Stonefield Housing Development Draft Environmental Impact Report

The Draft Environmental Impact Report for the proposed Stonefield housing project, consisting of a gated 28-home, executive development of 4-5,000 square foot homes on 10-20,000 square foot lots analyzes a standard set of criteria, including water, traffic, climate change, biological resources, air quality, aesthetics, conformity to the general plan, and others. Anyone who has examined these documents knows they are lengthy, written in often very technical language (EIR-speak) and can be confusing with terminology.

After a while, though, you tend to know where to look for key information relative to impacts as defined by the California Environmental Quality Act (CEQA) and mitigation to reduce or offset those impacts. You also are looking for those mitigation strategies that would lead a government entity to issue the "Statement of Overriding Considerations" (SOC), a gaping loophole in CEQA that provides a rationale for a government to approve a project, even if the impacts are determined to be signficant, adverse, and unavoidable.

I'm going to focus my remarks on four key issues: two of which were identified as having significant impacts and two which were not. To start with the latter, water supply was not seen as a significant impact because the future prediction of water supply is speculative. Meaning: we don't know for certain that rainfall and snow pack levels leading to reservoir levels will be low. Therefore, in essence, this line of argument is that we shouldn't really take water supply into account at all, unless, I imagine, we are in a severe drought with mandatory water rationing. The problem with this argument seems simple: any future predicting is speculative. Chino Hills' sales tax and property tax revenue is speculative; knowing the enrollment of children in our local schools (which has a direct bearing on government funds) is speculative; traffic counts which could dictate law enforcement and maintenance strategies is speculative; almost anything related to planning for the future is, indeed, speculative. Given that climatologists routinely argue that we are in a prolonged drought cycle, knowing that dry years have greatly outnumbered average or above average years, understanding that reservoir levels are generally well below capacity, and seeing that we are now in a voluntary conservation mode, with mandatory rationing a very strong likelihood for next year if we don't get a significant amount of rain and snow: why can't a moratorium be put into place until such time as reservoir and supply levels are back to an acceptable level? Let's not forget how big these homes and lots are (double most homes in the city.) What are some of the mitigation measures proposed to reduce water use? Drought-tolerant plants, CC & R mandates for pool and spa covers, Energy Star appliances and the like. The question is: is this enough for homes and lots this big, given where we are at with our water issues?

OK, now for traffic. This is determined to not be significant because of the small number of houses, cars, and estimated daily car trips (268/day) being insignificant as to the overall level of traffic on Carbon Canyon Road. A letter-grade system is assigned to roadways and criteria established for these. So, for example, a "D" is considered a high level of traffic, with heavy congestion and delays. Yet, this rating is acceptable. The question is: is it desirable? Also, let's not forget, although it's easy to when looking at an EIR because it examines a project entirely in isolation rather than taking in context, that there are three other canyon housing projects in the pipeline (ranging from on the cusp of approval to in process) and the total of number of homes there exceeds 300. That means almost 3,000 car trips per day on a road that is already rated "F", the lowest rating, at rush hour periods. The EIR traffic study here shows that most ratings fall within "D", with "E" and "F" ratings pretty common, depending on what intersection the readings are at. Despite the fact that there is no signficance identified, the EIR goes ahead and recommends mitigation: namely, traffic lights at the intersection of Carbon Canyon Road and Canon Lane and Canyon Hills Road, further west of the project. A light at Fairway is not feasible because of road curvature and sight lines. Yet, are traffic signals true mitigation. Does the presence of these actually improve flow, reduce congestion, and make the commute easier? The answer is a resounding NO! What it does is to allow drivers on Canon Lane and Canyon Hills Drive the ability to negotiate turns onto Carbon Canyon Road (I understand why that would be good for the relative few who would benefit, because I have to do the same thing, but wouldn't have the benefit of a light!) Just look at Grand Avenue and Peyton Drive, where the Shoppes development has just been completed. Several new sets of lights have been added, but they don't assist in getting drivers through more quickly, NOR are they designed to do so. They do slow drivers down and increase the time to get through the area, but that's because they're needed there. To go back, however. If Stonefield does not have significant traffic impacts, then why are mitigation strategies recommended, especially ones that do not mitigate, but exacerbate, the problem? The truth is: any additional traffic, no matter how small it might seem in isolation, is an unnecessary and unacceptable burden on an already over impacted Carbon Canyon Road, a road not designed or built for its level of traffic. Period.



