Loading...
HomeMy WebLinkAboutAGENDA REPORT 1992 1118 CC REG ITEM 11BDA u' MOORPARK ITEM I Is 8• 799 Moorpark Avenue Moorpark, California 93021 COSP ;n3 of / 199 FACTION. M E M O R A N D U M �y TO: The Honorable City Council FROM: Jaime R. Aguilera, Director of Community Development Prepared by Deborah S. Traffenstedt, Senior Planner DATE: November 13, 1992 (CC Meeting of 11- 18 -92) SUBJECT: REVIEW OF DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR BLUE STAR MINE, COUNTY OF VENTURA CUP 4633 Background In 1986, an application for a new Conditional Use Permit (CUP) was submitted to the County of Ventura by Blue Star Ready Mix, Inc., and the prior CUP for the Blue Star aggregate mine (CUP -1328) expired. Since that time, there has been prolonged environmental review and coordination between the applicant and the County. The current operations at the site are being conducted under authorization by the County while the CUP application is being reviewed. Because the previous CUP has expired, the proposed project is considered a new project and, as such, has received a new permit number, CUP -4633. The proposed project is a CUP request for a 50 -year, three -phase surface mining, sand and gravel operation that would encompass a total area of 533 acres (refer to Attachment 1). The combined new and old mining areas would encompass about 291 acres. The project site contains an existing quarry, ready mix plant plant, offices, and related mining Processing g quipment. The applicant is proposing to continue mining and expand the operation in a north - northwest direction. An asphalt batch plant is also proposed. The applicant has requested approval to conduct mining in three phases. Phase 1 encompasses approximately 65 acres and would be completed within 10 years (1993- 2003). Phase 2 would include about 50 acres and would also be completed within 10 years (2003- 2013). Phase 3 would occur over a 30 -year period and would include about 102 acres (2013- 2043). (It is important to note that the applicant has been grading within the Phase 1 area since expiration of CUP 1328 in 1986; therefore, the actual time period for excavation within Phase 1 is a total of approximately 16 years.) dst- I1- 13- 92/ 10: 32amC:\WP51 \OA- SNVIR\CUP4633.CC UL W. LAWRASON JR, JOHN E. WOZNIAK SCOTT MONTGOMERY BERNARDO M. PEREZ ROY E. TALLEY JR, Mayor Mayor Pro Tern Councilmember Councilmember Councilmember The Honorable City Council November 13, 1992 Page 2 The new CUP application also includes a request by the applicant for a maximum annual mine production rate of 3,4000,000 tons. The proposed maximum annual mine production rate ( "production" represents the processed, marketable material) is substantially greater than the recent annual production rates of the mining under CUP -1328. For example, the annual mine production rates in the last several years are shown below: 1991 838,000 cubic yards or 1,425,000 tons 1990 824,000 cubic yards or 1,400,800 tons 1989 11075,000 cubic yards or 1,827,800 tons 1988 946,000 cubic yards or 1,608,200 tons The City of Moorpark previously provided written comments to the County of Ventura on a prior Draft EIR for the same Blue Star aggregate mine project in a letter dated July 26, 1991 (attached). The County of Ventura determined that previous Draft EIR to be inadequate, and required a revised Draft EIR to be prepared. The current Draft EIR has been circulated for public review, and written comments have been requested by December 2, 1992. The following discussion summarizes impacts and mitigation measures identified in the revised Draft EIR and includes the Community Development Department's preliminary comments on the Draft EIR. The City Engineer's Office is reviewing the traffic section of the Draft EIR, and their comments will be provided to the City Council at the November 18th meeting. Discussion Impacts It is staff's opinion that the revised Draft EIR for the Blue Star Mine project adequately addresses the impacts of the proposed project that are of concern to the City of Moorpark. The impacts of primary concern to the City are noise impacts to residents along Walnut Canyon Road, Moorpark Avenue, and Los Angeles Avenue; visual impacts to Moorpark residents from cut slopes that would result from grading proposed in Phases 2 and 3; air quality impacts due to mining equipment and activities, processing equipment, and haul trucks; odor impacts to Moorpark