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HomeMy WebLinkAboutAGENDA REPORT 1994 1207 CC REG ITEM 11HTO: FROM: DATE: A G E N D A R E P O R T C I T Y O F M O O R P A R K The Honorable City Council ITEM110 H• Jaime Aguilera, Director of Community Development/ Deborah S. Traffenstedt, Senior Planner T November 28, 1994 (CC Meeting of 12 -7 -94) SUBJECT: CONSIDER COMMENT LETTER ON COUNTY OF VENTURA INITIATED GENERAL PLAN AMENDMENT REGARDING TRANSPORTATION/ CIRCULATION GOALS AND POLICIES Background Attached is a copy of a Notice of Public Hearing (Attachment 1), information on the project description and environmental impacts (Attachment 2), and a copy of the City's comment letter and the County's response letter from the Final Supplemental Environmental Impact Report for the County General Plan amendment regarding Transportation /Circulation Section goals and policies (Attachment 3). The County Planning Commission's public hearing was held on November 17, 1994, and the Board of Supervisor's hearing is scheduled for December 13, 1994. Discussion Staff's primary concern with the proposed General Plan amendment, is that General Plan Transportation /Circulation policies are intended to be adopted, which would allow County projects to be approved that could result in significant, unmitigated traffic impacts in the City of Moorpark. The project description information in Attachment 2 includes the proposed changes to the County General Plan Transportation/ Circulation Section goals and policies. Staff is concerned that proposed Policy 4.2.2.5 would allow the County to approve a project, such as Happy Camp Canyon Golf Course or Transit Mixed Concrete Mine, and not require any traffic mitigation measures for impacts to roadways and State highways located within the City. The language is broad enough so as to allow interpretation that if a city had not already adopted "...General Plan policies, ordinances, or a reciprocal agreement with the County (similar to Policies 4.2.2 -3 through 4.2.2- 6)... ", dst- 11- 28- 9411: I4PMC:\WP5I\STFRPT\CC12- 7CO.GPA 00411 The Honorable City Council November 28, 1994 Page 2 before a County project reached the public hearing stage, the County could approve that project and not require any mitigation of traffic impacts to a city. Also, we do not agree that adoption of the proposed policy language relieves the County of its obligation to use its authority to require changes, in any or all activities involved in a project, in order to lessen or avoid significant effects on the environment. Section 21002 of the California Environmental Quality Act includes the following language: The Legislature finds and declares that it is the policy of the state that public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects... It is the City Attorney's opinion that the County's adoption of the proposed revisions to their General Plan Transportation /Circulation policies does not relieve them of their obligation, pursuant to the California Environmental Quality Act, to require feasible mitigation for potentially significant impacts. In order to meet the legal requirements for a challenge to the action, the City Attorney has recommended that a letter be sent to the County expressing the City's opposition to the proposed General Plan amendment, and that staff attend the Board of Supervisor's hearing and verbally express the City's opposition. Recommendation Direct staff to prepare a letter to the Board of Supervisors, to be signed by the Mayor, that expresses the City's opposition to the proposed County General Plan Transportation /Circulation Section policy revisions, and direct staff to attend the scheduled Board public hearing to verbally express the reasons for the City's opposition. Attachments: 1. Notice of Public Hearing 2. Project Description and Environmental Impact excerpts from the Final Supplemental EIR 2. City's comment letter on Final Supplemental EIR and County's response letter det- 11- 28- 94/ 1 :14pW:\WP51\STFRPT\CC12- 7CO.GPA 00111 ATTACHMENT i RESOURCE MANAGEMENT AGENCY county of viEntura Planning Division Keith A. Turner Director RECEIVED 94 -1 80 n NOTICE OF PUBLIC HEARING BEFORE THE i994 VENTURA COUNTY PLANNING COMMISSION A AND VENTURA COUNTY BOARD OF SUPERVISORS FOR of iftorpar� COUNTY- INITIATED GENERAL PLAN AMENDMENT REGARDING bmm!!miv 0,3veiwrent Departme TRANSPORTATION/ CIRCULATION GOALS AND POLICIES, AND PUBLIC FACILITIES AND SERVICES APPENDIX r, The County- initiated General