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HomeMy WebLinkAboutSTAFF CONCERN 1 10-05-81DATE: FRON: SUBJECT: September 21, 1981 STAFF CONCERNS NO. 1 Inter -Corn William Huston, City Manager Mike Brotemarkle, Community Development Director County of Orange, Class I Industrial Waster Transfer Station Draft Environmental Impact Report 269 Circulation of the draft EIR starts the County process to consider development of such a facility. The City has until October 19, 1981 to respond with its concerns to this draft. A proposed final EIR would then be prepared and a County Planning Commission hearing scheduled. A Final EIR would have to be "Certified Complete" before further action. Attached is a copy of the Executive Summary and pertinent graphics summarizing the EIR along with an analysis of potential areas of weakness in thelenvtronmental document. I have included previous staff communications to the County expressing concerns which arose during preparation of the County's environmental document. Specific attention should be paid to the letter of Mr. Kenneth K. Hekimian, Ph.D. of Van Dorpe and Associates who is a recognized expert, consultant and university instructor in the field of waste disposal, Major points which should be pursued due to inadequate addressment in the draft include: I. Land Use A. Will ultimately impact far greater number of persons than other sites. Site 17 has commenced construction of 83,132 square feet of new industrial condos and to the southwest a new industrial development of 81,250 sq. feet is underway. This should eliminate site 17*from consideration and reduce the environmental ranking of 16. II. Circulation Site 16 is not as convenient as the other sites for access to the 57 Freeway and, therefore, less desirable for ultimate disposal at BKK in West Covina. B. Traffic is already extremely congested in the immediate vicinity. County of Orange, Class I Industrial Waster Transfer Station Draft Environmental Impact Report September 21, 1981 Page Two III. Economics Using the County's own figures, site 16 is 4th if ranked by cost. However, based on communication with Dave Christensen of the Irvine Co,any, the price used in the EIR comparisons is substantially below current market sales in the area. They estimate that a site such as proposed would cost $16.00 per square foot or a market value of $4,158,760.00 for site 16. The County GSA estimated a value of $2,600,000. This is $1,558,760.00 below what current sales would indicate. A possible 60% difference in the price would need closer analysis and affect the cost comparisons in the EIR. IV. Need Tustin is a low volume producer of such wastes at 7%, yet is expected to bear the burden of environmentally damaging activity to solve the problems of other industrial areas. Further analysis is needed. V. Alternatives to BKK The document suggests that in the future alternatives may have to be selected to BKK but does not adequately address the suitability of the alternative transfer sites to such alternative Class I duo sites. VI. Current Ownership The Orange County Department of Education via Jean Hayes has indicated they have not been contacted concerning a potential sale and still intend to carry forward their proposal for a special education facility and central cafeteria operation. The EIR should address the relative merits of the two proposed public uses. Further, the impact of the State Law restrictions on sale of surplus school property, it's equity gains, low cost housing exemption and the financial impact on the Department of Education should be addressed in detail. VII. Procedural The EIR does not adequately address the issue of local control, zoning, use permits, imposition of local conditions, or the State, County, Local regulatory matrix on such a facility. Mitigating measures to offset financial service costs to local government encumbered with such a facility need to be addressed fully. County of Orange, Class ! Industrial Waster Transfer Station Draft Environmental Impact Report 269 Recommendation Council direct a letter summarizing City of Tustin concerns be prepared for the Mayor's signature including the items discussed herein, brought forth in Council discussion or raised by public input. The Council encourage all citizen's, homeowners groups, business concerns or other interested party to also submit concerns to EMA, the City and/or Board of Supervisors regarding this facility. Council direct staff to ascertain the commitment level of the County Department of Education to their proposed project' and their course of action a~suming any potential acquisition by the County General Services Administration is proposed. MWB/dat