residents from asphalt haul trucks traveling on City streets; a traffic impact at the Los Angeles Avenue /Spring Road intersection; and adverse traffic and nuisance impacts from increased truck traffic on City streets. dst- 11- 13-92110.32aW:\WP51\0A- ENVIR\CUP4633.CC The Honorable City Council November 13, 1992 Page 3 Mitigation Measures Noise, visual, and air quality impacts are identified as Class I impacts that are not fully mitigated, requiring the adoption of a Statement of Overriding Considerations. Traffic is identified as Class II impact which can be mitigated. Following is a summary of some of the mitigation measures proposed in the Draft EIR: Reclamation Plan - The topography shall be properly restored to accommodate planned utilization of the land after mining operations. The reclamation plan must meet all applicable Surface Mining and Reclamation Act (SMARA) requirements, including but not limited to revegetation plans, topsoil management, erosion control, drainage, and any proposed or adopted statewide standards for reclamation. Mining may only occur within one phase at a time. Prior to mining in the Phase 2 and 3 areas, the Reclamation Plan for the previous phase must be approved by the County. Reclamation shall be implemented on an on -going basis, not just after the completion of each of the three mining phases. No more than 60 acres shall be actively worked at any time during the life of the permit. No more than 220 acres of the entire CUP permit areas shall be left unreclaimed at any time. Areas that have been mined to final grade shall be reclaimed within one year. All open -bed trucks leaving the site with products must either be covered with a tarp, or the product must be watered in order to avoid the generation of dust from the bed of the truck. All trucks operated by the mine, and all contract trucks that visit the mine, must be free of excessive soil, particularly around the wheels and axles. If necessary, the wheels and tires of trucks leaving the site should be sprayed and washed of loose dirt. The Reclamation Plan shall be submitted prior to each mining phase and shall emphasize the following elements in order to minimize residual visual impacts: (a) Use gradual and smoothed slopes to create gentle landscape features. Reclaimed slopes shall be graded to create a smooth transition with the adjacent, undisturbed slopes. dst- 11- 13- 921I0:31aW AWP51 \0A- BNVIR \CUP9633.CC The Honorable City Council November 13, 1992 Page 4 (b) Revegetate with native plants that will provide the maximum biomass and areal coverage in order to minimize visual scars from bare soils. (c) The existing two vertical cut slopes above the processing area, created during earlier mining, shall be removed as part of the mining plan to reduce visual impacts and create a gradual slope that can be revegetated. Prior to issuance of the zoning clearance for the Phase 1 mining, the applicant shall submit an Air Emissions Mitigation Plan to the Planning Division for approval which shall contain ozone precursor, PM -10, and asphalt plant mitigation measures as described in the Draft EIR. The applicant shall prohibit all Blue Star and contractor trucks from using "jake brakes" along Happy Camp Road and Walnut Canyon Road or within the City of Moorpark, unless there is an emergency. If the County receives a complaint about the use of "fake brakes- by Blue Star Mine associated trucks, the Planning Division may require the permittee to fund an independent monitoring effort to detect the violators. Noise impacts along access roads could be reduced or eliminated by the establishment of an alternative access route. To offset the project's significant impact at the Los Angeles Avenue /Spring Road intersection, the project should contribute its fair -share to the Area of Contribution (AOC) program for the funding of the intersection improvements required at this location. The project traffic at this location comprises 1.4% of the total cumulative traffic during the P.M. peak hour and should only be responsible for its fair -share of the improvement costs at this location. The applicant shall establish and maintain at his expense, a dedicated phone line with 24 -hour answering service to collect any complaints about speeding or unsafe truck traffic along Happy Camp and Walnut Canyon Roads. All public complaints shall be logged and submitted to the applicant and County on a weekly basis. The