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HomeMy WebLinkAboutCRYSTAL COVE STATE PARK LETTERCRYSTAL COVE STATE PARK LETTER CITY OF NEWPORT BEACH December 22, 1981 Mr. ,James M. Doyle, Supervisor Environmental Review Section California Department of Parks P.O.Box 2390 Sacramento,•California 95811 Dear Mr. Doyle: PLANNING DEPARTMENT (714) 640-2197 and Recreation Thank you for the opportunity to review the General Plan/Environ- mental Impact Report for the Crystal•Cove State Park. The City of Newport Beach reviewed the plan in detail and has a number of comments and questions. Major items of concern are: 1) Limitation of Public Access. The plan proposes that Crystal Cove State Park be used primarily to protect resources and that access be limited both to the canyons and to the shoreline. This'is contrary to the needs in .'Orange County which has a need for active recreational facilities. The restrictions on access to the -beach and the limitations on available parking are particularly significant when considering the severely overcrowded beach conditions which are currently experienced by the surrounding communities of Laguna Beach, Newport Beach - and Huntington Beach, and also by nearby State park beaches of Doheny Beach, Corona del Mar, Huntington Beach and Bolsa Chica Beach. The Crystal Cove Park plan provides for 1570 total parking spaces for 3.25 lineal miles of coastline. By comparison, Corona del Mar State Beach provides 488 parking spaces for 0.28 lineal miles of coastline. This is more signifi- cant when the 1570 parking spaces are to serve the entire 2,791 acres. 2) Participation of Surrounding Communities. It is the position of the City of Newport Beach that this plan shoulc be reviewed formally by the adjacent communities of Laguna Beach, Irvine, and Newport Beach, and also by the County of Orange. Additional review time should be allocated in order.that public hearing on the plan may be scheduled be- fore the legislative bodies of each of these jurisdictions. City Hall • 3300 Newport Boulevard, Newport Beach, California 92663-3884 Mailing Address - P.O.Box 176B - Mr. James M. Doyle - Page 2 December 22, 1981 3) Adequacy of Environmental Documentation. The Environmental Documentation is not adequate in the following areas: a) Cumulative and secondary impacts are not addressed. b) The EIR does not statistically describe the pro- posed project versus what currently exists. c) There is no description of the Regional/Local Setting. d) The document does not contain the documentation of the Notice of Preparation. Additionally, attached to this letter is a detailed list of com- ments and questions relative to each element of the Crystal Cove State Park General Plan. If you have any questions,.please call me at the above number. Very truly yours, PLANNING DEPARTMENT JAMES D. HEWICKER, Director by _ILPG( is-aa �I R D TALARIC Environmental Coordinator FT/PT/kk Summary 1) Consistently Corona del Mar is referred to in the document as a separate community. Corona del Mar is part of the City of Newport Beach. 2) The statement that the park contains some of the last remaining undeveloped coastal property in Southern Calif- ornia should be defined as being Orange County, Los Angeles County, San Diego County, etc. 3) Are the offshore submerged lands that may be added to the park part of the plan? 4) How large a region was considered for the regional plan-• ning considerations? 5) Did the study include the Urban National Park concept? 6) Are there any use intensity limits in the Crystal Cove Historic District? 7) The listings for the picnic/day-use areas should all be given by capacity (number of people). 8) Two of the overnight areas are listed as "ride -in." Are these for horses? 9) The access to be provided for the elderly and handicapped should be listed. - 1 - Introduction 1) Will future specific proposals be subject to CEQA? 2) Is the Environmental Impact Element part of the plan? 3) If this General Plan serves as the Environmental Impact Report, it does not meet all the requirements of CEQA (see additional comments on the Environmental Impact Element). 4) To what does the "Southwest Mountain and Valley Landscape Provinces" refer? 5) The plan states that an extensive arterial highway and free- way system serves this region but does not address the adequacy of the system. 6) flow do the proposed dedications, of the Local- Coastal Program and the preservation efforts of the Laguna Belt, Aliso Greenbelt and Urban National Park proponents fit'into the project description? Are they part of the plan? 7) Why are resource descriptions included in the project descriptions. 8) The section describing public involvement should include the location of and attendance at the meetings. 9) How broad was the survey of needs? Was it a scientific sample? - 2 - Resource Element 1) New acquisitions for Crystal Cove State Park should require an amendment to the General Plan. 2) What are the constraints on activity on the coastal terraces? 