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Letter to Mayor and City Council - May 1, 2006May 1, 2006 The Honorable Ernie Villegas
Dear Mayor Villegas, The Citizens for Responsible Growth would like to comment on the North Fillmore Specific Plan EIR. The Citizens for Responsible Growth are a group of concerned citizens who are proud of Fillmore. The number of residents who have organized is growing quickly. We have found that most citizens have been unaware of the project itself as well as the scope of the project. We appreciate the opportunity to comment on the North Fillmore Specific Plan. We look forward to hearing from the City in response to these questions and comments before any action is taken. We are concerned that the only involvement in workshops was with North Fillmore residents. This development will affect all Fillmore residents and public participation from all Fillmore residents should be encouraged. Many residents have not been aware of the nature and scope of the project until now. Outreach should be made to citizen groups such as Citizens for Responsible Growth, CUFF, homeowners associations, churches and other resident groups to make citizens aware of a development that will have such significant impacts on their environment and quality of life. Copies of the North Fillmore Specific Plan, Appendices, General Plan, Housing Updates and all Redevelopment documents should be made available to individuals and organizations without charge. The fee now being requested is excessive and will only deter public input on your document. Some of the documents are currently available on the city’s website. If more information is made available on the website, it will help save the City’s resources as well as meet one of the City’s objectives to communicate more information to citizens. We are not opposed to growth in Fillmore. However, we are opposed to growth that is not consistent with the character of Fillmore or growth that will cause our quality of life to decline. We believe in Vision 2020 and the original General Plan before it was updated in 2003. We seek to protect Fillmore and believe that with sensible, slow and controlled growth we can even improve our quality of life in Fillmore. Many of our group will be adversely impacted by this plan. As declared in the NOP for North Fillmore Specific Plan, the proposed projects will have significant impacts on the following elements;
Although some of the issue areas will be successfully mitigated as stated in the EIR, we believe that the following issue areas will not be successfully or effectively mitigated in a manner consistent with the Vision 2020 plan of Fillmore or be beneficial to the citizens of Fillmore.
These items have not been fully assessed or mitigated in the EIR. In addition, we have concerns regarding;
Mitigations proposed should go beyond the barest minimum of compliance. We ask that you revise the North Fillmore Specific Plan and re-open the workshops so that more citizen participation can be included, including the Citizens for Responsible Growth. The City of Agricultural Resources and Aesthetics Aesthetically, the EIR states that adding homes to the area will improve the aesthetics of the land. While, we agree that the architecture and design has been well and thoughtfully done, it is not appropriate for the area and will not be better aesthetically. Many residents living in the area presently have an open space view to the north and west. Their view will be blocked by the structures that will be built. This will result in aesthetically offensive views. The location and geography of the location prohibit adding this much housing to the area. There is only access and egress from the south. The fact that residents cannot go east, west or north will create a dangerous and chaotic escape route. We live in an area of historical occurrences and future probabilities of fire, earthquake, flooding and landslides. The density appears unreasonable considering that Heritage Valley Parks has 750 homes on 300 acres and North Fillmore Specific Plan will have 894 homes on 102 acres. The SunCal project will be even more dense with 201 homes on 30 acres. There is no provision for community gardens which are an element of “smart growth” principles. All of the true open space of North Fillmore will be consumed by this project. Tiny little patches of grass do not compensate or qualify as open space. When the General Plan was updated, the
city of Fillmore has now become the poster child for sprawl – and due to geography and the fact that 126 highway runs through our town carrying at minimum 31,000 vehicles per day, it is also the poster child for traffic congestion. The updated General Plan was revised to double the area of the city with the intention of cramming as many people and houses as possible into a geographically constrained area, surrounded by two rivers and a range of mountains. There will remain no orchards, no small farms, no ranches and no open space within the entire city limits. A study released by the Ventura County Civic Alliance in 2004 found that Fillmore will have exhausted the land available for development by 2008. Does our future not extend beyond 2008? Should we not conserve some land for the future beyond 2008? Housing The number of people per household has changed from the draft EIR and we would like to know the source of the new data. The Draft EIR used a 3.6 official census count of people per household. The Final EIR is using a 3.2 figure to calculate the number of people per household. The City is using a 3.72 ratio in its 2006 Amendment to the Redevelopment Plan Does this count include the “granny flats”? Knowing the history of Fillmore and the housing characteristics, it is not unreasonable to expect an entire family or a group of 3 or more people living in a granny flat. This will expand our population too quickly and too much. The projected increase in population should reflect the effect of the granny flats. Air Quality The EIR does not fully consider the air
quality impacts. A project of this size will have a
deteriorating effect on air quality in the region, which is
located in a locality which does not meet Federal and State
