A fully built-out SCV according to the OVOV Draft documents
If anything, today’s good Signal report on the reaction of the California Attorney General’s office to the joint City/County One Valley One Vision plan understated just how badly the AG’s office views the draft environmental impact review for OVOV.
Indeed, the letter from the AG savages the OVOV DEIR, saying it fails even as an informational document for “decision makers” and the public:
Our review to date indicates that the DEIR fails as an informational document, in that itfails to apprise the decision makers and the public of the full range and intensity of the adverseeffects on the environment that may reasonably be expected if the Plan is adopted and carriedout.
As The Signal mentioned, the letter also alleges that the OVOV DEIR glosses over the impact of increased traffic, pollution and greenhouse gases. Here’s a relevant section from the OVOV Draft Circulation Element on the County’s website (note this isn’t from the actual EIR document):
Pursuant to AB 32, standards and regulations for measuring and mitigating greenhouse gas emissions were still being developed during the time this General Plan was prepared. However, because of the importance of this issue and in response to the State’s mandate that local agencies consider the effects of greenhouse gas emissions in local planning decisions, the City and County have incorporated policies in the General Plan to reduce vehicle trips and thereby reduce carbon emissions through a variety of planning strategies. These strategies include establishing an urban limit line on the land use map, encouraging infill development through increased densities allowed in the urban core, encouraging mixed use in specified land use designations, promoting transit oriented development around Metrolink stations and the bus transfer station, expanding bikeways and walkways, and using transportation demand management measures.
And here’s the damning response from the AG’s office:
The failure to evaluate the impacts of the proposed Plan as measured against existing conditions, not hypothetical future conditions, results in the DEIR finding the proposed Plan would have no significant impact on climate change (despite adding almost four million metric tonnes of greenhouse gases to the atmosphere), on air quality (despite doubling existing pollutant emissions into an air basin that already is the most polluted in the nation), on transportation (despite increasing average daily trips by about 120%), and other areas. We believe that these findings are not supported by substantial evidence, and that they render the DEIR legally inadequate.
The letter also says that attempts to mitigate greenhouse gas emissions in the plan “tend to be voluntary and unenforceable, merely requiring that the mitigation be ‘encouraged’ or ‘promoted’ and not required.”
That’s probably right and it gets to the heart of the matter. You can’t require that homeowners and commuters use other, greener forms of transportation. To a large extent, a planner’s hands are tied, especially if he’s building low density developments that aren’t transit friendly.
The letter also argues that the premise behind OVOV may be flawed simply because it doesn’t recognize the impacts growth in the Antelope Valley will have on Santa Clarita and the North County region:
Further, the cumulative impacts of the proposed OVOV Plan, taken together with the impacts that will result from development and growth in the remainder of the North County subregion, particularly the Antelope Valley, are barely explored at all.
The letter says this “contravenes CEQA’s requirements and is at odds with one of the central rationales for cumulative impact analysis.”
Local critics of the OVOV plan often say that it encourages too much high density development and doesn’t adequately plan for traffic (TimBen Boydston explains in this video). They probably like the AG’s letter (enemy of my enemy is a friend etc) but would disagree with what would limit greenhouse gas emissions: higher density development that discourages private automobile use.
And as well know, high density is a non-starter in Santa Clarita.
One final note: a footnote on the letter says that these comments are submitted “pursuant to his independent power and duty to protect the environment and natural resources of the State from pollution, impairment, or destruction and in furtherance of the public interest.” It adds that the letter should not be “construed as an exhaustive discussion” of OVOV’s compliance with CEQA.
That to me makes it sound more like a political document rather than a document judging the legal merits of the DEIR. For what it’s worth, Jerry Brown is running for governor.
