2020-07-01 City Council Item No. 10.8 Public Comment - Phillips Attachment Regular MEETING - Additional Meeting MaterialsEARL W. PHILLIPS, JR, REHS
ENVIRONMENTAL ADVISOR PHILLIPS ENTERPRISES
PROFESSIONAL WRITER • GENERAL • ACADEMIC • TECHNICAL
29041 Hogan Dr., Menifee, CA 92586 ● Phone/Fax: 951.672.1072 ● Email: earlphillips@verizon.net
8-Jan-20
COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT FOR THE PALOMAR
CROSSING DEVELOPMENT PROJECT
Introduction.
The Palomar Crossings Project (proposed Project) Draft Environmental Impact Report (DEIR)
summarizes the environmental effects that are forecast to occur from implementation of a proposal to
change the current land use/zoning from its existing established commercial zone to high density/very
high density residential.
The DEIR presents the project background, project objectives, and project description along with
technical data, inputs from approval agencies, various impact analyses, and supporting data.
The DEIR presents three development alternatives; (1) No Project Alternative (NPA), (2) Existing
Specific Plan Alternative (ESPA), and (3), Reduced Project Intensity (RPIA).
The DEIR requests the City, as the Lead Agency, approve the proposed Specific Plan Amendments,
and allow the project proponents’ preferred Alternative, the (RPIA) to be developed.
If approved, approximately 80 % of this zone would be removed from the city’s available land space
inventory intended and designated for economic development.
Areas of Concern (AOCs).
The project site is located in an established economic zone featuring industrial, light manufacturing,
and commercial venues. Significant among the site’s physical features are the proximity of Southern
California Edison transmission lines & supporting structures, an isolated, abandoned railway
easement, State Highway 74, (which is a heavily used commercial, commuting, and industrial
transportation corridor), industrial, light manufacturing, commercial, and retail venues.
General Plan.
The proposed project would radically usurp the spirit and intent of the City’s General Plan’s Vision,
Goals, and Objectives. The conversion of an established economic development zone into a high
density/very high-density residential environment erodes the ability of the city to diversify its economic
portfolio, create jobs and career opportunities, and replace the current industrial/commercial/business
park theme already established for the zone.
EARL W. PHILLIPS, JR, REHS
ENVIRONMENTAL ADVISOR PHILLIPS ENTERPRISES
PROFESSIONAL WRITER • GENERAL • ACADEMIC • TECHNICAL
29041 Hogan Dr., Menifee, CA 92586 ● Phone/Fax: 951.672.1072 ● Email: earlphillips@verizon.net
Aesthetics.
Based on the DEIR and several site visits, there are no scenic, social, visual, or physical aspects to
the area that would be attractive to a higher income demographic. The area’s dominant industrial
theme, bounded by a moderate-to-low income rural residential community, are major deterrents to the
aesthetic quality envisioned by the RPIA. This represents an undesirable impact to the quality of life of
the future residents.
Demographics.
The abrupt increase in dwelling units (DUs) to be implemented AFTER the amendments are approved
raises the question as to why this is not reflected in the data. The DEIR submits information based on
what is termed “a worst-case scenario”, using a lesser DU criteria, which, given the developer’s stated
intent, is misleading information.
This error invites the perception that given the existing physical environment and its lack of quality
amenities and aesthetics, – this project has a different targeted demographic than what has been
presented. In other words, this project is perceived to attract low-to-very low-income families who will
be packed into a limited land area, within an industrial/commercial/business park environment.
Historically, as implied in the DEIR, such a development in the above-described environment leads to
increased demands for city services and a degradation in the quality of life (QOL) for the future
residents. This is exacerbated by the proposal to pack nearly 3000 people into a limited land area
(approximately 30 acres – of which at least 25% will be used for landscaping, open space, parking,
road access, utility access, and buildings).
Environmental Justice.
The DEIR does not present data or analyses that would address the Environmental Justice component
of CEQA. The proposed RPIA intends to pack a congested population within an industrial zone, with
limited access to quality amenities, quality aesthetics, and desirable city services.
The described environmental conditions, if ignored, will render this project as essentially creating a
barrio under the guise of the politically correct label of “affordable housing”. It should be noted that this
project sets a precedent within the city, as there are no developments of this type in the municipality.