applicant must respond in writing to the County Public Works Agency within 3 days to each complaint, indicating corrective actions. If the County is not satisfied with the corrective actions and /or there is repeated complaints of a similar nature, the County shall investigate the issue and then meet with the applicant to resolve the dst- 11- 13- 91/ 10: 31amC: \WP51 \0A- RNVIR \CUP4633.CC The Honorable City Council November 13, 1992 Page 5 issue. If there is a serious public nuisance or safety issue and a satisfactory response is not forthcoming from the applicant, the County shall have the option of revoking or modifying the permit to address the traffic issue at hand. This program shall remain in place indefinitely, at the County's discretion. In recognition of the adverse traffic and nuisance impacts increased truck traffic on the streets of the City of Moorpark due to the project, and the need for various improvements to mitigate future traffic on these streets as described in the City of Moorpark's Circulation Element, the applicant shall agree to, and participate in, any assessment district or other financing technique, including the payment of traffic mitigation fees, which the County of Ventura may adopt to fund or partially fund the proposed SR -23 bypass extension. If such a district or other mechanism is created, the applicant shall be required pay only its pro -rata share of any assessment or other charges. The Draft EIR does include a detailed mitigation monitoring plan which identifies for each mitigation measure: implementation responsibility, monitoring frequency, monitoring work program /monitoring agencies, and standard of success. Annual site visits and an annual status report are required. Project Alternatives Since not all impacts of the proposed project can be fully mitigated, several project alternatives are proposed which would eliminate significant adverse impacts or reduce them to a level of insignificance. Alternatives studied are as follows: 1) No Project; 2) Alternative Site; 3) Reduced Mining Area and /or Height; 4) Shorter Permit Period; 5) Alternative Access Routes; 5) Operational Changes; and 7) Environmentally Superior Alternative. Alternative No. 7, the Environmentally Superior Alternative, is a combination of several of the other alternatives studied and would consist of the following elements: Issuance of a permit for Phase 1 with a provision for a major modification to continue for another ten years for Phase 2, and another 30 years for Phase 3. The major modification would undergo a public environmental review to ensure that any unmitigated impacts of previous operations could be addressed in the subsequent phase. dat- I1- 13- 91/ 10. 31amC: \WPSI \QA- EYVIR \CUP4633.CC The Honorable City Council November 13, 1992 Page 6 Daily average truck trips are restricted to April 1992 levels - 638 daily vehicle (trucks and cars) trips, about one half less than the average vehicle trips associated with the proposed project (1,253 one -way trips). Hours for truck deliveries and returns are restricted to 6:30 a.m. to 6:30 p.m., compared to the proposed 6:00 a.m. to 8:00 p.m. hours. The restricted hours would reduce the noise impact to residents early in the morning and after 5:00 p.m. when workers are at home. At the middle of Phase 1 (i.e., within 5 years), the applicant shall provide the County with a feasibility study on alternate access routes to the mine, including property acquisition costs, conceptual grading and geometrics, and environmental constraints for the above alternative routes. Total average daily vehicle trips (see above) shall not increase above the existing levels along Happy Camp and Walnut Canyon Roads until one of the new access roads has been built (refer to Attachment 3 for alternative access routes). Increases above the existing levels of vehicle trips are allowed if these vehicles use Grimes Canyon Road to SR -118 and avoid Moorpark city streets. Staff's Preliminary Comments Staff's opinion is that the City Council should recommend to the County the selection of the Environmentally Superior Alternative for the following reasons: The applicant has a past history of alleged non - compliance with conditions of approval and project expansion without appropriate permit approval; therefore, restricted approval is warranted. Approving Phase 1 only at this time, and requiring a major modification approval for Phases 2 and 3, will