Plan Amendment. is proposed as follows: L: Goals, Policies and Programs Document This proposed amendment would modify the existing goals and policies of the Transportation /Circulation Section of the County's General Plan to: (1) provide a change in the Level of Service (LOS) standards for County roads, and Federal and State highways, (2) revise LOS thresholds for determining the need for road widening, (3) amend the Public Facilities Map to reflect reduced road widening, (4) replace provisions prohibiting discretionary development that would have certain impacts on the roads with provisions allowing sucr development, upon payment of fees, to provide its pro -rata share of road improvement costs, and (5) clarify related goals and policies. Public Facilities Appendix This proposed amendment would modify the text and figures within the Transportation /Circulation section to: (1) add a table showing Average Daily Trips (ADT) and LOS thresholds for different types of roads, (2) modify the 2010 Regional Road Network Map to reflect updated information regarding ADTs and number of lanes, and (3) update the text and figures to be consistent with the amendment= to the Goals, Policies and Programs document. A Supplemental Environmental Impact Report for this proposed project, prepared pursuant to the provisions of the California Erivironmental Quality Act (CEQA) and the County's Administrative Supplement to CEQA, indicates that the project (identified in the Supplemental EIR as "Alternative 2 ") may have a significant effect on the environment (Farmland and Farming Operations, Air Quality, Noise, Biological Resources, Traffic Flow, and Visual effects), and a Statement of overriding Considerations must be prepared for the project. Members of the public are invited to attend and be heard at the public hearing to be held by the PLANNING COMMISSION OF VENTURA COUNTY on Thursday, November 17, 1994, at 8:30 a.m., in the Board of Supervisors Hearing Room, County Government Center, Hall of Administration, 800 South. Victoria Avenue, Ventura, California, and at the public hearing held by the BOARD OF SUPERVISORS OF VENTURA COUNTY on Tuesday, December 13, 1994, at 1:30 F.m. at the same location. Questions concerning this proposed project may be directed to Kelly Scoles, RMA Planning, L #1740, 800 South Victoria Avenue, Ventura, California, or at (805) 654 -5042 Monday through Thursday, 7:C0 a rr.-3:00 p.m. If you challenge in court the action taken on the project described in this notice, you may be limited to raising only those issues you or someone raised at the public hearings described in this Notice, or in written correspondence delivered to the Ventura County Planninc: Directcr at, or prior to, the public hearings. 800 South Victoria Avenue, L # 1740, Ventura, CA 93009 cc, & ily m►f,,, D G a Printed on Recycled Paper 00 "12 (805) 654 -2481 FAX (805) 654 -2509 .rte r: r ATTACHMENT 2 VENTURA COUNTY RESOURCE MANAGEMENT AGENCY FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT FOR GENERAL PLAN AMENDMENT ( TRANSPORTATION /CIRCULATION GOALS AND POLICIES) SCH. NO. 87100711 The Environmental Report Review Committee recommends that the decision - making body of the proposed project find that this document has been completed in compliance with the California Environmental Quality Act. Chair, Environmental Report Review Committee Date R C �1/ED 00113 l 1994 uornfTm 9eVe,100111rt n9U8!;IP2CI I. FOREWORD (SUPPLEMENTAL EIR) Existing General Plan Transportation /Circulation goals and policies provide that discretionary development producing individual or cumulative traffic impacts which would result in an existing road within the Regional Road Network currently functioning at an acceptable Level of Service (LOS) to fall below that LOS, or would worsen traffic conditions on roads within the Regional Road Network which currently function below the acceptable County LOS, shall be prohibited unless a full funding mechanism is provided to ensure that those impacts are mitigated within a reasonable period of time. In effect, the existing goals and policies prohibit any discretionary development, without full funding of road improvements, which will generate traffic on roads expected to fall below acceptable County LOS standards by 2010. On March 23, 1993, the Board of Supervisors directed the Public Works Agency to prepare a Traffic Impact Mitigation Fee Ordinance and directed the Resource Management Agency to prepare amendments to the General Plan Transportation /Circulation goals and policies for the Board's consideration. The purpose of the Traffic Impact Mitigation Fee Ordinance is to establish a funding mechanism for improvements to the Regional Road Network. The purpose of the General Plan Amendment is to establish a policy which requires payment of the traffic impact fee as mitigation of the cumulative traffic impacts of discretionary development. An amendment to the County General Plan required the preparation of a Supplement to Comprehensive Update. 