air quality standards. The pending expansion of The proposed mitigation for air quality which currently does not meet state and federal threshold levels is not sufficient to prevent health hazards to residents in the area. Please explain how the effects of ozone, carbon monoxide, diesel fumes, gasoline powered equipment fumes and construction odors will have upon those with respiratory problems, or the aged living nearby. We are also concerned about the data used to analyze air quality. Data is gathered at the Piru monitoring station. The Piru monitoring station is not near a congested intersection and also doesn’t include the traffic from State Route 23 in the analysis. This is a significant addition to air pollution that needs to be taken into consideration. Traffic The fact that you are hearing concerns about traffic repeated over and over should indicate the severity of current traffic congestion and how legitimately frustrated citizens are with the possibility of worse traffic congestion. It is also a traffic issue that the
traffic studies included in the EIR do not reflect the actual
counts from State Route 23. The most recent Caltrans data
records show a higher count. The EIR counted the traffic
leaving the development area but did not take into account the
background traffic on the return trip of those driving south
on State Route 23. The traffic study only calculated 5% of
development traffic for State Route 23. This does not seem
reasonable since possibly as many workers commute south on
State Route 23 as commute west to Random timing of the signalized intersection at 126/23 has shown an over 200 second waiting period for getting through the intersection. This puts the intersection LOS at an F. No development is allowed if an intersection is currently at an E or F LOS. And, traffic congestion at intersections greatly increases hazardous air emissions. The future expansion of Oxy Petroleum as they re-open and produce the Sespe Oil Field will create additional traffic as well as the transport of hazardous materials. The minimum mitigation fees that will be paid to the County Transportation Fund will not effectively reduce air pollution in Fillmore and should not have been reduced to insignificance. The health of Fillmore citizens is important. Fillmore is also the most “housing
rich” city in The actual design elements and architecture of the SunCal plan are well done and attractive. We approve of the pedestrian oriented development. However, any benefit gained from the well designed “walkability” of the plan conflicts with the fact that the community will be commuting to another city to work. Smart Growth principles would consider the distance to highway 126 infeasible and will cancel out the benefits of walkability. North Fillmore is somewhat isolated from the rest of the city and if there is no commercial or retail development for several years it is even more impractical. This will create a hardship on those moving to Fillmore as the price of oil and gas will continue to increase as indicated in the SAIC Hirsch Report1. A Ventura Council of Governments (VCOG) study on Vehicle Miles Traveled (VMT) states that…”Reducing the number of vehicle trips is the most significant way of conserving energy and lowering air emissions because large amounts of pollutants are emitted each time a cold engine is started and when the vehicle is turned off. Home to work trips comprise 20% to 30% of all personal vehicle trips, and they are especially significant because they tend to be longer trips, and they also occur during peak times of traffic congestion.” Note that the VCOG study uses 20 to 30% of all personal vehicle trips for home to work trips. The North Fillmore Specific Plan traffic study only used a 15% rate to calculate trip generation. Since this data is incorrect, we contend that the traffic levels of service as well as the air quality issues and noise are in excess of the EIR. Noise A substantial amount of noise will be generated by the proposed project both during construction and after occupants start driving to work. The movement of heavy vehicles, trucks, compressors and construction equipment will create severe noise problems. Requiring residents to use air conditioners and keep doors and windows closed is not a reasonable solution and will not reduce noise levels to insignificance. Schools The mitigation measures suggested for schools are not feasible. The Fillmore school system is already exceeding capacity. Without proper school mitigation the future impacts of the city will be devastating.
The
http://www.vcss.k12.ca.us/Portals/VcssoPortals/Main/publications/FOE-022006.pdf Financial There is also an issue of the staggering
debt that the city may be taking on to finance infrastructure.
The repayment of the debt is based on a hoped for 3% increase
in property values. Although real estate price increases in Although some of the intentions of the Redevelopment Agency are for the benefit of the city and its citizens, there is a disadvantage in that using tax increments for financing the infrastructure of this project will divert funds from the local school district and county resources. Public Services The final EIR should fully address the impact on public services. This project will generate additional demands that the existing police and fire systems cannot handle. The North Fillmore Specific Plan doesn’t really address an effective mitigation for the drain on local public services. The funding mechanism suggests tax increments that will not show a positive amount for 6-8 years. How will this gap be filled? Currently there is no staff on nights or weekends at the police department. What is the current crime rate in the North Fillmore area? The parks are deficient. This plan has such a limited amount of park space. Using several tiny little spaces and calling them parks is laughable. And, the amount of money being paid for these spaces and development is an unreasonable cost to taxpayers. We are also questioning the valuation of land acquired with public funds for parks. The $700,000 per acre acquisition costs and $185,000 per acre for development costs appear to be excessive and not in line with current prices for vacant land or current prices for park development. Conclusion So, in conclusion, we believe that the only viable and feasible alternative to the North Fillmore Specific Plan is Alternative #1, do nothing until a complete review and revision can be made, with input from Citizens for Responsible Growth, CUFF and any other residents who are willing to participate. Sincerely, Citizens for Responsible Growth Planning Commission Commissioner Mark Austin (Chair) Commissioner Douglas Tucker Commissioner Vance Johnson Commissioner Diane McCall Commissioner Wallace Schaefle Mayor Ernie Villegas Council Member Steve Conaway Shirley Micarelli
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| 2006 - Gayle Washburn for City Council -
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