Now, to air quality. Simply put, there is a relative short-term (3 months, 6 months?) period of heavy grading, but a process which will create nitrous oxide and particulate matter pollution exceeding the already-low standards established by the Air Quality Management District (AQMD) and the Air Quality Index (AQI). In this area, the suspended particulate matter of 10 microns in diameter or more level is already 2x the state standard and ozone levels are also double the federal guidelines (which, again, are lax as they stand now). The levels of pollution generated by the Stonefield project will surpass these low standard by 40% on nitrous oxide and by 70-75% on one level of particulate matter (the other, a 2.5 microns or less diameter level, is a small amount over the threshold.) For 24-hour particulate matter, which would dissipate within one day, the threshold for effects within 73 and 50 meters (why are they using metrics when almost no one else does?) are quite severe, even if temporary. As to mitigation: there are several offeerings: having diesel oxidation catalysts on vehicles to reduce pollution by 15% (except that the project will exceed low standards by 40%); proper maintenance of vehicles subject to AQMD inspection (provided these inspections will actually take place regularly during the grading process); turning vehicles off when not in use; using electrical rather than diesel hookups for power tools (which should already be standard practice!); and the kicker: a traffic control plan for safe detour. On this last one, two simple words: TO WHERE! How can you possible have a safe detour for massive grading vehicles in Carbon Canyon? By the way, imagine the traffic impacts of these huge babies when they're hauling dirt to and from this project. The long and short of is this: these mitigations, poor as they are in most cases, will only be able to reduce pollution by 15%, when the project is 40% over our low standards. ERGO, this criteria cannot truly be mitigated. If it cannot be mitigated, it cannot be approved (theoretically).



That takes us to the last issue: aesthetics. There are several criteria: scenic vista, scenic resources along a state scenic highway, existing visual character, overall impact. Bascially, the project would completely fill in a natural landform within the canyon and then build the homes atop this manufactured area, to a point where some lots are actually slightly higher than the roadbed for Carbon Canyon Road. Consequently, there would be changes in landform, views and the scenic quality of the canyon permanently. Here is how it is expressed in the EIR: the project results in "permanently altering the scenic character" of the canyon. What is proposed is to "soften" the appearance via trees and hardscape (walls with nice rock facades, etc.) to make the place have a "pleasing appearance." Talk about speculative! When the project refers to open space, this includes manfactured slopes, access points, and streets (the latter two amounting to 5.68 acres or 20% of the open space!) The manufactured slopes would be highly visible in grading and then "landscaping would help blend the proposed houses into the natural surroundings." Actually, the correct way to put this should be: "the natural landscape will be obscured and compromised by artifical landscaping and the visibility of homes and hardscape." Incidentally, it is noted that, in 2004, CalTrans denied a Chino Hills request for a scenic highway designation. The reason: the canyon's natural scenery has already been compromised. Obviously, building this project right next to the road will doom that potential designation forever. The salient point with aesthetics is simply and bluntly expressed in the EIR, because it has to be: THERE IS NO MITIGATION AVAILABLE FOR ANY OF THE CRITERIA DEEMED SIGNIFICANT. So, what this means is that there is no way to alter the sigificant, unavoidable, adverse impacts of this project when it comes to the aesthetic character of the canyon.

WHICH IS WHY WE LIVE IN THE CANYON. We live here because we appreciate its rustic beauty, greenery (most of the year!), open space (what's left of it), changing landform, and many other qualities. If you have a project that openly admits that it cannot mitigate a significant affect of a quality that is essential to the canyon's existence, how in earth can this proect be approved. Well . . . let's see what the city does with this when it comes to the possibility (probability, certainty) of a "Statement of Overriding Considerations." I'd like to believe this is a straight-forward issue: two impacts are either not at all or not fully mitigatable (is that a word?). Therefore, the project should be rejected. Thanks, however, to the black hole-sized loophole that is the SOC, don't be at all surprised if the city comes up with a reason to approve.

That's where the concerned citizen comes in. Next Thursday, 30 October is the deadline for public comment. Send them to Betty Donavanik at bdonavanik@chinohills.org. Attend the Planning Commission meeting, tentatively scheduled for 16 December. Make your voice heard, if you care about the canyon.