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Home My WebLink AboutAGENDA REPORT 1991 0717 CC REG ITEM 11AA* MOORPARK 799 Moorpark Avenue Moor Dark, California 93021 M E M O R A N D U M (805) 529 -6864 -'O-'?PARK. CAUFOR,NIA a y Cou I) Meefing of 199 n B TO: The Honorable City Council FROM: Patrick J. Richards, Dire, °tor of Community Development DATE: June 18, 1991 (CC Meeting of 7/1.7/91) SUBJECT: PRELIMINARY COMMENTS ON DRAFT ENVIRONMENTAL IMPACT REPORT (EIR) FOR BLUE STAR QUARRv -- CONDITIONAL USE PERMIT NO. CUP -4633 Discussion Comments on the Blue Star Draft E_t.R are due on July 25, 1991. Attached is the summary section from the Draft EIR. Also attached are staff's preliminary comments on the adequacy of the Blue Star Draft EIR, which we propose to incl °de in a letter to the County. Recommendation Direct staff to prepare a comment letter to the County on the Blue Star Quarry Draft EIR which incorpr )rages staff and City Council concerns. Attachments: Blue Star Quarry Draft EIR Summary Section Preliminary Comments on Blue Star Quarry Draft EIR PAUL W. LAWRASON JR BERNARDO M PEREZ SCOTT MONTGOr +i_RI ROI E TALLEY JR. JOHN E- WOZNIAK Mayor Mayor Pro Tem Councilmemt : Grwncilmember Councilmember CITY OF MOORPARK PRELIMINARY COMMENTS ON DRAFT EIR FOR BLUE STAR QUARRY CONDITIONAL USE PERMIT NO. CUP 4633 We are concerned that this EIR understates the significance of traffic and noise 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 each mitigation measure in reducing the magnitude of impact, clearly identifies the party responsible for implementation and the method by which implementation can be assured, and clarifies whether the mitigation measure is acceptable to the responsible party and has been incorporated into the project of whether the County would need to either adopt the measure as a condition of approval or adopt a Statement of Overriding Considerations„ Following are comments related to specific discussion sect ons in the Draft EIR: Project Description Page 3 -4 - Hours of operation are aot clear. Will operation of 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 light and noise impacts will result. Truck trip restrictions should be imposed - se, comments on. Noise section. 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 1- °ark; however, it is not the City's responsibility to mitigate th( traffic impacts of that park. Page 4 -9, paragraph 5 - Contrary 1.o 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 ;_s proposed, and significant visual, noise and cumulative traffi impacts that will result. Water Resources Pages 4 -22 through 4 -24 are missing Page 4 -29 - Mitigation Measure No. s, 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. b;IR is unclear as to what the mitigation is if underlying groundwater is currently being contaminated. El Transportation Circulation and Safety Traffic impact analysis is inadequate. Traffic Study identifies that regional access to the 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 (outside of the City limits Happy Camp /Broadway and Grimes Canyon Road /Broadway intersections are also analyzed) The Scope of Work for the EIR ..refers that the Draft EIR would include traffic data from City, County, and Caltrans, and that existing deficiencies will be identified. Also, cumulative traffic impacts were to be addressed. The Traffic Study and Draft EIR do not appear to be consistent with ..he Scope of Work. Current City traffic data on existing and prr:J ected traffic was not used to analyze traffic impacts. Cumulative traffic data must not have been discussed with City staff, since several large projects proposed or recently approved ar( not addressed (such as Mission Bell Plaza, Westland Residential.F oject, Martin V. Smith Hotel and Apartment project, etc:.), The Blue Star expansion project will affect two critical intersections in the City -- Los Angeles Avenue /Spring Road and the High Street /Spring Road /Los Angeles Avenue intersections -- which' were not analyzed in the Blue Star Quarry Traffic Study. A recent traffic study completed for th( Westland Residential Project includes traffic count data co.11et:ted in May 1990 and updated to address 1991 expected traffic con,itions. That study identifies for existing plus 1991 traffic that the Los Angeles Avenue /Spring Road intersection is operating at _OS C for the a.m. and p.m. peak hours and that the High Street /:-.pri.ng Road /Los Angeles Avenue intersection is operating at LOS 1) in the a.m. and p.m. peak hours. The Westland Residential Project: Ti, aff is Study also identifies that near -term cumulative projects woul i resuli- in LOS F in the a.m and P.m. peak hours at both of these i..rr;:ersect. ions. Also, that traffic study identifies that near -term curniulative .impacts would result in a LOS F in the p.m. at the Moon €lark Avenue /Los Angeles Avenue intersection. The Traffic Stu('y for the Blue Star project identifies that the project plus :umulattve LOS at the Moorpark Avenue /Los Angeles Avenue will bc� -OS A. We request that the EIR consul °ant 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 affected by the proposed Blue St :.r Quarry expansion project. If significant traffic impacts will °es.ilt appropriate mitigation measures should be identified. 3 11 Air Ouality Page 4 -62 - For Mitigation No. 9, we recommend that paved roads on project site be required or that adverse effects from petroleum - based dust suppressants be 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 ioise levels. EIR also does not clarify how a 24 -hour a day opera +ion will affect noise levels. Visual The photographic exhibits in this ection are poorly reproduced and do not allow for analysis of view : Lmpacts. We do not believe that Phase 3 visual impacts on the City of Moorpark can be fully mitigated dut to the level of grading that is proposed. At this time, we are st,ongly opposed to Phase 3 due to the significant visual impacts tf�:'t will result and the lack of reclamation /revegetation details , r- ovided . Based on preceding comments wh:ic� address individual discussion sections in the Draft EIR and om.r overall concerns related to inadequate mitigation measures, we are recommending that the Draft EIR be revised and recirculated. We request that the mitigation monitoring program be included J..n revised Draft EIR. 4 Based on the past history of non- compliance with conditions of approval, project expansion without appropriate permit approval, and minimal efforts towards reclamation to date, we are recommending that the County cons..L.der restricting approval to the requested Phase 1 expansion only (ti.e, a ten -year limitation on the CUP). Subsequent expansion phases should require a new CUP. Requiring subsequent CUP approval for proposed Phases 2 and 3 will aid the County in enforcement of mitigation measures including reclamation /revegetation requirements. At this time we are strongly opposed to Phase 3 appro�,,,al due to the significant visual impacts that will result. Postponing approval of Phases 2 and 3 will also allow time for further analysis of alternative haul routes. For example, in conjunction with the City's current General' Plan Update, we are analyzing a circulation plan wh_-ch includes a rural collector connecting Broadway to Alamos Canon at. Highway 118. I