Golf Course in the City of Rolling Hills Estates. The County’s Parks and Recreation Department is the lead agency for the EIR, with the actual document preparation being handled by the consulting firm, ESA. The project proponent is a development consortium, headed by Rob Katherman, which has a 2-year contract with the County to complete the land use entitlement process for the golf course.
The project site is the 160-acre former landfill located between Crenshaw Boulevard and Hawthorne Boulevard. Existing activities on the site include a co-generation and recycling facility for the old landfill, as well as the City of Rolling Hills Estates’ equestrian center. The developers propose an 18-hole, par-72 golf course and a 29,000-square-foot clubhouse. The contract with the County also requires the developer to provide a 7,000-square-foot area for an equestrian center in the immediate area surrounding the golf course, although the exact location of the new equestrian center has not been determined.
A major issue of concern raised by the ±150 people in attendance at the scoping meeting was the disposition of the existing equestrian center and trails on the site. Additional issues of concern included drainage problems for downslope properties in the City of Torrance; geologic concerns about the stability of the old landfill; health concerns regarding toxic materials and methane gas from the old landfill; concerns about the operation of the golf course such as noise, lighting, traffic and security; and construction-related impacts such as air quality, noise, vibration and truck traffic.
The developer’s consultant, ESA, anticipated that the Initial Study (IS) would be complete in early December 2001 and that a Notice of Preparation (NOP) for the EIR would be released at that time. The 30-day comment period for the NOP would end in early-to mid-January 2002, with expected public release of the draft EIR in late Spring 2002 and possible action by the County in Summer 2002. It was Staff’s impression that the November 26th scoping meeting was somewhat premature since the IS was not complete and the NOP had not been released. Staff also believed that this schedule may be overly optimistic, given the level of public concern expressed at the scoping meeting, and that it is more likely that the County will make no decision until some time in the fall. As of the end of January 2002, Staff had yet to receive a copy of the NOP for this project.
On February 11, 2002, the City received a copy of the NOP and Initial Study for this project. The deadline for public comment on the NOP was originally March 12, 2002. The Initial Study identified a number of potentially significant environmental impacts in the areas of air quality, noise and transportation/traffic. Based upon the review of the Initial Study, Staff has identified further significant concerns in the areas of hazards and hazardous materials, hydrology and water quality and recreation. These concerns were reflected in a draft comment letter that was reviewed by the City Council on February 23, 2002. Since that date, Staff received additional information regarding the former Palos Verdes landfill, and the draft NOP comment letter was revised to incorporate this additional information. Also, Staff contacted the County on February 26, 2002 to request a 30-day extension of the comment deadline for the NOP. As of late February 2002, the County had not yet responded to the City’s request. Therefore, Staff requested the City Council’s final input on the draft NOP comment letter on March 11, 2002 so that the comments could be submitted to the County Parks and Recreation Department by the March 12th deadline in the event that an extension was not granted.
On March 6, 2002, the County informed us that a 30-day extension of the NOP comment period had been granted. The new deadline for comments was April 11, 2002. The City Council took a final look at the draft NOP comment letter for this project on April 2, 2002. Based upon the City Council’s comments, a final comment letter on the NOP was forwarded to the County on April 5, 2002.
On June 4, 2002, the City received a packet of information from the County Sanitation Districts regarding the Palos Verdes Landfill. The packet consisted of eight fact sheets issued by the Department of Toxic Substances Control (DTSC) between May 1990 and October 1995. The fact sheets were prepared and distributed in order to inform the public of the plans to identify, investigate and remediate any potential migration of contaminants from the Palos Verdes Landfill.
PROPOSED DEMOLITION AND RECONSTRUCTION OF RE/MAX OFFICE BUILDING, 2483 PALOS VERDES DRIVE NORTH (CITY OF ROLLING HILLS ESTATES)
On April 16, 2002, the City received a copy of the Notice of Preparation (NOP) and Initial Study for the RE/MAX office building project in the City of Rolling Hills Estates. The project proposes the demolition of the existing, single-story 2,000-square-foot building and parking lot, and the construction of a new, single-story 5,950-square-foot office building. The project requires a number of discretionary approvals by the City of Rolling Hills Estates, including a General Plan Amendment and Zone Change, a Minor Deviation from the minimum site area for commercial development, a Precise Plan of Design and a Grading application for the importation of 5,700 cubic yards of fill.
