I just received a copy of this letter which was sent to Escondido Assistant Planning Director Jay Petrek by email today. Lots of interesting comments here. This letter is from TODD SNYDER, Chief, Advance Planning Division, County of San Diego.
April 22, 2014
Jay Petrek, AICP
Assistant Planning Director City of Escondido
201 N. Broadway
Escondido, CA 92025
Via email to Jpetrek@ci.escondido.ca.us
COMMENTS ON THE SAFARI HIGHLANDS RANCH PROJECT AND REQUEST FOR ANNEXATION INITIATION HEARING
Dear Mr. Petrek:
The County of San Diego (County) has received the materials submitted to the City of Escondido to request an annexation initiation hearing for Safari Highlands Ranch, dated March 12, 2014, and appreciates this opportunity to comment. County Planning & Development Services (PDS), Department of Parks and Recreation (DPR), Department of Public Works (DPW) and the County Fire Authority have the following comments for your consideration. The comments in this letter should not be construed as support for the project or the annexation.
Concordia Communities, LLC is proposing an annexation to the City of Escondido of an approximately 1,100 acre property currently located in the unincorporated area of the County, outside of the sphere of influence of the City of Escondido. The project would allow development of 550 single family estate homes among several neighborhoods at a density of 1 unit per 2 acres and lot sizes ranging from 10,000 square feet to one acre. The project may include an on-site sewer treatment/water reclamation facility, parks and trails, and a proposed fire station. This area is designated in the City’s General Plan as Specific Plan Area (SPA), or the Valley View SPA#4. This area does not have an adopted Specific Plan, but the General Plan includes Guiding Principles for development of this SPA.
1. The County Land Use and Environment Group has developed Guidelines for Determining Significance that are used to determine the significance of environmental impacts and mitigation options for addressing potentially significant impacts in the unincorporated portions of the County. Project impacts that could have potentially significant adverse effects to the unincorporated County or County facilities should be evaluated using the County’s Guidelines for Determining Significance. These guidelines are available online at: http://www.sdcounty .ca.gov/dplu/procguid .html#guide.
2. Under the existing County of San Diego General Plan Rural Lands (RL-40) Land Use Designation, the 1,100 acre project site would accommodate approximately 27 single family units. The County General Plan states that rural areas are not appropriate for intensive residential or commercial uses due to significant topographical or environmental constraints, limited access, and the lack of public services or facilities. The rural lands designation is intended to:
a. Preserve the County’s rural atmosphere
b. Protect land with significant physical or environmental constraints or hazards
c. Preserve open space, farmland, and natural resources
d. Provide open space buffers and a visual separation between communities
e. Preserve and provide land for agricultural opportunities
f. Prevent sprawl development, thereby reducing vehicle miles traveled and greenhouse gas emissions.
Although the project includes a proposed annexation to the City of Escondido, the County will be reviewing this project in relation to its ability to meet the goals for Rural Lands as designated in the County General Plan.
3. City of Escondido Annexation Policy 16.6 states: “Maintain an annexation procedures manual outlining the steps and city policies regarding annexations that includes, but is not be limited to, applicant’s responsibilities, requirements for environmental review, requirements for development plans, and fees for annexation.” The County requests a copy of this procedures manual for annexation to fully understand the considerations of the City when annexations are proposed. UPDATE: City of Escondido Annexation Guide is available online.
4. Of the 1,100-acre Safari Highlands Ranch site, approximately 400 acres in the northern portion are in the County’s proposed Multiple Species Conservation Program (MSCP) North County Plan and approximately 700 acres in the southern area are in the Metro Lakeside-Jamul segment of the approved MSCP South County Subarea Plan. For both of these plans, the proposed project area is designated Pre-approved Mitigation Area (PAMA), with a very small amount designated Unincorporated Land in the Metro Lakeside-Jamul segment of the South County Subarea Plan. The MSCP proposes a permanent regional preserve system that will provide large blocks of habitat connected by corridors and linkages that allow the movement of wildlife throughout the region. The preserve system in the unincorporated County is designed to connect to preserve systems in other jurisdictions. The County’s preserve will be established within the PAMA, though not all of the PAMA will be preserved.
5. Removing 700 acres from the adopted South County Subarea Plan PAMA may require an amendment to the County’s existing South County Subarea Plan since the annexation would remove a large block of habitat from the County’s jurisdiction. Such an amendment would require concurrence from the USFWS and CDFW. The proposed annexation would also require modification of the draft North County Plan to accommodate the removal of 400 acres from the PAMA. The City of Escondido General Plan, Land Use Element contains the following Guiding Principle applicable to SPA #4: “Development and open space areas shall be coordinated with the San Dieguito River Valley Regional Open Space Park and appropriate regional open space planning efforts.” The County appreciates coordination on appropriate preserve design for this important habitat area.
