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TO: HONORABLE MAYOR AND COUNCILMEMBERS
FROM: DIRECTOR OF PLANNING, BUILDING & CODE ENFORCEMENT
DATE: DECEMBER 16, 2003
SUBJECT: REVIEW OF DRAFT COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED SOUTH COAST COUNTY GOLF COURSE AT THE FORMER PALOS VERDES LANDFILL
Staff Coordinator: Kit Fox, AICP, Senior Planner
Review Staff’s draft comments on the Draft Environmental Impact Report (DEIR) for the proposed South Coast County Golf Course, and provide feedback to Staff to finalize these comments prior to their submittal to the County.
BACKGROUND AND DISCUSSION
On November 18, 2003, the City Council decided to hire The Source Group, Inc. (TSG) to review and comment upon technical portions of the DEIR. TSG has completed its review, and Staff now presents the attached draft comments for the Council’s consideration. Also attached are TSG’s original comments.
At the December 2, 2003 meeting, it was the Council’s unanimous motion that Mayor Gardiner and Councilman Stern contact Supervisor Knabe again regarding the City’s request for an extension of the comment period for the DEIR. In previous conversation with Councilman Stern, Supervisor Knabe verbally agreed to extend the comment period to at least January 30, 2004 and possibly further. Although there had been no official confirmation of such an extension as of the last City Council meeting, on December 4, 2003 the City was advised that the comment period would be extended to March 4, 2004.
Based upon the foregoing discussion, Staff seeks direction from the City Council regarding its draft comments. Staff intends to finalize these comments and submit them to the County prior to the end of the public comment period for the DEIR on March 4, 2004.
On November 18, 2003, the City Council authorized the expenditure of up to $5,000 for technical review of the DEIR by TSG. As of the date of preparation of this report, the City had not yet received an invoice for TSG’s services. However, if the Council desires TSG to conduct further analysis, these costs may exceed $5,000, thereby requiring a further budget appropriation.
The alternatives available for the City Council’s consideration include:
2. Direct Staff to modify its comments and forward them to the County.
Since the deadline to submit comments on the DEIR has been formally extended to March 4, 2004, the City Council may wish to review any revisions at a future meeting.
Joel Rojas, AICP, Director of Planning, Building and Code Enforcement
Les Evans, City Manager
Draft comments on the DEIR
Technical review comments by TSG
[Draft Comments on the DEIR]
16 December 2003
VIA FACSIMILE AND U.S. MAIL
FAX: (213) 487-0380
Larry Hensley, Chief of Planning
County of Los Angeles
Department of Parks and Recreation
433 S. Vermont Ave.
Los Angeles, CA 90020
SUBJECT Comments in Response to the Notice of Availability of a Draft Environmental Impact Report for the Proposed South Coast County Golf Course
Dear Mr. Hensley:
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the Draft Environmental Impact Report (DEIR) for the above-mentioned project. The City respectfully offers the following comments on the DEIR for the proposed golf course:
Although the project description now includes Rancho Vista, we note that the discussion of air quality in the DEIR still does not identify Rancho Vista as a sensitive receptor (p. 3B-7). As such, we question whether the air quality analysis accurately depicts the environmental impacts to the Rancho Vista campus.
With respect to the discussion of hazards and hazardous materials in the DEIR, we note that the document discusses risk assessment for off-site residents, on-site workers and recreational visitors under the current site conditions and future project conditions (pp. 3F-20 – 3F-22). We are not convinced, however, that this analysis accurately reflects the risk to children, staff and visitors on the Rancho Vista campus—who are most likely to be present during construction periods for the project—under the current and future conditions. The impact analysis in the DEIR (p. 3F-41) states that "potential impacts to the Rancho Vista Elementary School and the Rolling Hills Country Day School are not anticipated to be significant," even without any mitigation. The City believes that the available evidence does not support this assertion, and that a detailed risk assessment for these school sites should be included in the analysis of hazards and hazardous materials in the DEIR.
3) In our NOP comments of 5 April 2002, we requested the inclusion of a project alternative where a new equestrian center is not provided. Although we understand that the County asserts that the provision of a site for a relocated equestrian center must be provided, the City of Rolling Hills Estates has made it clear that it is not in a financial position to construct a new equestrian center and does not support its relocation. As such, even if the golf course project was eventually approved, it seems likely that a new equestrian center might be significantly delayed or never built. Therefore, the City respectfully reiterates its request for the inclusion and analysis of such an alternative in the DEIR. In the absence of such an alternative, the City suggests that the issuance of permits by the County to begin the construction of the golf course project should be contingent upon the provision of the necessary resources—financial and otherwise—to ensure the construction of the relocated equestrian center.
The City of Rancho Palos Verdes wishes to stress that it appreciates the unique character and ambiance that the many equestrian neighborhoods contribute to the City and the Peninsula as a whole, and we do not support the elimination of an equestrian center from the proposed project. However, in the event that a new equestrian center is significantly delayed on not built, the horses currently kept at the equestrian center would need to be kept somewhere else—most likely, somewhere else on the Peninsula. The City of Rancho Palos Verdes has limited opportunities for commercial boarding, and the operation of commercial boarding facilities in residential neighborhoods has been a recurrent concern of the Rancho Palos Verdes City Council and many City residents. As such, the City requests that the DEIR analysis of the impact on surrounding communities of the elimination of the existing equestrian center, either temporarily or permanently. Particular attention should be given to the land use impacts of commercial stables in residential areas, as well as to the impacts to drainage and water quality as a result the stringent new NPDES standards for animal-keeping facilities.
