YHB's letter:
Dear Mr. Crabtree,
In
response to the recirculated draft EIR for the Madrona Plan, I offer the following
comments on why the project should be rejected by the Brea City Council.
·
Carbon Canyon has a distinctiveness of place
that would be fundamentally and permanently altered by the siting of a very
large housing development in a key location that would transform its rural
nature and diminish already-disappearing open space. Madrona’s frequent use of “refined country”
to describe itself can only really be seen as an essential negative alteration
of the basic character of the Canyon and the continued incompatible
transplantation of suburban elements into it.
Developers have had far more than their share of space to build
housing. We lack sufficient landfill
space, water supply, roadways, and the funds to build new and maintain existing
infrastructure, and our pollution levels are still grossly excessive. This project would only contribute to the further
degradation of the Canyon and contribute to the mounting problems mentioned
above affecting Brea and every other part of our region.
·
Although the new owners have re-sited housing to
avoid one of four hazardous landslide zones, there are still enormous amounts
of grading and fill, and the attendant pollution exceeding air quality
standards, that would have to be used.
Any unavoidable significant and unmitigated adverse impacts that violate
CEQA should be reasons enough to deny the project. A statement of overriding consideration on
this can only provide an assumed benefit elsewhere in the city and not
adequately address this deficiency in the plan nor the question of continuing
to bypass air quality standards in a region with pollution levels that are still
far too high.
·
The analysis of traffic similarly inadequately
evaluates the fundamental problem of a two-lane winding road with almost no
lighting, poor sight lines and a documented history of dangerous driving and
serious accidents, much less the crowded conditions found during the several
hours of peak commuter volume during the weekdays. Moreover, the proposed entrance to the
project is at a location that has proven to be highly susceptible to
accident-prone behavior by drivers.
·
Despite modern advances in home construction and
fire planning, the 2008 fire in Carbon Canyon and surrounding areas
demonstrated once again that it is an unacceptable and dangerous level of risk
building houses in wildfire-susceptible wildland areas. The “shelter in place” philosophy, which
predominated several years ago, would simply be playing the odds in a fashion
that would be intolerable in an area as remote and relatively inaccessible as
this. With climate change causing
extremes in weather conditions, the frequency and intensity of fires, already
noticeable with recent major events, will continue to exacerbate. Finally, the existing fire history of the
Canyon, also well documented in print and visual media, will be rewritten in
ways that make this project simply inconceivable given the new realities.
·
To reiterate, these last two points come to a
basic question of public safety and liability issues. The City of Brea would be assuming an unacceptable
risk, especially in the matter of fire response and protection.
·
It is also to be noted that, as a project that
has a grandfather clause with respect to current code and planning standards,
Madrona could never be approved if it were brought as a new project to the
Council now. Yet, for all intents and
purposes, this is a new project with a new owner, new name, and new, that is,
amended, plan. Consequently, it clearly
fails to meet the basic standards of 2013, if not 1993 or 2003.
·
Finally, to address any concern about private
property rights, there are two points to raise:
o The
first is that this is not an individual property owner or an owner that has a
vested or expressed interest in working with and improving the quality of the
community. This is a bankrupt
out-of-state corporation, whose unethical failings have been well documented,
seeking to recover whatever asset valuations it can for the purposes of satisfying
creditors. In other words, this is a
corporate investment, not a matter of a dedicated project for the betterment of
Brea.
o Secondly,
private property rights, essential as they are, cannot and should not supersede
the common welfare of the community in Brea.
This project would not only fail to provide enough benefit, in the form
of overriding considerations elsewhere in the city, to Brea, but would put
future residents of Madrona and nearby neighborhoods at risk, as noted above
with respect to public safety and other considerations.
In 2008, the Planning Commission narrowly approved an
earlier iteration of this project, before the devastation of the fire that fall
that utterly consumed this area. That
conflagration and the other issues noted here and elsewhere should be enough
reason to deny this project now and at any time in the future. The site is too vulnerable and susceptible to
fundamental public safety hazards, belies the nature of Carbon Canyon, and has
several unacceptable significant adverse impacts in its EIR that cannot simply
be satisfied by statements of overriding considerations. Finally, as a corporate investment by a firm,
which employed unethical tactics in its operations that led it to bankruptcy
and receivership, traditional notions of private property rights do not
apply. Approval of this project would
only benefit the distressed firm and its creditors and do nothing to improve the
quality of life for the City of Brea and its residents.
For these reasons, the City Council should reject
this application and keep Brea’s portion of Carbon Canyon protected from any such
project that purports to improve it.
Instead, Madrona offers far too many risks than benefits.
Many of us have turned in our comments in great hope that Brea's City Council will see the light and reject Madrona as a failed proposal. Your comments encourage us to stand together as a community for the benefit of the canyon and its residents.
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