August 12,  2003

 

Sheila Donovan

(Code 05GPE.D.SD)

Commander, Southwest Division

Naval Facilities Engineering Command

1220 Pacific Highway

San Diego, CA  92132-5190

 

SUBJECT: Notice of Availability of a Draft Environmental Impact Statement for Military Family Housing in the San Diego Region

 

Dear Ms. Donovan:

 

The City of Santee received a copy of the Draft Environmental Impact Statement (DEIS) for the above referenced project on July 24, 2003, at a public meeting.  The City finds that the DEIS is inadequate pursuant to 40 CFR 1502 which mandates full and fair discussion of significant environmental impacts and avoidance/minimization of adverse effects, specifically in the areas of traffic, visual resources, public services, and biological resources, as described herein.

 

The DEIS has been prepared for a joint United States Marine Corps and Department of the Navy proposal to construct military family housing in San Diego County within the boundaries of MCAS Miramar.  As stated in the DEIS, the Commander Navy Region Southwest provides centralized housing program management for ten military installations ranging in locations from Imperial Beach to Miramar.  As such, it is not assumed that the proposed project will exclusively provide housing for Marine Corps Air Station personnel, but rather, will provide housing for military personnel and their families Countywide.

 

Three alternative sites were analyzed in the DEIS in addition to the “No Action” alternative.  Site 8 is closest to Santee and would be accessed off State Route 52.  Site 2 is located in the northwest corner of East Miramar, with proposed access via Pomerado Road.  Site 3 is located approximately 2 miles east of Interstate I-15, at the Miramar Way interchange, with proposed access via a constructed extension of Miramar Way.  The DEIS identifies Site 8 as the preferred alternative.

 

Donovan

August 12, 2003

DEIS – Military Housing

Page 2 of 5

 

 

Site 8 is located just north of SR 52, at Santo Road, and extends north and east to encompass a 264-acre site.  The project proposes up to 1,600 units, two reserved elementary school sites and a community center/park. 

 

Two potential access routes have been identified in the DEIS, one being off Santo Road via a new two mile extension of Santo Road generally eastward to the development site (Site 8A), and the other is a new SR 52 interchange less than a mile further east and the construction of a shorter 400 foot long road to the development site (Site 8B).  Site 8, regardless of access options, will have the greatest effects on the City of Santee.  Concerns with Site 8 are as follows:

 

Traffic

The project will increase traffic on SR52 with the addition of up to 1,600 units, two elementary schools and community center/park.  There is no analysis of State Route 52 operations in the DEIS.  Only side street and ramp intersections are analyzed.  The DEIS assumes in all scenarios that 100 percent of the traffic would be westbound, and that no traffic would be eastbound from Santo Road, or from the new interchange on State Route 52. The volumes at peak hours on State Route 52 do not appear to have been considered in the traffic analysis. Moreover, Alternative 8B does not meet FHWA one-mile interchange spacing requirements and should be considered infeasible.

There are significant employment, shopping and recreational opportunities in Santee and the rest of East County that would invalidate westbound traffic assumptions in the DEIS.  Additionally, the DEIS relies on a trip generation of six trips per dwelling unit which would be reflective of actual conditions only if none of the spouses or children of the military personnel work, none of the families have children of driving age, trips for shopping are very limited and all children will walk or ride the bus to school.

The 1996 BRW traffic study that established trip generation rates for SANDAG’s “Guide to Vehicular Traffic Generation Rates for the San Diego Region”, analyzed three small attached military housing complexes to derive a rate of 6 trips per unit for off-base military housing.  These military housing projects are not representative of the large scale project currently contemplated that include schools and community facilities. 

Additionally, the traffic analysis is not in compliance with SANDAG’s Congestion Management Program (CMP).  The CMP was adopted by SANDAG on November 22, 1991.  It is intended to directly link land use, transportation and air quality through Level of Service (LOS) performance.  The document needs to include this analysis to be in compliance. 

Donovan

August 12, 2003

DEIS – Military Housing

Page 3 of 5

 

The DEIS should note that State Route 52 terminates in Santee and connects to State Route 125.  The southbound connection of State Route 125 has been ignored in the study and must be included in the traffic analysis.  SR 125 offers an alternative route to the 15, the 805 and the 5 for personnel headed for installations south of SR 52.

 

The analysis of the Mast Boulevard /State Route 52 ramps should be included in this report.  Furthermore, SR 52 will be constructed to SR 67, projected to be completed by 2008.  SR 67 would similarly offer an alternative route for personnel headed for installations north of SR 52. 

 

The near term analysis without the project ignores the SR52 am peak hour congestion.

 

The 2020 analysis without the project ignores the SR52 am peak hour congestion.

