Loading...
HomeMy WebLinkAboutAgenda Bill 1.A-Late13 04/25/2011s. Petaluma Ne ibor��ood Association 40`Fourth Street- Petaluma, CA 94952 Community Development Department Attn: Heather 'Hines; Project Planner City of Peialtima I l English Street Petaluma CA 94952. April 14th, 2011 Re: Draft EIR "Deer Creek Village" Project The following comments are in response to the open public comment period for the Draft Environmental. Impact Report for the "Deer Creek Village." Project on N. McDowell. Blvd (will be referred to in the comments below as "the Project "). The subsequent attached comments should be included in the administrative record for the DEIR and the Project. General Plan Compatibility As a neighborhood organization we concur with the primary directive of Petaluma's General Plan (GP) which stipulates, "maintain a close -knit, neighborly, family friendly city. " We believe that neighborhoods are the City's greatest assets and, the quality of living in Petaluma's neighborhoods should not be undermined for any reason. The City's General Plan clearly states, ast a number one Guiding Principle, "activities and facilities used on a frequent basis, such as stores and parks, should be easily accessible to residents ". and that, "land uses are designated to ensure- balanced neighborhood development with a mix of uses ". The importance of maintaining and cultivating a healthy community through the use of responsible planning methods is enumerated throughout our city's General Plan. We strongly feel that in order for Petaluma to. move forward with growth and development in .a socially and fiscally responsible manner, we must require large scale projects, such as Deer Creek Village, to stringently comply with the policies and programs of our General Plan. We encourage city council, city planners and staff to recognize the importance of "General - Plan Compatibility", requirements in the context of CEQA's rules and regulations. If city staff finds it necessary to facilitate amendments to the IZO in order to achieve GP compatibility, we request that the, city 's lead agency do so. We request that the city's planning staff recommend to the project proponents,, that the project be redesigned into an efficient mixed -use (residential /retail) project that incorporates Smart Growth (walkable, transit oriented, bicycle - friendly) principles. The following comments attempt to point out the disparities between what our General Plan envisions and. that which -has been proposed by Merlone Geier Partners at the N. McDowell Boulevard project site. Our intentions are to see a project built at the site, that better integrates into the community. Thereby, enhancing the existing adjacent neighborhoods on the East side and the communi`tyas a whole with the very least amount of impacts. General flan Compatibility Section l of_Petaluma's General Plan, entitled Land Use, Growth Management_& The Built Environment describes Mixed.Use in the following manner, This classification requires a robust combination Hof uses, including retail, residential; service commercial, and /or offices. Development is oriented toward the pedestrian. By °not including residential, the Project.as it is presently proposed falls shoft of the General Plan's requirements to incorporate a combination of uses in a layout that is residential.and.pedestrian oriented. Section 2 of the General Plan, Community Design,..Character, and Green.Building, provides a more; detailed description of the intent of the Mixed Use classification and also identifies areas of the city specifically intended for mixed use development. General Plan Goal 2 -G -14, North McDowell Boulevard states,; Allow.for a range of uses including commercial, office and residential, in the mixed -use area on the southwest corner of North McDowell and Rainier Avenue. It is abundantly clear by this description, that the community wanted to see Mixed Use development at the Project: site. Yet. the Project's DEIR does:.not,adequately address what was consider to be. the General 'Plan's primary location for Mixed. Use. It does not adequately analyze the feasibility and inherent benefits of a superior Mixed Usealternative thavis more consistent with contemporary thinking,of sustainability (amore walkable,, livable community that lessens vehicular travel) over, the existing proposal, which is essentially a auto - centric single -use shopping center. The. underlying principal of General Plan Goal 2 -G -14 North McDowell Boulevard also: states Recognize the complex demands upon the Boulevard and enhance the function and aesthetic value it could provide to the community. The Project's DEIR does not address the irrefutable impacts of a commercial retail projcctofihis type the- aesthetics of the McDowell Boulevard corridor. A project of this scope and nature will undoubtably have negative impacts on the Boulevard and the adjacent sites in terms of traffic mitigation devices, retail signage, light and glare, blank windowless walls and paved asphalt. Because the DEIR does not adequately analyze the potential unavoidable aesthetic impacts, it also does'not provide discussion for possible mitigation, of such impacts. General' Plari policy 2 -P -92 states, extending Lynch Creek: Way northwest through.new developments, thereby promoting, greater accessibility' to the Petaluma, River and neighboring areas. The proposal fails to incorporate into its design,: the extension of Lynch Creek Way in 'a northwest direction through the project site, as-the General Plan stipulates. The DEIR