6. The proposed project as presented in the March 12, 2014 letter to the City of Escondido would preserve about 54 percent of the property (600 acres of 1,100 acres). Since overall, the County’s approved Subarea Plan and draft North County Plan anticipate preservation of 75 percent of lands in the PAMA, the proposed preservation of 600 acres would not meet the MSCP’s anticipated conservation level. The biological studies should include a discussion of the applicable City of Escondido conservation requirements, how these requirements compare to MSCP conservation levels, and how the project will affect the overall preserve planning in this area.
7. Design of the preserved land is critical to providing high value, functioning habitat suitable for a MSCP preserve. The Safari Highlands Ranch project could improve preserve design by limiting the impact of development areas, keeping development areas as close together as possible and avoiding fragmenting habitat with roads and trails. The preserve design principles that should be considered and that are used by conservation biologists in preserve planning are as follows:
a. Conserve sensitive and covered species throughout the Plan Area: Species that are well-distributed across their native ranges are less susceptible to extinction than are species confined to small portions of their ranges.
b. Create larger preserves: Large blocks of habitat containing large populations of the target species are superior to small blocks of habitat containing small populations.
c. Keep preserve areas close: Blocks of habitat that are close to one another are better than blocks of habitat far apart.
d. Keep habitat contiguous: Habitat that occurs in less fragmented, contiguous blocks is preferable to habitat that is fragmented or isolated by urban lands. Contiguous habitat also minimizes deleterious edge effects of urban lands.
e. Link blocks of habitat: Interconnected blocks of habitat serve conservation purposes better than do isolated blocks of habitat. Corridors or linkages function better when the habitat within them resembles habitat that is preferred by target species.
f. Create diverse preserves: Blocks of habitat should contain a diverse representation of physical and environmental conditions.
g. Protect preserves from encroachment: Blocks of habitat that do not have road access or are otherwise inaccessible to human disturbance serve to better conserve species than do accessible habitat blocks.
h. Maintain natural processes: Preserves that are designed to maintain natural processes will sustain native biodiversity better than preserves in which such processes are disrupted.
8. The Safari Highlands Ranch property is known to have several sensitive species that are covered by the South County Subarea Plan and proposed to be covered by the North County Plan. Notable species are coastal cactus wren, coastal California gnatcatcher, mountain lion, coastal rosy boa, southern California rufous-crowned sparrow and San Diego horned lizard. Conservation will need to take these and other sensitive species found on the property into account in the preserve design. For example, trails should be sited with sensitivity to sensitive species habitat, particularly coastal cactus wren and coastal California gnatcatcher habitat.
9. If the proposed annexation moves forward, the County may request that the City of Escondido enter into an agreement with the County, USFWS and CDFW as part of the annexation process. The purpose of an agreement would be to ensure the annexation and ultimate development would not jeopardize the buildout of the regional preserve, MSCP covered species, compromise viable habitat linkages within the proposed regional preserve, and that development occurs in accordance with the Planning Goals of both the adopted umbrella MSCP Plan and the South County Subarea Plan, and the proposed North County Plan. Since the City does not have an approved subarea plan, Take Authorizations will be required from the USFWS and CDFW.
10. The project materials submitted indicate that an action to detach from CSA No. 113, San Pasqual Fire Protection District, would be required. Please note that CSA No. 113 was dissolved and the area is served by the County Fire Authority.
11. The Safari Highlands Ranch project would include a reorganization of fire services to detach from the San Diego County Fire Authority (SDCFA) and be served by the Escondido Fire Department. Although the County would no longer provide fire service in the event of annexation and detachment from the SDCFA, the following comments are provided in the interest of public safety and coordinated regional fire planning, particularly considering that the project is located in a designated “Wildland Urban Interface” area, a State Responsibility Area, and is ranked as a “Very High” Fire Severity Zone – the highest risk category.
12. The Safari Highlands Ranch Land Use Map shows a spine road through the development terminating at the north end of the project boundary with a gate and an emergency access road offsite that would lead to Lake Wohlford Road. In the interest of connectivity and to benefit residents of the development area and the region, the onsite road and northerly emergency access road should be publicly-maintained from Rockwood Road to Lake Wohlford Road.
13. The Land Use Map shows numerous pockets and peninsulas of open space throughout the development, which can be problematic for fire suppression personnel. To be in alignment with County General Plan Policy S-3.3, Minimize Flammable Vegetation, pockets and peninsulas of open space should be minimized.
14. The nearest Escondido fire station to the project is located at 421 N. Midway Dr. and is more than 5 minutes travel time from the furthest reaches of the project. Therefore, the project would not be in compliance with the County General Plan Safety Element travel time requirements. Although the project proposal includes a new fire station located at the southern portion of the project, it is uncertain how a project consisting of 550 single family dwellings could financially support the construction and ongoing operations and maintenance of a new fire station. Future project submittals should clarify how the fire station construction and ongoing maintenance would be supported.