We also note that the discussion of transportation/traffic in the DEIR includes an analysis of existing and future distribution for equestrian center trips, assuming the relocation of the equestrian center to the northwesterly portion of the project site. However, this analysis does not appear to cover traffic impacts related to diversion of equestrian center trips during construction and/or in the event that a new equestrian center is not built.
4) In our NOP comments of 5 April 2002, we suggested the inclusion of several mitigation measures to reduce fugitive dust levels to less-than-significant levels. We note that some of these have been included in the DEIR, but we respectfully suggest the inclusion of additional mitigation measures Chapter 3B (Air Quality), such as:
6) The City of Rancho Palos Verdes is concerned about the transfer of ownership of—along with the associated liability and risk for—portions of the project site from the County Sanitation Districts to the County Parks and Recreation Department and, ultimately, the project proponent. The DEIR should include full discussion and disclosure of the project proponent’s ability to fulfill all the of recommended mitigation measures in the DEIR, and assume full liability in the event of any future adverse environmental effects (whether sudden or gradual) upon residents of the Palos Verdes Peninsula.
7) The City’s environmental consultant offers the following comments and observations on the DEIR for this project:
a) The discussion of Impact 3G1 (pp. 3G-11 to 3G-13) identifies the potential for failure of the improved cap and the identification and rectification of the failure. It is not clear how the failure of the buried geotextile will be detected. Subsidence of the landfill is expected and this subsidence may lead to failure, but the mitigation is the stockpiling of soil to fill in the subsidence area so that water does not pool. If a breach in the improved cap occurs, the first indication may be the increase in contaminants in the leachate collection system. Although no risk to groundwater or sensitive receptors would occur, it does represent a significant impact to the current containment and treatment system.
Some mention of moisture sensing devices is made for the purposes of irrigation control. It is assumed that moisture-sensing devices installed below the improved cap for the monitoring of the cap integrity would not be feasible due to the large number of moisture sensing devices and the probable installation through the cap compromising the cap’s impermeability.
b) The discussion of Impact 3G3 (pp. 3G-14 to 3G-15) notes the potential for the graded hillsides to fail as a project impact. The mitigation discusses monitoring and rectification of any failures. This may be too late for residences on the north side of the landfill, particularly in light of the fact that some failures have occurred. Technically, the failure of the grading is the baseline and no further impact of the project could be assumed. But future failure of graded hillsides may be attributed to the golf course anyway, particularly if the mitigation’s are expected to prevent further hillside wasting.
c) In the discussion of the Project Description and Site Characteristics (Section 2.1.1 on p. 2-4 and Section 2.3.4 on p. 2-33), the DEIR text indicates that a computer will control irrigation based on weather conditions and real-time sensor data from devices such as soil moisture and pipeline pressure probes. Has a monitoring and inspection program been developed to inspect and/or confirm that the real-time sensors are functioning properly? Or, will sensors be replaced or re-built at a regularly scheduled time interval?
i) Several exposure scenarios were evaluated as part of the site’s remedial investigation and feasibility study (RI/FS). However, there would appear to be some exposure scenarios that should be evaluated as result of redeveloping the property as a public golf course. For example, no construction worker scenario was evaluated as part of the risk assessment. Specifically, a construction worker at the site during construction of the golf course may need to be considered. The cover of the landfill may (or will) be disturbed during grading of the golf course and membrane installation under fairways of the golf course. Further, the DEIR text indicates that the landfill gas recovery system will be off at times during golf course construction. The exposure scenarios completed, as part of the RI/FS may not adequately address potential exposures to a construction worker.
Another worker scenario that does not appear to be addressed in the risk assessment is that of a groundskeeper employee exposure scenario. While the RI/FS risk assessment did include a current and future worker exposure scenario, it is in the context of a landfill operations employee, not a full-time golf course or groundskeeper staff person.
ii) Testing for 1,4-dioxane was requested in November 2001, and analyzed for in the third quarter of 2002. However, other emergent chemicals have been included in recent requests for additional chemical testing. These additional compounds have included perchlorate, N-nitrosodimethylamine (NDMA), 1,2,3-trichloropropane, total/hexavalent chromium, and polybrominated diphenyl ether. Has sampling and analysis been performed for these compounds at the site, or has it been requested?
iii) The EIR addresses fertilizer/pesticide chemical release/migration to groundwater. However, it does not appear to directly address the potential for interaction with landfill waste and leachate. Is it possible that the infiltration of fertilizer/pesticides into the landfill waste cells and leachate could change the composition of chemicals in leachate and landfill gas by altering the microbial activity in the landfill? The waste decomposition process may be altered by the introduction of additional nitrate, for example.
v) In the response to the discussion of Impact 3F4this impact, the DEIR text mentions that the existing gas collection system consists of approximately 361 vertical gas collection wells and 1,308 feet of horizontal gas trenches. How will the wellhead integrity of the 361 vertical gas collection wells be protected during golf course construction? What safeguards will be used to protect the horizontal gas trenches that are expected to remain in operation after golf course construction? The cited mitigation measures M-3F.13 through M-3F.18 do not address protection of existing gas collection system features.
Further, the language of the discussion of this impact may support the need to complete a supplemental risk assessment to address health risks associated with a construction worker scenario.
Again, thank you for the opportunity to provide comments on this important project. The City also appreciates the additional time granted to review and comment upon the DEIR. If you have any questions or need additional information, please feel free to contact me at (310) 544-5228 or via e-mail at firstname.lastname@example.org.
Kit Fox, AICP
cc: Mayor and City Council
Les Evans, City Manager
Joel Rojas, Director of Planning, Building and Code Enforcement
Douglas Prichard, City Manager, City of Rolling Hills Estates