1F52- 1.94/1 Traffic /Circulation Section goals and policies the EIR prepared for the 1988 General Plan 00114 III. PROJECT DESCRIPTION (SUPPLEMENTAL EIR) Ventura County is processing an amendment to the Ventura County General Plan. This amendment is described below: A. PROJECT APPLICANT County of Ventura 800 South Victoria Avenue Ventura, CA 93009 B. PROJECT LOCATION This amendment to the County General Plan covers future discretionary development located in the unincorporated area of Ventura County. C. PROJECT OBJECTIVES The objectives of this amendment to the General Plan are to revise the Transportation/ Circulation goals and policies (Sections 4.2.1 and 4.2.2 of the Goals, Policies and Programs document) to modify the Level of Service (LOS) standards for i road segments and intersections within the Regional Road Network, and to require that discretionary development which would have a cumulative impact on existing and future roads pay its pro -rata share of the costs of necessary improvements on the Regional Road Network as established in the County Traffic Impact Mitigation Fee Ordinance (see Section D). The existing goals and policies of the Transportation /Circulation Section of the County General Plan establish LOS standards for the entire Regional Road Network including all County thoroughfares, County- maintained roads, and for all Federal highways and State highways. The proposed amendment would enable cities to prescribe LOS standards for those Federal and State highways which are located within their corporate boundaries, as well as their own roads and thoroughfares. The existing General Plan policies provide that County General Plan land use designation changes, zone changes and discretionary development producing individual or cumulative traffic impacts which would: (a) result in an existing road within the Regional Road Network currently functioning at an acceptable LOS to fall below that LOS, or (b) worsen traffic conditions on roads within the Regional Road Network which currently function below the acceptable County LOS, shall be prohibited unless a full funding commitment is made to ensure that those impacts are mitigated within a reasonable period of time. 1F52- 1.94/11 00115 improvements to the Regional Road Network as provided under the provisions of the Traffic Mitigation Fee Ordinance. Project specific impacts will continue to required fully funded improvements to ensure that the affected road segments remain within acceptable County LOS standards. D. PROJECT SPECIFICS The proposed changes to the Transportation /Circulation Section goals and policies are as follows: 4.2.1 GOALS 2. Ensure that as new discretionaa development creates the need, existing roads within the Regional Road Network and Local Road Network are improved, and additional roads needed to complement the Regional Road Network and Local Road Network are constructed, so as to keep all such roads functioning at an acceptable LOS. 3. Ensure that eaeh new development which would individually of eufnuiatiyelyy contribute to the cumulative need for improvements or additions to the Regional Road Network of LeealE Rea Netwer k bears its pro -rata share of the costs of all such improvements or additions. 4.2.2 POLICIES C 3. The minimum acceptable Level of Service (LOS) for road segments and intersections within the Regional Road Network and Local Road Network shall be as follows: a. LOS -'D' for all County thoroughfares. County - maintained local roads and Federal highways and State highways in the unincorporated area of the County, except as otherwise provided in subparagraph (b); b. LOS -'E' for State Route 33 between the northerly end of the Ojai Freeway and the City of Ojai; e. LOS 'C' roads;; and 1 F52 -1.94/ 12 00 .16 \ c.d- The LOS prescribed by the applicable city for all Federal highways, \ State highways, city thoroughfares and city - maintained local roads located within that city, if the city has formally adopted General Plan policies, ordinances, or reciprocal agreement with the County (similar to Policies 4.2.2 -3 through 4.2.2 -56) respecting development in the city that would individually or cumulatively affect the LOS of Federal highways, State highways, County thoroughfares and County - maintained local roads in the unincorporated area of the County. At any intersection between two roads, each of which has a prescribed minimum acceptable LOS, the lower LOS of the two shall be the minimum acceptable LOS for that intersection. 