allow the City and the public additional opportunities to comment on the project, impacts, compliance with conditions of approval, and access issues and will allow for reconsideration of traffic issues. A 50 -year CUP is beyond the time period covered by both the County and City General Plans. ds[- 11- 13- 92110: 32amC: \WP51 \QA- ENVIR \CUP4633.CC The Honorable City Council November 13, 1992 Page 7 Planned excavation in phases 2 and 3 could result in significant visual impacts to future residents and open space /recreation area users in areas shown as Specific Plan Nos. 2 and 8 on the City's land use plan. Requiring a major modification approval for Phases 2 and 3 would allow an additional opportunity to address significant visual impacts. Until an alternative access route is available that does not require Blue Star vehicles to travel on City roadways, total vehicle trips should not be permitted to increase beyond a maximum of 638 daily vehicle (truck and car) trips. Staff also intends to include the following suggestions in the comment letter: The Environmentally Superior Alternative should include an additional restriction that the maximum daily vehicle trips would be 638 until an alternative access route is available that does not require Blue Star vehicles to travel on City roadways. In addition, all of the project mitigation measures, identified in the Draft EIR, should be imposed in addition to the Environmentally Superior Alternative restrictions (with the exception of mitigation measures that are redundant to provisions of that alternative). The County should not approve the new processing facilities that are proposed including concrete batch plant, portable combined road base plant and recycling plant, asphalt concrete plant. These plants will require material to be imported, including concrete, asphalt, and oils. The proposed processing facilities represent a substantial expansion of the original permitted use - i.e., sand and gravel mining. Based on the adverse impacts of the overall project, approval of the various processing facilities is not justified. Geologic mitigation measure No. 1, Reclamation Plan, should be modified to reduce the CUP permit area that may be left unreclaimed at any time from 220 acres to approximately 150 acres. The 220 acres is based on the existing situation, which the City believes to be excessive. Traffic mitigation measure No. 4 (traffic complaint line) should be modified to also require a copy of the complaint log to be submitted to the City. dat- II- 13- 92110 :31amC: \WP5I \QA- E"IR \CUP4633.CC The Honorable City Council November 13, 1992 Page 8 The following corrections should also be made to the EIR prior to certification: Figure 13 - High Street between Moorpark Avenue and Spring Road should not be shown as an access route. Spring Road between Los Angeles Avenue and High Street is an access route until the SR -23 /SR -118 connector is completed. Section 4.5.2, page 4 -10 (Description of Moorpark Land Use Plan) - Paragraph 3 - Revise first sentence as follows: The new land use plan designates wee _fie Specific Plan areas within and outside the City to --- gude land development, consistent with the Land Use Plan Goals and Policies, and the buildout population of 40,856. Paragraph 4 - Revise first sentence as follows: The overall impact of the new land use plan outside of the City boundaries is the conversion of undeveloped land to urban uses paE l eu °r-' -� r__________j.nc2dng agricultural lands. Revise the last sentence of this paragraph as follows: The draft fl EIR on the Land Use Element update only identifies ene that the following impactt that cannot be mitigated to a level of non - significance: 16^" of native Paragraph 5, revise first sentence as follows: Build -out of the prepesed Cr Land Use Plan will result in the increase of 'average daily trips from 166,300 to 452�g Appx4x�mately �345�5i10 by the year 2010, according to the di4f f na!: Ik,TR. dst- 11- 13- 92/ 10. 32amC. \WP51 \0A- HMJIR \CUP4633.Cc The Honorable City Council November 13, 1992 Page 9 Section 5.8.1, Noise - Existing Conditions, Paragraph 4 - Revise as follows: Residences along Walnut Canyon Road, as well as city streets within Moorpark (such as High Street orpark A anuej" as< �,n"I s ; .venue and Spring CSC Read) .. w r` e Haul trucks: woulii pass Section 5.9, Traffic - Change Spring Street throughout this section to Spring Road. Section 5.9.2.9, Evaluation of Moorpark's Circulation Element Improvements - Revise as follows: Extension of S.R. 118 to the west through the City of Moorpark, north of High h Street, connecting to existing -_._. _...