The Initial Study identified a number of potentially significant environmental impacts in the areas of land use and planning, earth resources, water, air quality, transportation and circulation, biological resources, risk of upset, noise, public services, utilities, aesthetics, cultural resources, and recreation. It should also be noted that this project is just down the street from the Rolling Hills Covenant Church, which is also proposing a major expansion (see discussion above). The deadline for public comments on the NOP for the RE/MAX project was June 3, 2002. Staff intended prepare comments on the NOP and forward them to the City of Rolling Hills Estates.
On May 21, 2002, Staff forwarded the NOP comments to the City of Rolling Hills Estates. These comments identified potential issues of concern in the areas of geological problems, transportation and circulation and hazards. Staff intends to review the draft EIR once it is available and provide further comments on this project.
PROPOSED BUTCHER RESIDENTIAL SUBDIVISION, PALOS VERDES DRIVE NORTH BETWEEN PALOS VERDES DRIVE EAST AND MONTECILLO DRIVE (CITY OF ROLLING HILLS ESTATES)
On July 10, 2002, the City received a Notice of Preparation (NOP) and Initial Study for the proposed Butcher residential subdivision in the City of Rolling Hills Estates. The subject property is a 6.41-acre site near the northeast corner of Palos Verdes Drive North and Palos Verdes Drive East. The developer proposes to create twelve residential lots and a private street parallel to Palos Verdes Drive North. The project requires a number of discretionary approvals by the City of Rolling Hills Estates, including a General Plan Amendment and Zone Change, a Tentative Tract Map and a Grading application.
The Initial Study identifies a number of potentially significant environmental impacts in the areas of land use and planning, earth resources, water, air quality, transportation and circulation, biological resources, risk of upset, noise, utilities, aesthetics and cultural resources. The subject property is also located adjacent to the site of the proposed new RE/MAX Palos Verdes office building and across the street from Rolling Hills Covenant Church, which is also planning a major expansion (see discussion above). A public scoping meeting for the Butcher subdivision was held on July 31, 2002, but Staff was unable to attend. However, Staff intended to prepare written comments on the NOP and forward them to the City of Rolling Hills Estates prior to the August 23, 2002 public comment deadline.
On August 12, 2002, Staff forwarded NOP comments to the City of Rolling Hills Estates. These comments identified potential issues of concern in the areas of biological resources, transportation/traffic, hazards and land use planning. Staff intends to review the draft EIR once it is available and provide further comments on this project.
SAN PEDRO FACILITY RESTORATION ADVISORY BOARD (DEPARTMENT OF DEFENSE AND CITY OF LOS ANGELES)
On August 19, 2002, the City received public notice for the annual meeting of the San Pedro Facility Restoration Advisory Board (RAB). The meeting was intended to provide an open forum for the discussion of the environmental investigations and clean-up activities at the Defense Fuel Support Point San Pedro Facility and adjacent housing areas on Western Avenue and Palos Verdes Drive North. Staff attended the August 28, 2002 meeting, at which Navy personnel presented updates on a variety of on-going soil remediation programs on the site, including:
There was also a presentation by the Peninsula Land Conservancy regarding its efforts to restore coastal sage scrub habitat and monitor the population of the Palos Verdes blue butterflies on the site.
There was no new information presented at the RAB meeting regarding the status of the transfer of the San Pedro and Palos Verdes housing sites to the various agencies identified by the San Pedro Reuse Committee in 1999. A portion of the housing along Taber Avenue was transferred to the Archdiocese of Los Angeles in 2001 for the possible future expansion of Mary Star of the Sea High School. Also, information regarding the San Pedro Facility RAB is available on-line at:
On September 13, 2002, Staff spoke with Navy personnel regarding the transfer of the housing sites. According to the Minutes of the August 2001 RAB meeting, the transfer of these properties was being held up by the issue of Palos Verdes blue butterfly habitat on and adjacent to the housing sites. Consultations between the Navy and the US Fish and Wildlife Service (USFWS) over the Navy’s proposed habitat plan reached an impasse in early 2002, which was only broken when the Navy agreed that it would retain ownership of a critical habitat area adjacent to the Palos Verdes housing site. Under this scenario, the various proposed recipients of the properties—including Marymount College—would be responsible for dealing individually with USFWS if any critical habitat issues arose on their respective properties as a result of their proposed reuse and/or redevelopment. However, the City of Los Angeles apparently objects to this scenario and has asked the Department of Housing and Urban Development (HUD)—which is the last Federal agency that needs to approve the transfer of the properties—to withhold any action on the San Pedro Reuse Plan until its concerns are addressed. Navy personnel indicated that HUD could unilaterally approve the Reuse Plan over the City of Los Angeles’ objections but has been understandably reluctant to do so. Nevertheless, the Navy believed that the transfer of the housing sites could be finalized by early 2003.