PARKS AND RECREATION
15. The project information submitted indicates that the project would include a community park in the southern portion of the project site. If a 550 unit residential subdivision was proposed within the County’s jurisdiction, approximately 4.7 acres of developed land would be required to be dedicated for local public park purposes as a condition of subdivision approval. Additionally, the project approval would include a condition to establish a funding mechanism, such as a special tax district, to fully fund the on-going operation and maintenance of the public park. The County recommends that the project include an equivalent acreage of land dedicated for public park purposes and require adequate funding mechanisms. Future project submittals should provide details as to the acreage of public parks provided and funding mechanisms for ongoing operations and maintenance.
16. This Project has an opportunity to provide the residents of the new community and surrounding community with an interconnecting trail system with the future potential for regional connectivity. Opportunities for trails connectivity to the north include possible connections to trails in the Valley Center Trails Plan, the Hellhole Canyon Preserve to the northeast and Bottle Peak Preserve to northwest. To the south, there are opportunities for connections with the Coast to Crest Regional Trail, the Ramona Community Trails Plan and the Ramona Grasslands Preserve. The County appreciates integrating the maximum amount of connectivity with regional trails into the project’s trail plan.
17. In order for the proposed trails to successfully provide connectivity to adjoining regional trails the County recommends the following:
a. The project trails be open to the public,
b. The trails be granted to a public agency as trail easements,
c. The trails be designated non-motorized multi-use (hiking, horseback riding, mountain biking).
18. A more detailed description of the trails, ownership/responsibility for maintenance and a separate trails plan should be provided to ensure the best opportunity for future connectivity.
TRAFFIC AND TRANSPORTATION
19. Project access (not including emergency access) is from Rockwood Road. The following County roadways (TB: 1130-G3) will be directly impacted by 100% of the anticipated Safari Highlands Ranch trips:
a. Rockwood Road (Local Public Road)
b. Cloverdale Road (2.2E Light Collector)
c. Mountain View Drive (2.2E Light Collector) .
20. Rockwood Road, between Cloverdale Road and the County boundary (TG: 1130-H4), is a County maintained roadway. As part of the annexation process, the City of Escondido should consider assuming maintenance responsibility.
21. Both Cloverdale Road and Mountain View Drive are County Mobility Element (ME) Roadways. The proposed Safari Highlands Ranch development may need to consider improving the impacted roadway segments, and intersections, to their full public road standards/ultimate County ME classifications.
22. The parcels on which Safari Highlands Ranch is located were studied as part of the County’s Transportation Impact Fee (TIF) (http://www.sdcounty.ca.gov/dpw/land/tif.html) program; therefore, the project should pay TIF to mitigate cumulative impacts within the unincorporated county.
23. The Safari Highlands Ranch development (550 single family estate homes) will generate approximately 6,600 Average Daily Trips (ADT) and should conduct a Full Traffic Impact Study (TIS) following the County’s Guidelines for Determining Significance (http://www.sdcounty.ca .gov/pds/docs/Traffic Guidelines.pdf) for impacted roadway segments and intersections within the unincorporated County.
24. Two emergency access routes north and south of the project site are proposed. The proposed emergency access routes should consider the County’s Public Road Standards and be reviewed in coordination with the County Fire Authority.
25. The Safari Highlands Ranch project submittals indicate that the emergency access route to the north will provide future and neighboring residents an emergency access out of the Valley to the north. The County notes that the northern emergency access route could also serve as an emergency access route to the south for residents north of the project (i.e., Valley Center). This route could serve as another viable option in the Valley Center Evacuation Route Study (http ://www .sdcounty . ca .gov/pds/advance/Evacuation Final Study Valley Center.pdf) .
26. The forthcoming project submittals to the City should clarify the nature of any access easements in the area and provide detailed information as to any required realignments of the road and impacts to the properties and residents who live along this route. It is our understanding that Concordia Homes will work closely with the residents in this area regarding the project and the northerly access route.
The County appreciates the opportunity to participate in the review process for this project and looks forward to reviewing additional project details as they become available. If you have any questions regarding these comments, please contact Jennifer Domeier, Land Use Environmental Planner, at (858) 495-5204, or via email at jennifer .domeier@sdcounty .ca.gov.
TODD SNYDER, Chief
Advance Planning Division
Sachiko Kohatsu, Policy Advisor, Board of Supervisors, District 3 Dustin Steiner, Chief of Staff, Board of Supervisors, District 5 Megan Jones, Group Program Manager, LUEG
Michael Ott, Executive Officer, LAFCO
Dahvia Lynch, Chief, Department of Parks and Recreation
Richard Chin, Associate Transportation Specialist, Department of .Public Works Nick Ortiz, Land Development Project Manager, Planning & Development Services Julia Quinn, Environmental Planning Manager, Department of Public Works