3) Is there any difference in climate between the coastal and canyon portions of the park? 4) The plan states that the major source'of beach sand originates in and near the park. Is this the major source for the park? Newport Beach? Laguna Beach? Orange County? 5) The plan states that changes in land use or modifications to the existing landscape may affect beach sand supply. What is the source of information? Do all changes result in a negative effect? Are there any changes which could result in a more beneficial situation? 6) To what extent do slope failure and earthquake damage limit recreational development? 7) The magnitude of bluff erosion should be quantified. What part does bluff erosion play in beach replenishment. 8) What is the•exteht of each plant community? Do any of these limit recreational development, and if so, why? 9) To what extent are the two rare plant species found in the park and in adjacent undeveloped areas? 10) Where is the California Least Tern found near the• project area? Does the park contain any areas considered to be critical habitat for the Least Tern? 11) The section on Marine Life should include a discussion of the Outer Continental Shelf development and the State Tide- lands Act. 12) The plan states that the park is located amidst dense urban development.. What is the definition of dense? Laguna Beach and Newport Beach are predominantly low -density residential in character. 13) How many people reside within 1, 5, 10 and 20 miles of the site? How many will reside at buildout? 14) The Resource Section does not delineate needs. 15) What type of authority or what kind of influence does the State have in the "Zone of Primary Interest." 16) Do the existing reservoirs provide a resource for active recreational uses? - 3 - 17) Please map the areas to be included in the bluff protection zone. Please provide the supporting documentation for placement of these areas in this very restrictive designa- tion. Will there be any access or permitted uses in these areas? 18) What effect will the policy on allowing grasslands to revert to scrub or chaparral have on fire suppression needs? 19) Since the plant resources' policies lead in the direction of increased fire hazard, will the State be able to provide total fire protection or will cost be incurred by nearby localities expected to participate in fire planning pro- grams. 20) The protection from wildfires' policies should be coordinated with all adjacent jurisdictions during implementation of the General Plan., 21) Do any of the surface water areas within the park have any vector control problems'? 22) Will the marine life resources area be managed differently than similar areas in Newport Beach and Laguna Beach? 23) A policy regarding off -shore oil drilling would be appro- priate in the Marine Life Resources Section. 24) Describe the types of measures which may be taken to amelio- rate the impacts of the equestrian facility. 25) The criteria used in developing allowable use categories and the supporting data on resource constraints and sensi- tivity should be included in the documentation in' that they are the primary justification for the liinited use proposed in the park plan. 26) The statement that "the purpose of Crystal Cove State Park make available to the people for their enjoyment ... a sig- nificant open space area..." is very important and should be at the beginning of this document. - 4 - Land Use and facilities Element 1) Discussion of the regional setting is inadequate. 2) There is a conflict between the recreational needs outlined and the proposed plan for a minimum of recreational develop- ment. 3) How many regional day -use visitors can be expected and how does this compare to the adjacent cities of Laguna Beach and Newport Beach? 4) An objective of the plan is to support and encourage pro- posals for increased use of alternative transportation. There does not appear to be any monetary or planning support for this concept other than a severe restriction on available parking facilities. 5) Placement of a significant portion of. parking facilities on the inland side of Pacific Coast Highway conflicts with the plan objective of safe and convenient access to sandy swim- ming beach areas. 6) Will there be parking provided in the Historic District? 7) The plan concentrates intensive developments in two locations: Crystal Cove and Moro -Cove. Why can't these facilities be spread out if the whole coastal shelf is disturbed? 8) The primary design concept for the park is for extensive trail development. Won't most visitors drive to the park, and isn't the major demand for swimming/sunbathing? 9) What provisions for marine safety will be made for the Marine Ecological Preserve and the Underwater Park Area. 10) What parking is proposed for beach visitors? Is it located conveniently for families with small children and elderly people? 11) How accessible is the Pelican Point Coastal Strip, since it is a quality recreational and educational area? 12) How much of four sixty -car areas for trail access are for day use? 13) How important is Sand Canyon Road (proposed) to�the function- ing of the park? Should development of the park be phased with roadway construction and improvements? 