 

Visual Resources

 

The project will be visible from State Route 52 and the Mission Trails Regional Park.  State Route 52 defines the current north limit of the Mission Trails Regional Park, generally between Santo Road and Mast Boulevard, and the view corridor is characterized by natural vegetated hillside slopes and rock outcroppings.  The proposed development could adversely affect the potential designation of State Route 52 as a State Scenic Highway in that location.  Furthermore, the Mission Trails Regional Park is a significant recreational and habitat resource for the region, encompassing over 5,800 acres, essentially separated from the project site only by SR 52 to the south.  The DEIS must analyze all potential impacts on the Mission Trails Regional Park.

 

Photo simulations are required to fully analyze the potential visual affects of the proposed development from strategic viewpoints.  Key locations should be selected within the Mission Trails Regional Park, along State Route 52, and other publicly accessible points, followed by discussion of how visual effects will be reduced to a level of insignificance.

 

Education Facilities

 

The DEIS calculates that 1,600 housing units will add 1,172 K-5 students, 228 middle school students and 163 high school students.  Based on this, two elementary school sites have been provided within the development site. 

Donovan

August 12, 2003

DEIS – Military Housing

Page 4 of 5

 

 

It is unclear whether the schools will be constructed concurrently with the

construction of housing, and who would be responsible for their construction.  Would there be an interim location for these K-5 children?  The DEIS concludes that middle and high school children would be accommodated at San Diego schools, but only if capacity is increased.  Federal Impact Aid funds are identified as a potential funding source for construction of expanded facilities, which could be viewed as “deferred” and uncertain mitigation not supported by state environmental law. 

 

Notwithstanding this, with a limited San Diego Unified School District budget, it is possible that these children would attend schools in Santee.  For instance, West Hills High School is within 5 miles of the project site.  The effects on schools should be analyzed more fully in the DEIS, and expanded to include the City of Santee.

 

Fire Protection Services

 

The DEIS acknowledges that the development would result in an increased demand for fire protection services, but that this would be insignificant because “fire services could be provided by existing and planned fire stations.” 

 

The DEIS notes that the Federal Fire Department on MCAS Miramar, as well as the “Elliot temporary station” would provide services, “with emergency backup from local jurisdictions”.  The City of Santee is party to an aid agreement with the City of San Diego that addresses “automatic” and “mutual” aid situations.  As such, the City of Santee Fire Department would be affected by the development, and the potential impacts on the Santee Fire Department must be more fully analyzed in the DEIS. 

 

Solid Waste

 

The project would generate approximately 1,920 tons of solid waste per year, and the DEIS identifies the Miramar Landfill as being the recipient of this waste at no cost to the Department of the Navy per lease agreement with the City of San Diego.  As such, the Sycamore Landfill will not be affected by the project.  However, the time of the lease agreement and “any extension hereof”, is of interest to the City of Santee, and should be included in the DEIS. 

 

Donovan

August 12, 2003

DEIS – Military Housing

Page 5 of 5

 

Biology Resources

 

The project is subject to compliance with the Integrated Natural Resource Management Plan, MCAS, 2000, and environmental mitigation. The DEIS characterizes the site predominantly as a “Level IV” site which represents areas that “do not support substantial high value, regulated resources, though isolated high value resources may be present.”  Nevertheless, habitat compensation would be required under the INRMP, to include timing of construction to avoid bird breeding seasons, minimization of urban edge effects, transplantation of species of regional special concern and preservation of habitat linkages and corridors. 

 

With the proposed construction of 498 dwelling units in East Elliot (Pardee), and the proposed expansion of the Sycamore (Allied Waste), the City of Santee is concerned that the viability of habitat for the protection and sustainability of species identified in the Multiple Species Conservation Plan (MSCP) will be reduced.  The DEIS should include an analysis of the potential effects of the project, in concert with these future projects, on the ability to establish or preserve viable corridors/linkages consistent with the MSCP.  Additionally, as previously noted under “Visual Resources”, all potential impacts to the Mission Trails Regional Park should be disclosed and fully analyzed, to include “edge effects” on surrounding habitat.  This is important to the City of Santee, as an adjoining jurisdiction that is also a part of the Multiple Species Conservation Plan.

 

Please be advised that the City of Santee did not receive the Notice of Availability, nor the DEIS.  Instead these materials were delivered to the Santee library.  Please forward any future correspondence to the attention of Melanie Kush, City Planner at the City Hall address. 

 

Thank you for the opportunity to comment on the DEIS.  The City looks forward to your responses.  I may be reached at (619) 258-4100, extension 167 with any questions concerning these issues. 

 

Respectfully,

 

 

Douglas Williford, AICP

Director of Development Services

 

c.         Keith Till, City Manager

            Honorable Mayor and City Council