On October 28, 2002, the Daily Breeze reported that the impasse regarding the transfer of the former Navy housing sites had been broken, largely due to the efforts of Congresswoman Jane Harman and Los Angeles City Councilwoman Janice Hahn. The transfer of the property to the City of Los Angeles was expected to be complete by the end of 2002. As a part of the property transfer, the Navy will set aside a 10-acre fenced preserve for the Palos Verdes blue butterfly, to be maintained and monitored by the Land Conservancy. The housing sites will ultimately be transferred to Marymount College, Rolling Hills Preparatory School, South Bay Crossings and the Kenny Nickelson Memorial Foundation for Homeless Veterans, all of whom were identified in the 1999 base reuse plan. However, the Harbor-UCLA Research and Education Institute (REI), which was slated to redevelop approximately 46.5 acres of the Western Avenue housing site, withdrew its plans for the site. With the withdrawal of REI, its portion of the San Pedro housing site will be put up for bid sale by the Navy in early 2003. The former REI portion—which is zoned R-1 and contains approximately 190 dwelling units—is expected to generate interest from the residential development community. Staff intends to continue monitoring the transfer and future redevelopment of these sites.
[Rolling Hills Covenant Church Expansion EIR Comments]
7 November 2002
VIA FACSIMILE AND U.S. MAIL
FAX: (310) 377-4468
Deborah Linn, Project Planner
City of Rolling Hills Estates
4045 Palos Verdes Dr. N.
Rolling Hills Estates, CA 90274
SUBJECTComments in Response to the Draft Environmental Impact Report for the Proposed Expansion of Rolling Hills Covenant Church
Dear Ms. Linn:
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the draft Environmental Impact Report (DEIR) for the above-mentioned project. The following comments fall into three general categories: typographical or factual errors, Notice of Preparation (NOP) comments not addressed in the DEIR, and additional comments and issues of concern.
Typographical and Factual Errors
1.Green Hills Memorial Park is incorrectly identified as "Rolling Hills Memorial Park" in at least two locations in the DEIR (p. 2.0-4 and p. 4.2-22). This error was noted in our NOP comments and should be corrected wherever it occurs in the DEIR.
2.Several corrections are necessary in the cumulative impact analysis (p. 4.0-4 through 4.0-6):
a."Rancho Palos Verdes Estates" should be "Rancho Palos Verdes";
b."Long Pointe" should be "Long Point";
c."Crestridge Villa" should be "Crestridge Villas"; and,
d.The application for the Cal Water/JCC Homes project has been withdrawn by the developer.
These corrections should also be made to Table 4.0-1 (p. 4.0-7), Table 4.5-6 (p. 4.5-22) and Table 4.7-3 (p. 4.7-6). We have also enclosed a copy of Figure 4.0-1 (p. 4.0-5) depicting the correct locations of the Belmont Village, Marymount College and Western Avenue Self-Storage projects.
3.The beginning of the second bullet point at the top of Page 4.1-4 should read:
"The Peninsula Verde and Rolling Hills
NOP Comments Not Addressed in the DEIR
4.In our NOP comments of 6 September 2002, we noted that the Initial Study indicated that air quality monitoring would occur and "be analyzed at those locations…where ‘hot spots’ could occur." The City requested that the list of air quality "hot spots" to be analyzed include the proposed haul route between the subject property and Green Hills Memorial Park. However, we note that the analysis of air quality "hot spots" appears to be limited to the analysis of operational—as opposed to construction—impacts at two heavily-impacted intersections along Palos Verdes Drive North in Rolling Hills Estates. Since many of the air quality impacts related to the proposed movement of 20,000 cubic yards of material and the use of heavy equipment are likely to affect Rancho Palos Verdes and Rolling Hills Estates residents in the immediate vicinity of the proposed haul route and export site, the City of Rancho Palos Verdes respectfully requests that the analysis of air quality "hot spots" be expanded to address this portion of the project.