4. County General Plan land use designation changes, zone changes and discretionary development shall be evaluated for their individual &id eufflulativ impact on existing and future roads, with special emphasis on the following: (a) Whether they project would cause existing roads within the Regional Road Network or Local Road Network that are currently functioning at an acceptable LOS to function below an acceptable LOS; (b) Whether they project would worsen traffic conditions on existing roads within the Regional Road Network or the Local Road Network that are currently functioning below an acceptable LOS; and (c) Whether they rp oject could cause future roads planned for addition to the Regional Road Network or the Local Road Network to function below an acceptable LOS. 5. County General Plan land use designation changes, zone changes and discretionary development which would individually er cause any of the impacts identified in subparagraphs (a) through (c) of Policy 4.2.2 -4 shall be prohibited unless feasible mitigation measures are adopted which would ensure that the impact does not occur or unless a project completion schedule and full funding commitment for road improvements are adopted which ensure that the impact will be eliminated within a reasonable period of time. This policy does not apply to city thoroughfares er, city - maintained local roads or Federal or State highways located within a city unless the applicable city has formally adopted General Plan policies, ordinances, or reciprocal agreement with the County (similar to Policies 4.2.E -3 through 4.2.2--56 ) respecting diseeetienary development in the city that would affect the LOS of County thoroughfares and County- maintained local roads, and Federal or State highways located within the unincorporated area of the Countti. 1F52- 1.94/13 00117 6. Development that would generate additional traffic shall pay its pro -rata share of the costs of necessary improvements to the Regional Road Network per the County's Traffic Impact Mitigation Fee Ordinance, as may be amended from time to time. 7. 6. The County shall oppose discretionary development within cities, and annexation to cities for the purposes of development, where such development would individually or cumulatively cause: 1 F52-1.94/14 (a) Any existing road within the Regional Road Network, or any existing County - maintained local road, that is currently functioning at an acceptable LOS to function below an acceptable LOS, necessary to efis,...o that the C....e fienin of the d 41. be « d te an (b) Any existing road within the Regional Road Network, or any existing County - maintained local road, that is currently operating below an acceptable LOS to function at an even lower LOS, unless a f ..sib or (c) Any future road planned for addition to the Regional Road Network, or any planned future County- maintained local road, to function below an acceptable LOS. This policy does not al2ply to those cities which have formally adopted General Plan policies. ordinances, or reciprocal agreement with the County similar to Policies 4.2.2 -3 through 4.2.2 -6 IV. ENVIRONMENTAL SETTING IMPACTS AND MITIGATION MEASURES (INCLUDING ALTERNATIVES) K. TRANSPORTATION /CIRCULATION 1. ROADS AND HIGHWAYS a. Setting The Ventura County Regional Road Network consists of Federal highways. State highways. County thoroughfares city thoroughfares and reserved rights of way. The Local Road Network consists of County - maintained local roads and city - maintained local roads. - The existing (1x986) if 992) Regional Road Network consists of 541 miles of County maintained thoroughfares and 267 miles of State maintained freeways, expressways, and conventional highways. State highways and freeways traversing the county include State Route 1, State Route 23, State Route 33, State Route 34, State Route 118, State Route 126, State Route 150, State Route 232 and U. S. 101. U. S. 101 carries the greatest traffic volumes