Here is the transcript of the radio news report by KCDZ 107.7 about the January 30 meeting between Alta Mira developer representatives and local Joshua Tree residents.
Here is MBCA's detailed Comment Letter on Alta Mira .
You may reach San Bernardino County Senior Planner Chris Warrick about this issue at [email protected]
or mail printed comments to:
Chris Warrick, Senior Planner
County of San Bernardino
Land Use Services Department - Planning Division
385 North Arrowhead Avenue, First Floor
San Bernardino, CA 92415-0182
Originally proposed more than 8 years ago, this 105 acre, 248-home gated community housing project plan has undergone revisions. What follows is MBCA's detailed review of various aspects of concern. Links to supportive websites and documents are provided throughout this page.
A video of the 2009 MAC meeting where the project was discussed is available at http://www.youtube.com/watch?v=cX2h4GhEbGA. The discussions and comments are spirited, informed, and remain relevant. Terra Nova was also at that meeting to present the project and answer questions.
Note 1: All page references in the Commentary below refer to the project’s Initial Study, hereafter referred to as IS, and available here. This describes the entire project. You may also want to read the brief document that states the proponent's intent to adopt a Mitigated Negative Declaration, indicating their belief that all environmental factors in the Initial Study have "less than significant impact." Here is the link to this so-called Notice of Availability, also referenced in the commentary as the MND.
Note 2: The word ‘gated’ no longer appears in the description although in the Tentative Tract Map illustration it appears surrounded by a wall. There is a 6-foot high concrete block wall at the perimeter of the project adjacent to the school. The wall shall be constructed of decorative material consistent with the other walls throughout the project. Mitigation XII-2, page 59.
In order for the community to fully review the project, MBCA requested that the County Planning Department upload the Project Specific documents on the county website. This was not deemed possible, but we were provided all of the documents on a CD. Although some documents were too large to upload to our website, we have provided summary and essential information from those large documents.
The 30 day comment period opened on August 13, 2014 and closes on Friday September 12, 2014. At the end of the 30 day comment period the project can proceed with no additional documentation or public input to the Planning Commission for approval.
Based on the public controversy that has followed this project from the beginning MBCA feels that the IS/MND does not serve the public’s need for a complete environmental review and that an EIR is necessary under CEQA.
Selected Issues of Environmental Concern:
Transportation/Traffic - IS, page 47
Our abridged version of the Revised Traffic Impact Analysis is available here.
The Alta Loma project wraps around two sides of the school and will have an entrance/exit on to both Sunny Vista and Alta Loma. Parents and neighboring homes experience daily traffic jams during Friendly Hills Elementary School drop off and pick up times. The intersection of Sunny Vista and Alta Loma is a magnet for traffic and the sidewalks a danger zone for pedestrians.
The traffic analysis does not include Friendly Hills Elementary School in the project description nor is it located on the maps. For examples see Figure 1 - Project Location Map; Figure 10 - Project Average Daily traffic Volumes; or Figure 11 - Project Morning Peak Hour Intersection Turning Movement Volumes. (Check traffic volumes on Figures 10 and 11.) Using Adobe Search there were no hits for ‘Friendly Hills Elementary School’, ‘Elementary School’, or ‘School’. The daily trips by parents to drop off and pick up their children at Friendly Hills Elementary School are not included in the traffic analysis. There is no explanation for this. If the project is built a dangerous situation will only become more dangerous. This analysis is flawed at its core and is not usable for this project.
Public Services/Fire Protection - IS, page 43
Joshua Tree NP to the south of the development is not mentioned in the IS. However, the foothills of Quail Mountain that reach out from the park into the community are identified by Cal Fire as a State Responsibility Area. Wildland lightening strike fires moving out of the park are not unknown. In the event of a fire what is the plan for staging fire firefighting equipment and the emergency evacuation of residents from the surrounding neighborhoods, the 248 houses in Alta Mira project, and the school?. Comments from the Fire Department are needed?
Here is a map that shows the CalFire State Responsibility Area around the proposed development. The white square with the black dot on the north boundary of the yellow SRA is Friendly Hills Elementary School.
Another fire-related map shows fire history in Joshua Tree National Park. A number of major fires have occurred only a few miles south of the proposed development.
Utilities and Service Systems
Joshua Basin water district has indicated that it is able and willing to serve the proposed project. IS, XVII d page 51
This is no longer true, the will serve notification has expired and our entire state is in severe drought with mandatory conservation measures in place. The Alta Mira project is not included in the 2010 JBWD Urban Water Management Plan. JBWD has not yet been approached so has yet to determine its ability to serve this new community during construction or at buildout.
Hydrology and Water Quality - IS, page 33
Estimates are that the project will use 45,000 gallons of water a day for potable consumption based on a usage factor of 69.3 gallons per person per day. This is the average consumption for indoor usage and does not address outdoor landscaping, which, even with desert adapted plants, is more consumptive that indoor usage. The calculations for water usage at buildout are in error. Figures used for calculations must be supplied by JBWD.
For Water Use During Construction, reference the following:
Air Quality Mitigation - IS, III-1 AQ-Dust Control Plan page 17
-Exposed soil must be kept wet during grading – water at least 2 times a day
-Any portion of the site to be graded shall be pre-watered to a depth of three feet prior to the onset of grading activities.
-(and 10 additional requirements that use water.)
The 248 lots of 10,000 square foot and larger could have impacts on the water supply. A detailed approved plan should be in place before construction begins. The plan should include the county updated Model Water Efficient Landscape Ordinance, Landscaping Standards, and Plant Protection and Maintenance. Details are important; for instance, where will the approximately 1000 Joshua Trees and possibly twice as many Mojave Yucca be stored and cared for before replanting and who monitors the ‘nursery’ and plan compliance?
Biological resources - IS, page 19
Desert Tortoise and Wildlife Linkage
The project is located within an area where residents have seen the threatened Desert Tortoise. The results of studies by Circle Mountain Biological Consultants for the Mojave Desert Land Trust (MDLT) and others have identified tortoise sign in 21 surveys on numerous sites in areas surrounding the proposed development. Map here.
Timing of tortoise survey
The tortoise update survey was conducted on Dec. 6, 2013 when tortoise are underground for the winter. This survey needs to be updated during the desert tortoises’ most active periods -- April through May or September through October if there have been winter storms.
Surrounding Conservation Lands
Since the Alta Mira project was introduced in 2006 the MDLT has made a considerable investment in land to preserve the linkage corridors between Joshua Tree National Park and the Marine Base. To date they have acquired Sec. 33 – 640; Sec.9 - 530 acres; Quail Mtn. Project - 955 acres; Nolina Peak - 639 acres (conveyed to JTNP) as part of their Wildlife Linkage Campaign. Map here.
Terra Nova (consultant) General Biological Reports: 2007, 2010 and 2013
The IS does not identify impacts to the scenic vistas, resources, or visual character of the area. The IS does not reference the Joshua Tree Community Plan 2007 nor does it reference the Morongo Basin Conservation Priorities Report 2012 and the mapping program which analyzes conservation values at the parcel level.
Here is a report about historical and archaeological studies.