Site Investigation and Preparation.
The site has a lengthy history of agricultural use, specifically the growing of crops. The use of general
and specialized agricultural chemicals (herbicides, pesticides, fungicides) has not been fully
determined. The DTSC, a past participant in the City’s concern with the undocumented use of sludge
biosolids, untested imported soils, and other related activity, has requested a focused site investigation
to determine (1) If there are concentrations of residual contaminants of concern (COCs), including
biosolids, and (2) the likelihood of these residuals posing a adverse impacts to sensitive receptors.
EARL W. PHILLIPS, JR, REHS
ENVIRONMENTAL ADVISOR PHILLIPS ENTERPRISES
PROFESSIONAL WRITER • GENERAL • ACADEMIC • TECHNICAL
29041 Hogan Dr., Menifee, CA 92586 ● Phone/Fax: 951.672.1072 ● Email: earlphillips@verizon.net
Risk Analysis (RA).
Risk assessments build upon the EIR and include important external parameters, i.e., cost-benefit to
the public good and long-term costs/administrative impacts to governance.
Environmental Impacts carry a risk burden which must be assessed and analyzed to determine the
most feasible course(s) of action (or acceptable alternative(s)). After the assessment, the Lead
Agency may elect to,
1. Accept the proposed project alternative,
2. Accept the proposed project alternative with the imposition of conditions of approval.
3. Deny the proposed project and select a more viable/less costly alternative.
The DEIR presents three alternatives (mentioned above), each with a suite of risks which should be
reviewed and analyzed prior to initiating an approval process.
RA-1. No project alternative (NPA) – Risk Burden.
• Loss of potential economic diversity, economic growth, and revenue.
• Loss of potential jobs and/or career opportunities.
• Loss of a potential enhancement to the City’s business image.
RA-2. Existing Specific Plan Alternative – Risk Burden.
• Addition of adverse air pollutants to the ambient air thereby degrading air quality.
• Minor or sporadic increase in the demand for city services.
• Minor increase in traffic congestion.
RA-3. Reduced Project Intensity Alternative – Risk Burden.
• The loss of approximately 80 % of land space from the city’s EDC inventory intended and
designated for economic development.
• Addition of adverse air pollutants to the ambient air thereby degrading air quality.
• Exposure of sensitive receptors to existing and future air pollution contaminants.
• Significant increase in the demand for city services.
• Significant increase in traffic congestion.
• Significant increase in a population density subjected to living in a small land area that is
deficient in quality aesthetics, amenities, and access to quality venues.
• Introduction of possible [social] environmental conditions that violate CEQA’s Environmental
Justice component, particularly with the siting of a high-to-very high-density residential
development within an established industrial/commercial/manufacturing economic zone.
• Loss of potential economic diversity, economic growth, and revenue.
• Loss of potential jobs and/or career opportunities.
EARL W. PHILLIPS, JR, REHS
ENVIRONMENTAL ADVISOR PHILLIPS ENTERPRISES
PROFESSIONAL WRITER • GENERAL • ACADEMIC • TECHNICAL
29041 Hogan Dr., Menifee, CA 92586 ● Phone/Fax: 951.672.1072 ● Email: earlphillips@verizon.net
• Loss of a potential enhancement to the City’s business image.
• Significant increase in the administrative burden to the utility companies along with the
requirement to restructure their service delivery components.
• Significant increase in the administrative burden to the City with the requirements to approve
and implement the proposed amendments at the expense of existing infrastructure already
in place.
• Increase in the long-term O & M cost burden to the city.
Recommendation.
1. The City DENY the proposed amendments and retain the current EDC zone designation
(ESPA).
S/
Earl W. Phillips, Jr. REHS, CDR USNR (Retired)
Phillips Enterprises
References:
1. Initial Study for Menifee North Specific Plan 260, Amendment No. 3 (2010-090) “Palomar
Crossings” February 2019
2. Draft Environmental Impact Report. State Clearinghouse Number 2019029123
for Menifee North Specific Plan 260, Amendment No. 3 (2010-090) “Palomar Crossings”.
December 2019.
3. Menifee Sludge/Biosolid controversy Oct 2013 – 2014.
4. Site visits (2018-2020)
12/2021