and is the only road in Ventura County which is entirely constructed as a freeway or expressway within the eounty County. Level of service (LOS) is a term which provides a qualitative description of operating performance of a road or intersection based on traffic conditions regarding speed, travel time, freedom to maneuver, traffic interruptions and motorists' perceptions (see Figure 29a). The levels range from 74 "A" (free flow conditions) to F "F" (jammed conditions). The Ventura County General Plan specifies that LOS "C" is acceptable on County roads; LOS "D" is acceptable for State highways (except for Highway 33 between the end of the freeway and the City of Oiai); LOS "Er' is acceptable for Hi hway 33 between the end of the freeway and the City of Ojai The 1994 General Plan Transportation /Circulation goals and policies amendment would amend these standards to apply only to the unincoMorated areas of the County. City thoroughfares and State freeways and conventional highways within cities would be subject to the LOS standards of the particular city's General Plan For purposes of establishing traffic mitigation 1 fees, the County does not recognize a city's LOS standards unless a reciprocal agreement exists between that city and the County. ' ='p �'�'�-��� 7,: ♦ ' ,. A- - ,- -.--A rU 7 Yl(, "Tn uru • . , , r ..r�trivrc. past -iei�t -tear. 1F52- 1.94/15 00 119 At the present time. the County has two reciprocal traffic agreements with cities: one with the City of Agoura Hills (for mitigation of traffic impacts in Zone III in Oak Park and Ahmanson Ranch) and one with the City of Oxnard Agoura Hills' General Plan establishes LOS "C" as the city's standard The City of Oxnard's General Plan establishes the city standard at LOS "C" excepting a few intersections within its jurisdiction. The 1993 Congestion Management Plan (CMP) prepared by the Ventura County Transportation Commission (VCTC), designates LOS "E" (unstable flow at or near capacity) as the minimum system -wide standard Roads which have existing traffic congestion at LOS "F" have been accepted at that traffic level to avoid the penalty of loss of gas tax funds. LOS "F" is a temporary traffic level designation which is upgraded to LOS "E" once improvements are built Caltrans-Di strict 7 has determined that LOS "E" and "F" is acceptable for conventional State Hi hways, and that LOS "FO" (forced flow operation with a duration of more than 15 minutes and less than one hour and operating speed of less than 20 miles per hour) is the minimum acceptable LOS for the freeway system. Caltrans will consider funding capacity enhancing_ projects only when the operating LOS deteriorates to less than that which Caltrans-Di strict 7 considers acceptable. Construction of desired road improvements prior to reaching these levels requires local financial participation ( The existing Regional Road Network in Ventura County is generally adequate to meet existing traffic needs. However, according to a the 4484 1993 Congestion Management Plan's LOS monitoring, and taking into account recent freeway widening work on U. S. 101, approximately 44 35.92 miles of the existing County Regional Road Network (excluding city thorou hfares) currently operates below current 1=08 -0 County LOS standards (see Figure 29b). These roads include portions of State - Reute-- 33 &ate Reete 118-- U. S. -11, and Vietafia State Routes 23, 34. 118 and U.S 101. b. Environmental Impacts 1F52- 1.94/17 Traffic Congestion - Development in accordance with the General Plan land use policies (whieh including city general plans) will result in significant increases in traffic. Specific traffic projections for 31 County subareas are detailed in Ventura County Area Transportation Study (VCATS, September 1987). The County's adopted Population /Dwelling -Unit Forecast projects an average population increase of 2.3 percent per year from 1987 to the year 2010. This will result in approximately 274,440 additional County residents and 137,420 additional dwelling units. The increased number of residents, coupled with a projected 90% increase in County jobs, will translate into significant increases in vehicle trips (889,290 vehicle trips between 1994 and 2010). 