provides no adequate alternative for achieving the city's goal of enhancing vehicular or pedestrian/bike connections tomearby neighborhoods. General Plan Consistency and Water Use There has been no evaluation of water usage cited in the Project's DEIR. The .Water Resources Section of the General.Plan.has gone to painstaking effort to provide 'guidance for future water use and conservation. It recognizes, the scarcity of the resource and the need to use water in the most environmentally sensitive and responsible manner. Unfortunately, the DEIR has not identified the estimated water usage of the Project nor, does it take into account or.seek to implement meaningful water conservation measures. The recently approved East Washington Place (EWP) .362,000 sf project has an estimated water usage of 13.065 million gallons: per year. Based on the estimated water usage of EWP project and considering the fact that Deer Creek. Village is approximately 315,000 sf and also has proposed a health club facility at the site, which are know to have high wafer ,consumption rates, we can surmise that it's water usage will be substantial, possibly exceeding the estimated water usage of the EWP project. California enacted SB 610 in 2001 to improve ,the linkage between. water and land use planning. It was intended to ensure greater communication between water providers and local planning agencies. Accordingly, SB 6.10 aims to ensure that land use decisions for certain large development projects are fully informed as to whether sufficient water supplies are available to serve the project. Under SB610, California Water.Code section 1:0910 requires a Water Supply Assessment be conducted if "A proposed shopping center or business establishment employing more than 1, 000' persons or having more than 500;000 square feet of floor space." In light of this, It would be prudent for City staff,and planners, to consider the combined 677,000 sf ratio of both projects in the pipeline, as a cumulative' quantity that exceeds the 500 sf requirement to trigger a Water Supply Assessment when evaluating conservation measures for the Project. City staff should require the DEIR consultants to determine the estimated water usage for the proposed project. The DEIR should then consider the feasibility of incorporating all. of the Sustainable Site Planning (Low Impact Design) standards stipulated, in the Water Resources section of our General Plan. In addition, City staff and planners should put forth the recommendation to install dual flush toilets and waterless urinals in all of'the onsite washrooms.- General Plan's Sustainable ,Site Planning (Low Impact Design) Standards: Reduce imperviousness by limiting building footprint, and using permeable paving or landscaping to break up, expanses of impervious surfaces. Grade to encourage sheet flow and lengthen flow paths to increase the runoff travel time in order to reduce the peak flow rate. Cluster development on sites to minimize disturbance. Use canopy trees to absorb rainwater and slow water flow. Direct runoff into or,across vegetated areas to help filter runoff and encourage groundwater recharge. Preserve,,or design into the infrastructure, naturally vegetated, areas that are:in close proximity to parking areas, buildings,, and other impervious expanses in order to, slow runoff, filter out pollutants, and facilitate inf ltration. Reduce street widths °for internal circulation Remove curbs and gutters from streets, parking areas, and parking islands where appropriate, to Allow storm water',sheet flow into vegetated areas. Use devices such as bioretention cells, vegetated swales,.infiltration trenches, and `dry wells to increase storage volume and facilitate infiltration. Disconnect impervious areas from the storm drain network and maintain natural drainage divides to keep flow paths dispersed. Disconnect roof and direct storm water into vegetated areas or into water collection devices. Install cisterns or sub retention facilities to capture rainwater for use in irrigation and non-potable uses. Install "eco- roofs" .(vegetated or garden roofs). Use native;plants (or adaptable species) to establish an adaptable and low maintenance landscape thatrequ_Tres less irrigation and are appropriate for the climatic, conditions. Use naturally occurring bio- chemical processes in pl'adslocated in tree box filters, swales, and planter boxes. Divert water away and disconnect from the storm drain using correctional drainage techniques Gener" al Plan Compatibility The Deer Creek Village Draft EIR hinges its analyses of project impacts greatly on,Petaluma's General PlanEIR. In the most important areas such a_ s, Urban Decay, Traffic, Water Usage, and Aesthetics 'impacts, the Project's DEIR is inadequate and leans heavily on the City's General Plan EIR. While "sirnultarieously, .rejecting all of our General ..Plan's major planning directives for designing and building a, sustainable mixed -use, pedestrian oriented project that would benefit the community most. The proposed project is out - syncr with whatthe community has envisioned in our General Plan for that specific site. Therefore, rendering General Plan EIR data inapplicable. Given the size and scope of the proposed project, city council and staff should,not allow the Draft EIR .consultants the option of incorporating`this previous data until a alternative project proposal, that better complies with." Petaluma's. General Plan is presented. Sincerely, Paul Francis Petaluma; Resident Co- Founder Petaluma Neighborhood Association