14 October 2015

Hidden Oaks Environmental Impact Report Notice Commentary

The Hidden Oaks housing development site in Carbon Canyon, proposed for 107 luxury custom home lots.
Here is a submitted comment of a local resident to the City of Chino Hills concerning the Notice of Preparation for the Environmental Impact Report with the Hidden Oaks project, proposing 107 custom lots in Carbon Canyon, south of Carbon Canyon Road at Canyon Hills Road:

           The first concern has to do with the city staff’s request for clustering, ostensibly intended to protect more ridgelines and natural features within the project site.  Unfortunately, while clustering may work very well in certain types of developments and environments, it is entirely another matter with Hidden Oaks.  A review of the maps presented at last month’s scoping meeting indicate that the clusters actually serve to divide up “open space” (put in brackets because it is unclear how much natural vs. manufactured open space there will actually be] that limits the effectiveness of the clustering arrangement.  This is particularly so in regards to animal movement as well as general aesthetics for the Carbon Canyon area, such as visibility from nearby areas including Chino Hills State Park and the clustering of high concentrations of artificial ambient light.
Clustering, in this project, also serves to further complicate emergency evacuations in case of fire, which is a serious risk to this property, having been burned several times in recent decades, most notably in November 2008. This is especially so considering the one main route in and out of the proposed development and what appears to be a significantly under-considered emergency access road out through the Vellano community, given existing local fire department standards for such roads.  The alternative emergency access road not only would, along with an unneeded public park added as a sweetener to the project, decimate an excellent mature oak grove, but would only be a few hundred yards west of the main entrance and deposit fleeing residents onto a congested Carbon Canyon Road.
Finally, in order to accommodate the desires of the developer (rather than the concerns of the community in which the project is located), the city, which has no legal obligation to do so, proposes a zoning change for clustering.  Chino Hills citizens in 1999 passed Measure U precisely in response to excessive zoning changes granted by accommodating city councils to developers to the detriment of local and broader communities and, especially, to the sensitivities of places such as Carbon Canyon, which has unique characteristics.  This property should be developed under existing zoning, which were developed for entirely valid reasons and which are far better for the site in terms of aesthetics, emergency evacuation, animal movement and other aspects. 
                Secondly, the fire risk is greatly increased by the siting of houses along ridge tops and hillsides leading to ridges.  Ridge tops and other higher elevation areas are not only exposed to stronger wind gusts, but the canyons and gullies that lead to them are natural funnels for fire.  Even with so-called “fuel modification zones,” walls of flame that can reach several dozen feet or more in heights and, importantly, embers that can travel up to a mile, can breach these sites.  Anyone conducting EIRs in areas like this, that are actually, on the Orange County/Brea portion of the canyon, signed by CalTrans as a “Hazardous Fire Area”, should carefully watch and review Living With Fire, a 22-minute film released in June 2013 by the United States Geological Survey through its Southern California Wildfire Risk Project.  This film can be downloaded online at: http://gallery.usgs.gov/videos/620.  As increasingly larger portions of our state burn from year-to-year, it is imperative that abundant caution be utilized by local governments when considering housing projects in wildland or wildland-adjacent areas.
                With regards to air quality, while it is obvious that any large-scale housing development project will generate particles that exceed CEQA mitigation standards, there is always the fallback of using a Statement of Overriding Consideration (SOC).  The question for the city becomes: what form of mitigation through an SOC will actually have any meaning for the canyon, as opposed to what might be done more broadly within the city?  It is also relevant here to note that there are new climate change statutes that should be considered with respect to how housing projects are planned with regard to this and other issues, preeminently water, as well as traffic with respect to emissions.
                Concerning traffic, here is another mitigation problem.  The city would undoubtedly invoke another SOC on this point, but if the thought is that a traffic signal at the project entrance at Carbon Canyon Road and Canyon Hills Road constitutes a meaningful mitigation, the city would do well to reconsider that assumption.  All a signal will do is slow down the vast majority of commuters on Carbon Canyon Road to allow Hidden Oaks residents to turn on to what has become in the last two years, a notably more congested state highway.  It should be further noted that more idling traffic means worse air quality for people, animals and plant life within Carbon Canyon. 
                Finally, there is water.  Obviously, California is in a drought of historic proportions and mandated cuts by the state and local water agencies are in effect.  Yet, as news outlets are increasingly reporting, the grossest users of water are those who live in larger homes on bigger lots in exclusive communities.  This is precisely the type of development embodied by Hidden Oaks.   Hopefully, the EIR will take into account the fact that one of greatest environmental impacts of any development project during this era of unprecedented water scarcity is the amount of water to be consumed by luxury homes on large lots. 
                Hidden Oaks is exactly the kind of project that should be avoided in this and many other contexts.

Another shot of the Hidden Oaks site, taken in early September.

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