00IL 20 Given these projections, if no improvements to the existing Regional Road \ Network were made, traffic conditions in the County would substantially decline. Excluding city thoroughfares and Federal or State highways located within a city, approximately 4-2-5 72 miles of County roads and State highways /freeways would be operating below 1S "G" current County LOS standards, with more than 4-08 60 miles of roads and highways operating at LOS "F" (Figure 30). Estimates of projected decline in LOS on City thoroughfares are not available at this time Allowing planned growth without improving the roadway netwafk), Regional Road Network would result in significant adverse impacts weld -eeeur- with respect to traffic congestion, air pollution (from idled engines) and energy (fuel consumption). Additionally, economic effects would occur as a result of increased travel time and would (potentially) decrease tourism. A perceived, if not real, decline in the quality of life would occur as a result of frustration over traffic delays. 1F52- 1.94/19 Figure 31 illustrates the Regional Road Network , illu tfates the read ..e.,,.,,.,. (excluding city thoroughfares and State conventional highways within cities) which will be necessary to adequately accommodate tr-a€€e tiens based the 2010 traffic projections. Figures 32a and b list the projected improvements to the Regional Road Network in the unincorporated area to maintain County LOS standards. Figure 33 illustrates the projected improvements to the 2010 Regional Road Network listed in Figures 32a and b. The proposed network would operate at LOS "C" for County thoroughfares and LOS "D" for State maintained highways, freeways and expressways, and at —1✓' fey except for State Route 33 between Casitas Springs and the City of Ojai. 00121 . .. - Wn - _. .... ._ 1F52- 1.94/19 Figure 31 illustrates the Regional Road Network , illu tfates the read ..e.,,.,,.,. (excluding city thoroughfares and State conventional highways within cities) which will be necessary to adequately accommodate tr-a€€e tiens based the 2010 traffic projections. Figures 32a and b list the projected improvements to the Regional Road Network in the unincorporated area to maintain County LOS standards. Figure 33 illustrates the projected improvements to the 2010 Regional Road Network listed in Figures 32a and b. The proposed network would operate at LOS "C" for County thoroughfares and LOS "D" for State maintained highways, freeways and expressways, and at —1✓' fey except for State Route 33 between Casitas Springs and the City of Ojai. 00121 that dese6bed . As noted previously, the acceptable LOS for Highway 33 is LOS "E ". According to the Draft EIR (DEIR) for the Update of the Ojai Valley Area Plan. cumulative development potential of the Plan would likely cause segments of Highway 33 to fall below LOS "E" some time before 2010 T#e That DEIR offers mitigation measures to decrease project and cumulative traffic impacts, but concludes that these may not be feasible and may not reduce the impact to a less than significant level. Roadway Improvements - The 2010 Regional Road Network in the unincorporated area will require construction of 2(4 135.9 lane -miles of State highway /County thoroughfares and 444 40.2 lane -miles of freeways and expressways. in addition existing (includes the construction of 43 6_0 lane -miles of new State highwaysf, 3.26 lane -miles of new County thoroughfares and 6-.2 24.6 lane -miles of new freeways, including 5 new freeway interchanges). The precise number of miles of freeways expressways and thoroughfares within cities' boundaries is not available at this time While the construction of the proposed 2010 Regional Road Network improvements would ensure that traffic congestion impacts generated by the 4m ft General Plan land use policies would not result in significant changes from existing levels of service (except for State Route 33 between Casitas Springs and the City of Ojai), the construction of the proposed road improvements could result in several potentially significant effects, which are summarized below: Farmland and Farming Operations - The various road improvement projects in the unincorporated area will physically consume approximately 242 190 acres of agricultural land. Road widening within some cities would also result in some loss of agricultural land. Approximately 439 100 Agricultural Land Conservation Act contracts will be impacted. The increase in traffic on rural farm roads and the construction of new roads in agricultural areas may adversely affect farm operations by impeding the movement of farm equipment between fields separated by roads. These tra€€ie related -f mid impacts are considered significant due to the high productivity