__ S.R. 118 west #abe Rvd and cont3:na.ng outside of theCity limits :..............:... ............................... .- :r....... , - Recommendation Direct staff to prepare a letter to the County which addresses any City Council comments as well as the staff comments, as contained in this report. Attachments: 1. Project Site Map 2. Prior City comment letter to County dated 7 -26 -91 3. Alternative Access Routes Exhibit JRA /DST dst- 11- 13- 92110: 32amC : \WP51 \QA- E[JVIR \CUP4633.CC j i i i ■ ■ ■ -� -� - - _ - -. -- , . _ _ ,.. _ /- .. . �,.. - .1_z --gar ^.. - � 7`� 1�. �. ✓` �- : 7 -a - /\ - - _ _ •"f�. _ , _�..���`' _ .. � _ J, `v-� _ _ .' /. ✓' -mow:' • -}I /�`��.1 . /�. _�•. Proposed CUP 4633 Boundary _— ----Limits of Proposed,-- Mining Area Existing - --Quality Rock Mine CUP 4158 Area Mined. under CUP 1328 l LO 39 6 co m m� a\ O• . Ol p 1/2 1 Scale in Miles O J Base map: USGS 7.5' Topographic Ouadrang!es: Simi, CA 1969, Moorpark, CA 1969, FIGURE 2 PROJECT SITE Dames & Moors July 26, 1991 MOORPARK 799 Moorpark Avenue Moorpark, California 93021 (805) 529 -6864 Keith Turner Planning Division County of Ventura 800 South Victoria Avenue Ventura, CA 93009 Attention Janna Minsk SUBJECT: COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR THE BLUE STAR QUARRY, CUP 4633 Dear Keith: Thank you for the opportunity to review the -Draft EIR for the Blue Star Quarry expansion project. We are concerned that this EIR understates the significance of traffic, noise, light and glare, and visual impacts, and that proposed mitigation measures throughout the document are vague and will be difficult to effectively enforce as currently written. We recommend the use of a mitigation format which addresses the effectiveness of mitigation measures in reducing the magnitude of impact, identifies the party responsible for implementation and the method by which implementation can be assured, and clarifies whether a mitigation measure is acceptable to the responsible party or should be required as a condition of project approval. As currently written, it is difficult to comprehend the effectiveness of mitigation measures included in the Draft EIR and whether or not all or a portion of these mitigation measures will be required as conditicns of project approval. Following are comments related to specific discussion sections in the Draft EIR: Insignificant Environmental Impacts Page 2 -7 - Comments recently received from Moorpark residents and from the Moorpark Branch of the Environmental Coalition appear to contradict the County Planning Division's determination that the project would not produce glare on surrounding properties. The Draft EIR should analyze whether Campus Park West residents and any -- other residential areas in the City of Moorpark are currently being impacted by light and glare from the Blue Star operations. The light and glare impacts of the proposed project should also be analyzed. PAUL W tFtia_�,•. _a _�al�arOC V �ca.Z s..,"' yvNr;;.f.�� apr c 7ALLEr a .CHN E WOZPUa✓ Keith Turner July 26, 1991 Page 2 Proiect Description Page 3 -4 - Hours of operation are not clear. Will operation of the quarry 24 hours a day require inbound or outbound truck traffic after 8:00 p.m. on weekdays and Saturday? Will the new batch plant be operated 24 hours a day? We are opposed to a 24 -hour a day operation if significant light and noise impacts will result. Truck trip restrictions should be imposed - see comments on Noise section. Page 3 -12 - Proposed Reclamation Plan is vague. Since no known reclamation has been accomplished to date, it is important to.have strict controls on when reclamation activities will be accomplished with the proposed expansion. . "As soon as feasible" during each phase is not adequate. Land Use Page 4 -9, paragraph 2 - As written is misleading. Moorpark's Circulation Element update will take into consideration the traffic generated by Happy Camp Regional Park; however, it is not the - City's responsibility to mitigate the traffic impacts of that park. Page 4 -9, paragraph 5 - Contrary to statement in EIR, City of Moorpark does not consider the project as currently proposed to be consistent with the City of Moorpark General Plan due to the significant hillside