5.In our NOP comments of 6 September 2002, we also noted that the Initial Study stated that no impacts were expected that would as a result in the "[exposure] of people or structures to potential substantial adverse effects, including location on a geologic unit or a soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse." We pointed out, however, that the California Division of Mines and Geology maps of Seismic Hazard Zones identified areas in the southwesterly portion of Green Hills Memorial Park—the general location for the proposed placement of the 20,000 cubic yards of exported material—as "Zones of Required Investigation" for liquefaction. Although we requested an assessment of the risk of liquefaction and other unstable soil conditions as a part of the DEIR, no such assessment has been provided for this project. Instead, all Earth and Geology Impacts of the project have been described as having no significant effects in the DEIR. Since the export of 20,000 cubic yards of material to this site appears to be part of the preferred alternative identified in the DEIR, the City of Rancho Palos Verdes respectfully reiterates its request for this additional soils assessment.
6.Finally, in our NOP comments of 6 September 2002, we noted that the discussion of Risk of Upset and Human Health impacts in the Initial Study stated that no impacts are expected that would result in "significant hazard to the public or the environment though the routine transport, use or disposal of hazardous materials." The State Department of Toxic Substances Control (DTSC) expressed concerns about the historic use of the property in its comments on the original NOP on 20 February 2002 (Appendix 1.0(B)). The City is also aware that there has been historic dumping of construction waste and other materials in many of the former canyon areas in this area of the Peninsula, including portions of the Green Hills Memorial Park site and the Navy’s Defense Fuel Support Point (DFSP) in San Pedro. Although the City understands that the subject property has been used for institutional purposes since 1957, and that this use would not normally involve the manufacture, use or disposal of hazardous materials, the City requests that the mitigation measures for the DEIR include the requirement for the testing of any soil or other materials exported from the project site for hazardous substances that may have been dumped there prior to the development of the current church facilities.
Additional Comments and Issues of Concern
7.Section 3.3.4 of the DEIR discusses the construction characteristics of the proposed project, including the proposed export of 20,000 cubic yards of material to Green Hills Memorial Park. The last paragraph on Page 3.0-25 states:
"The applicant proposes to coordinate the export activities with grading activities at the Memorial Park to allow the export material to be graded as compacted fill material consistent with the approved Master Grading Plan. If a joint export and grading operation cannot be coordinated for any reason, all or part of the exported earth materials would be temporarily stockpiled at the Memorial Park until grading operations on the Memorial Park property can be conducted."
On Page 3.0-27, this paragraph goes on to describe the estimated size of such a the stockpile as three hundred feet (300’) in length, two hundred feet (200’) in width and about ten feet (10’) in height. This equates to a ten-foot-tall pile of earth covering an area the size of a football field.
It must be clearly understood by all parties that the importation and/or temporary stockpiling of material on the Green Hills Memorial Park site will not be allowed unless and until the City of Rancho Palos Verdes approves revisions to the Master Grading Plan and associated permits for Green Hills Memorial Park. As of the date of these comments, no such revisions have been requested by Green Hills Memorial Park. Therefore, the City of Rancho Palos Verdes respectfully requests that the project description on Page 3.0-25 be revised as follows:
"The applicant proposes to coordinate the export activities
with grading activities at the Memorial Park to allow the export material to
be graded as compacted fill material consistent with the approved Master Grading
Plan. If a joint export and grading operation cannot be coordinated for any
reason, all or part of the exported earth materials would be temporarily stockpiled
8.Section 4.5.3 of the DEIR discusses the noise impacts associated with the proposed export to Green Hills Memorial Park. Noise impacts associated with the placement of this fill are expected to exceed 65 dBA at adjacent residences in the Rolling Hills Riviera neighborhood, and there are no feasible mitigation measures to reduce these impacts to less than significant levels. The City appreciates the inclusion of the "Chandler Quarry Site Export Alternative" as a way to avoid these construction-related noise impacts. Regardless of which development alternative may eventually be approved by the City of Rolling Hills Estates, the City of Rancho Palos Verdes supports any feasible and effective noise mitigation measure that can be identified.