of Ventura County farmland and its importance to the local and regional economy (see also Section IV E of this EIR for a further discussion of farmland, and farming operations impacts). Air Quality - Construction of the proposed 2010 Regional Road Network improvements will result in particulate. ROC and NOx air quality impacts due to construction activities and due to increased numbers of vehicles which will be able to utilize the road network. Impacts from ROC and NOx should be partially offset by decreased air pollution due to improved traffic flow conditions. A temporary increase in particulate matter (PNI") as a result of roadway construction may he ex ectzd_ 1F52- 1.94/27 00122 V. RELATIONSHIP BETWEEN LOCAL SHORT -TERM USES OF THE HUMAN ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG -TERM PRODUCTIVITY The CEQA Guidelines require that an EIR prepared for a project for which there may be a significant impact on the environment include a statement of the relationship between local short-term uses of the environment and the maintenance and enhancement of long -term productivity. Existing General Plan policies provide that discretionary development producing individual or cumulative traffic impacts which would result in an existing road within the Regional Road Network currently functioning at an acceptable LOS to fall below that LOS, or would worsen traffic conditions on roads within the Regional Road Network which currently function below the acceptable County LOS, shall be prohibited without a full funding commitment to ensure that those impacts are mitigated within a reasonable period of time. This policy effectively prohibits any discretionary development, without full funding of road improvements, which will generate one peak -hour trip on those roads expected to fall below, acceptable County LOS by 2010 and are not currently funded for improvement. The proposed amendment to the General Plan goals and policies will permit approval of projects with cumulative traffic impacts on the Regional Road Network upon payment of a traffic mitigation fee, formulated to represent the project's pro -rata share of designated Regional Road Network improvements. Project - specific traffic impacts will still require full funding mechanisms for mitigation and approval. J` Except for those impacts already identified in the 1988 General Plan EIR, the pro sed amendment is not expected to have a significant impact on the environment in the short- tterm. The significant or potentially significant adverse long -term environmental effects of constructing the Regional Road Network improvements have been identified in this Supplemental EIR as occurring to: Farmlands and Farming Operations, Air Quality, Noise, Visual Resources, Cultural and Historical Resources, Biology, and Growth- Inducement. However, since it is recognized that the Traffic Impact Mitigation Fee Ordinance will not result in complete funding of all necessary improvements to the Regional Road Network, the LOS on some roads can be expected to drop below acceptable County standards by the year 2010. This will result in significant impacts to Farming Operations (p. 35), Air Quality (p. 36), and Noise (p. 36) from the long -term effects of increased traffic on inadequate roads. §' 1F52- 1.94/61 00123 August 10, 1994 ATTACH TENT 3 MOORPARK 799 Moorpark Avenue Moorpark, California 93021 (805) 529.6064 Kelly Scoles Resource Management Planning Division County of Ventura 800 South Victoria Ventura, CA 93009 Agency Avenue, L #1740 SUBJECT: COMMENTS ON DRAFT SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT (EIR) FOR GENERAL PLAN AMENDMENT (TRANSPORTATION / CIRCULATION GOALS AND POLICIES) - SCH NO. 87100711 Dear Ms. Scoles: Thank you for the opportunity to comment on the above referenced Draft Supplemental EIR. We are concerned that none of the County Regional Road Network assumptions take into consideration the City of Moorpark's adopted General Plan Circulation Element. We also • have concerns related to the specific wording of several of the transportation /circulation policies proposed to be amended. In regard to the County Regional Road Network assumptions, a State Route 23 bypass connecting to Broadway should be addressed in the funding options. The City's Circulation Element also assumes that Broadway would be extended to a new interchange with State Route 118. These new roadways are considered necessary to serve both local and regional projected traffic needs. The