grading that is proposed, and significant visual, noise and cumulative traffic impacts that will result. Water Resources Page 4 -29 - Mitigation Measure No. 6 requires additional study to verify pond bottom permeability to preclude groundwater mineralization. This study should be done now; future study is not an acceptable mitigation measure. EIR is unclear as to what the mitigation is if underlying groundwater is currently being contaminated. Transportation, Circulation and Safety Traffic .impact analysis is inadequate. The Scope of Work for the EIR infers that the Draft EIR would include traffic data from the City, County, and Caltrans, and that existing deficiencies would be identified. Also, cumulative traffic impacts were to be addressed. The Blue Star Quarry Traffic Study and Draft EIR do not appear to be consistent with the Scope of Work. Current City of Moorpark traffic information on existing and projected traffic was not used -- i to analyze traffic impacts. It is the City's opinion that the Blue Star Quarry Traffic Study incorrectly identifies the existing and projected level of service for all City of Moorpark intersections analyzed. Also, the cumulative traffic data used in the Blue Star Keith Turner July 26, 1991 Page 3 EIR =or the City of Moorpark is not accurate. Several large recently approved as well as proposed projects in the City of Moorpark are not addressed in regard to cumulative traffic impacts. The Blue Star Quarry Traffic Study identifies that regional access to t_^.e quarry site is provided by Highways 23 and 118; however, within the City limits only the intersections along Moorpark Avenue and Walnut Canyon Road are analyzed. The Blue Star expansion project will also affect two critical intersections in the City located along Spring Road -- the Los Angeles Avenue /Spring Road intersection and the High Street /Spring Road /Los Angeles Avenue intersection. A recent traffic study completed for the Westland Company Residential Project (located south of Los Angeles Avenue, west of Liberty Bell and east of Maureen Lane) includes traffic count data collected in May 1990 and updated to address 1991 expected traffic conditions. That study identifies for existing plus 1991 traffic that the Los Angeles Avenue /Spring Road intersection is operating at LOS C for the a.m. and p.m. peak hours and that the High Street /Spring Road /Los Angeles Avenue intersection is operating at LOS D in the a.m. and p.m. peak hours. The Westland Residential Project Traffic Study also identifies that near -term cumulative projects would result in LOS F in the a.m and p.m. peak hours at both of these intersections. Also, that traffic study identifies that near -term cumulative impacts would result in a LOS F in the p.m. at the Moorpark Avenue /Los Angeles Avenue intersection. As an example of its inadequacy, the Traffic Study for the Blue Star project incorrectly identifies the existing plus project plus cumulative LOS at the Moorpark Avenue /Los Angeles Avenue intersection as LOS A. It is also important to note that the City of Moorpark is currently updating its. Land Use and Circulation Elements. Since the Blue Star Quarry is requesting a long -term, 50 -year CUP, the cumulative traffic scenario in the Blue Star Draft EIR should also address what effect the Blue Star project proposal would have on the City's proposed circulation system after buildout of the City's revised land use plan. We request that the EIR consultant be directed to obtain a cumulative project list and current traffic count data from the City of Moorpark and that the intersection capacity analysis be recalculated for all intersections within the City limits that will be a-ffected by the proposed Blue Star Quarry expansion project. If significant traffic impacts will result, appropriate mitigation measures should be identified. Keith Turner July 26,-1991 Page 4 Air Quality Page 4 -60 - The odor impact and mitigation discussion is vague. If night time operation of the asphalt plant will result in a significant odor problem, then Mitigation No. 5 should prohibit night time operation of that plant. Page 4 -62 - We recommend that Mitigation No. 9 require that all roads on the project site be paved with roadway sweeping or scraping of these roads to be conducted at specified time periods. Use of petroleum -based dust suppressants to control emissions would not be appropriate unless the adverse effects from