9.Section 7.0 discusses effects not found to be significant as a result of the environmental analyses completed for the Initial Study and DEIR. In the discussion of Water and Hydrology Impacts on Page 7.0-5, it is noted that no significant flooding impacts related to dam or levee failure are expected since the RHCC site is not within the potential inundation area of the Palos Verdes Reservoir. However, it should be noted that areas in the southwesterly portion of Green Hills Memorial Park—the general location for the proposed placement of the 20,000 cubic yards of exported material—are located within the inundation area of the reservoir depicted on the enclosed inundation map. As such, the City of Rancho Palos Verdes respectfully requests the inclusion of an analysis of the potential flood risk posed by the export of material to the Green Hills site.
10.Section 4.3 of the DEIR discusses the traffic impacts of the proposed project. The traffic analysis evaluates weekday peak-hour impacts at six intersections along Palos Verdes Drive North (Rolling Hills Road/Portuguese Bend Road, the Dapplegray Elementary School entrance, Dapplegray Lane, Palos Verdes Drive East, Montecillo Drive and Rolling Vista Drive), and expands the Sunday peak-hour analysis to include two additional intersections with Palos Verdes Drive North (Hawthorne Boulevard and Crenshaw Boulevard). However, none of these analyses include the intersection of Palos Verdes Drive North and Western Avenue (State Route 213). Western Avenue is a major regional thoroughfare that provides access to the Eastview area of the City of Rancho Palos Verdes. Any project impacts at this intersection would be likely to affect a large number of Rancho Palos Verdes residents, most particularly residents in the Peninsula Verde community. Therefore, the City of Rancho Palos Verdes respectfully requests the expansion of the traffic analysis in the DEIR to include the intersection of Palos Verdes Drive North and Western Avenue.
11.Related to Comment 10 above, we note that the traffic impact analysis in the DEIR concludes that adverse impacts at three intersections along Palos Verdes Drive North (Rolling Hills Road/Portuguese Bend Road, the Dapplegray Elementary School entrance and Dapplegray Lane) can be mitigated to less than significant levels though widening and restriping, and that adverse impacts related to the proposed installation of two traffic signals for RHCC can be reduced but not fully mitigated through operational modifications. Aside from these impacts, the traffic impact analysis identifies no other significant adverse impacts resulting from the project at any of the other intersections that were analyzed. However, we are aware of anecdotal reports from residents surrounding the RHCC site of more widespread Sunday peak-hour traffic impacts than the three intersections identified in the DEIR. The third-party review of the traffic study by Coco Traffic Planners, Inc.(Appendix 4.3(B), p. 5) questioned the assumptions used in calculating the future Sunday trip generation for the project. Rather than utilizing the widely-accepted Institute of Transportation Engineers (ITE) trip generation rates, the project’s traffic analysis is based upon direct observation of a single "typical" Sunday morning’s traffic and parking activity nearly three-and-a-half years ago. To validate these assumptions, the third-party reviewer recalculated the anticipated intersection volumes for the three intersections nearest to the RHCC site and concluded that the project’s Sunday peak-hour trip generation assumptions were reasonable. Given the highly sensitive nature of this project and the known peak-hour traffic problems that exist on Palos Verdes Drive North, the City of Rancho Palos Verdes respectfully requests that the third-party reviewer recalculate the anticipated intersection volumes for all eight intersections identified in the original traffic study, plus the intersection of Palos Verdes Drive North and Western Avenue. We also request that the project applicant provide more current traffic and parking data for the existing RHCC site, and that the data be drawn from observations on more than just one "typical" Sunday.
Again, thank you for the opportunity to provide comments on this important project. If you have any questions or need additional information, please feel free to contact me at (310) 544-5228 or via e-mail at email@example.com.
Kit Fox, AICP
cc:Mayor and City Council
Les Evans, City Manager
Joel Rojas, Director of Planning, Building and Code Enforcement