proposed Transportation /Circulation Section policies, 4.2.2 -3, 4.2.2 -5, and 4.2.2 -6, would require that a city already have adopted General Plan policies and /or ordinances similar to the County proposed policies, or no mitigation measures to minimize traffic impacts on city maintained local roads or Federal or State highways located within a city would be imposed on discretionary development projects. There would appear to be no time allowance for negotiation of a reciprocal agreement, as is suggested in other sections of the EIR. Obviously, it would not be possible for the City of Moorpark to have the same or similar policies or an ordinance adopted, before the County completes its current General Plan update. It may also be appropriate for reciprocal agreements to be negotiated on a project -by- project basis, to ensure that mitigation money is spent on circulation improvements which will truly mitigate the cumulative traffic impacts associated with a particular development project., 00124 PAUL W. LAWRASON JR. PATRICK HUNTER .;C -N E VVCZNIAK BERNARDO M. PEREZ SCOTT, MCVTGCMERY n Camciimember Counah►ember Mayor Mayor Pro Tam _,oncdmembe / - P-WOO W AayNW Pam, Kelly Scoles August 10, 1994 Page 2 In summary, we believe that the draft General Plan policies, as currently drafted, should be modified. In addition, all County discretionary projects, which would result in a traffic impact on a city maintained road or on a State highway located within a city, should be conditioned so as to require funding of the required improvement(s) or payment of a city traffic impact fee, if a reciprocal agreement is negotiated prior to a specified time period. For example, this type of condition of approval was imposed on Conditional Use Permit No. 4571, Quality Rock. while the condition language is somewhat vague, it is a starting point for discussion. Sincerely, to Aguilera Director of Community Development JRA /DST cc: Honorable City Council Steven Kueny, City Manager Ken Gilbert, Director of Public Works Charles Abbott, City Engineer Il 00251 M RESOURCE MANAGEMENT AGENCY �ourity of ventura N-6 17011 September 27, 1994 Jaime Aguilera, Director Moorpark Community Development Department 799 Moorpark Avenue Moorpark, CA 93021 Planning Division Keith A. Turr,r, Direc-k Subject: Response to Your August 10, 1994 Comments on Draft Supplemental EIR for General Plan Amendment to the Transportation /Circulation Goals and Policies Dear Mr. Aguilera: Thank you for your comments on the subject document. The following responses are provided: The determination of the need for Regional Road Network improvements was based upon projected Average Daily Traffic (ADT) for a given road segment. According to the information provided by the Public Works Agency's Traffic Section, the projected 2010 ADT for Route 23 can be accommodated on existing roadway improvements. Nonetheless, the plans which the City may have for a Route 23 bypass could be discussed as part of a reciprocal agreement between the City and the County. The County's Public Works Agency does not agree that a new interchange with State Route 118 in the Moorpark area is needed before 2010. Should a new interchange be warranted due to development in the City of Moorpark, it could be discussed as part of a reciprocal agreement between the County and the City. The proposed amendment to the Transportation /Circulation section policies 4.2.2 -3, -5, and -6, does = require that a reciprocal agreement between a given city and the County be in effect at the adoption of this General Plan Amendment. Rather, we expect negotiations between the cities which do not yet have reciprocal agreements with the County to begin after action by the Hoard of Supervisors on the proposed amendment. 800 South Victoria Avenue, L tt 1740, Ventura, CA 93009 1805) 654 -2481 FAX (805) 654 -2509 Printed on .7ecyclec Paper 00 126 Jaime Aguilera -2- September 27, 1994 The County is most anxious to work with the cities to achieve funding of needed Regional Road Network improvements through reciprocal agreements. Accordingly, while the County will not categorically reject the idea of a project -by- project negotiation of reciprocal agreements, we consider that solution to be highly time - consuming and inefficient. If you have additional comments or questions on this matter, please contact Kelly Scoles at (805) 654 -5042. Sincerely, Bruce Smith, Manager General Plan Section cc: Bob Brownie, County Public Works Agency i 00127