their use are analyzed in the Draft EIR. Requiring future study is not an acceptable mitigation measure. For Mitigation No. 13, we recommend prohibiting the coating of truck bodies with kerosene and fuel oil. Mitigation No. 17 is unclear - exactly what is proposed? Noise The Draft EIR identifies that noise levels along Moorpark Avenue at sites tested are generally in excess of 70 dB Leq, with peak truck traffic noise levels at approximately 77 -83 dB. Significant truck traffic currently begins before 6:00 a.m. Additional project traffic is predicted to increase noise levels by 3 -4 dB in the City limits. No noise mitigation is proposed for Moorpark residents other than a vague inference (Page 4 -69, No. 5) that the number of hourly or daily truck trips could be limited. We recommend that truck trips be prohibited on Sundays and restricted prior to 6:00 a.m. on weekdays, prior to 9:00 a.m. on Saturday, and after 7:00 p.m. on weekdays and Saturdays to minimize truck traffic noise impacts during the times of the day when residents would most likely be adversely affected. The Draft EIR does not specifically identify what impact the proposed batch plant will have on noise levels, and does not clarify how a 24 -hour a day operation will affect noise levels. Visual The photographic exhibits in this section are poorly reproduced and do not allow for analysis of existing view impacts. We do not believe that Phase 3 visual impacts on the City of Moorpark can be fully mitigated due to the level of grading that is proposed. At this time, we are strongly opposed to Phase 3 due to the significant visual impacts that will result and the lack of reclamation /revegetation details provided. eith = 'erne= -uly :5, 15 :l =ace ?ecre_�ion lttho_gh Happy Camp Regional Park i s ;u;is =icticz, we are concerned fro --sers .hat noise, light and glare, ::ate e not been adequately addressed, =_1 `er -ative Haul Routes outside the City of Moorpark's m the standpoint of recreational air quality, and visual impacts is p_=viously identified, Moorpark is currently updating its --i=culatior. Element. A draft circulation plan has been prepared based on a thorough analysis of planned land use and existing and oroje =ted traffic. The City's proposed circulation plan shows an al z�erative route for Highway 23 (similar to Route D analyzed in the -Blue Star EIR) and a rural collector roadway connecting Broad-�ay to Alamos Canyon and Highway 118 (not analyzed in the Blue Star SIR). The Draft EIR should at least reference the City's proposed circulation plan. Based on the City's preliminary Ciicr.Latior. Element update studies, Routes C and E ( as shown in the Blue Star EIR) are not acceptable. In smeary, based on preceding comments which address individual discussion sections in the Draft EIR and our overall concerns related to inadequate mitigation measures, we are recommending that the raft EIR be revised and recirculated for public review. We also request that the mitigation monitoring program be included in a =erased Draft EIR. Based on the past history of non - compliance with conditions of aporczal, project expansion without appropriate permit approval,, and minimal efforts towards reclamation to date, we are recommending that the County consider an alternative to the project proposal which would involve restricting approval to the requested Phase 1 expansion only (i.e, a ten -year limitation on the CUP). This alternative would require a new CUP for subsequent expansion phases. Requiring subsequent CUP approval for proposed Phases 2 and : will aid the County in enforcement of mitigation measures i= 11_-ding reclamation /revegetation requirements. Restricting agprcval to a ten -year period only, will also allow time for fu._--t -er analysis of alternative haul routes consistent with the City of Moorpark's Circulation Element. Plea_e con =act me if you have any questions regarding our comments. Pa -:�r =_-k ,J. Richards Dire__or c: Community Development T_V_ -:--- cc: Honorable City Council area. 1ueny, City Manager To , FLUrnore To Oxnard/Camarillo Isw.w am GRIMES CANYON ALTERNATIVE SR 23 BY-PASS ALTERNATIVE. Spael/b Plan i2 City of Moorpark, MOORPARK 4' SPacMo t Rang Clfy of Moorpark i ti BROADWAY ' ;; EXTENSIONja Y t �1Y al '! yp",... 1\� R 1 10 LOORPARK INTERCHANGES TO BE COMPLETED r IN 1993 EXTENSION TO BE \, COMPLETED IN 1993 To Thousand Oaks `\ To Simi Valley I FIGURE 4 ALTERNATIVE ACCESS ACCESS ROUTES