14) How far will day -use visitors need to walk to get to the various- destinations? 15) What is.the timing for construction.of the group day -use and overnight campground facilities? - 5 - 16) Development of overnight camping on the E1 Morro Mobile Home site will put the RV's in a most visible location from the highway. A mitigation measure should be proposed addressing this impact. 17) How does the campground intensity of six sites per acre com- pare to Newport Dunes, San Clemente, Doheny Beach and San Onofre. 18) How many square feet of operational and administrative facilities are being proposed? 19) Where is on -site staff housing to be provided? Where will the balance of the staff reside? 20) What is the proposed park entrance fee? 21) Are there any capacity or supply. constraints on water, sewage, and power needs for the park? 22) The General Plan should include details of services and locations for concession facilities.' 23) What is the justification for maintenance of the snack shack in its present location? It is not located in an area easily accessible to park visitors; it is only accessible to through traffic on Pacific Coast Highway. 24) Given the location of the parking facilities, a park tram shuttle should be provided.• Day use will be severely re- stricted if there is no tram system. 25) Assuming the instantaneous capacity number of 7,480 visitors is appropriate, a minimum of 2,137 parking spaces should be provided (one parking space per 3.5 visitors). Are these provided? 26) The plan gives a turnover rate of 2'.0. Newport Beach experi- ences a turnover rate of 3.0+, 27) How does the phasing of increased park operations relate to Pelican Hill Road and Sand Canyon Road? u Interpretive Element 1) One interpretive theme is how ranching preserved the land from development. Isn't ranching a form of development? 2) A sub -theme should be added addressing the relationship with the adjacent communities of Laguna Beach and Newport Beach. 3) Has consideration been given to provision of an archaeo- logical/paleontolog•ical museum and center in the Crystal Cove area? 4) Since the area has great educational value, has considera- tion been given to additional educational facilities through cooperation with the University of California, Irvine and California State University, Fullerton? 5) Why are no audiovisual programs proposed? 6) How is access to Moro Canyon achieved? 7) Why is the coastal terrace area only proposed -for day use? 8) How many day beach visitors are expected to use the intern pretive facilities and trails? Aren't most people going to the beach simply to sunbath and swim? 9) Why can't the inland Crystal Cove Area be more actively used? 10) Where is the proposed point of origination for .boat tours of the marine preserve. 11) What is the -definition of "environmental living"? 0 - 7 - Operations Element 1) How many day -use visitors currently use the park per year and how much parking is currently provided? 2) The section on Administrative Heeds should discuss numbers of employees and necessary housing in detail. 3) What basic services are provided at similar coastal park units. Compare what is to be provided at Crystal Cove with Huntington State,Beach, Bolsa Chica State Beach, Doheny State Beach, etc. 0 MIM Environmental Impact Element 1) Will EIR's be prepared for subsequent specific projects and improvements. 2) On what specifically will the two million dollars for interim facilities be spent. 3) The Element does not follow the State EIR Guidelines. 4) Document does not contain the documentation of the Notice of Preparation. 5) The land immediately adjacent to the park is not com- mercial, residential and industrial. it is vacant. 6) The document states that the creation of the Orange Coast National Urban Park adjacent to Crystal Cove State. Park is not actively being pursued. this is not true. 7) The population section should show.population within the 15, 30 minute 1, 2 hour travel time frame and the 5, 10, 30, 60 mile radius frame. 8) EIR does not address secondary cumulative impacts on adjacent beach areas resulting from the restricted access proposed in the plan. 9) What affect will erosion control and drainage structures have on the sand supply necessary for .beach replenishment. 10) Mitigation measure regarding runoff from Reef Point, Crystal Cove and Pelican Point parking areas' runoff is not adequate. Construction and operational phases' mitigation measures are needed now or in.subsequent environmental documents. 11) Mitigation measures regarding surface water runoff are inadequate. Additional mitigation measures addressing pollution controls (e.g., vacuum sweeping of parking lots, etc.) will need to be addressed now or in subsequent en- vironmental documents. 12) All mitigation measures should be numbered for easy reference. 13) The mitigation measures do not specifically delineate. the actions which are to be taken as part of the proposed project. 14) If a controlled burn program is instituted by the Depart- ment of•Parks and Recreation for the Crystal Cove Park, a fire protection should also be completed prior to commencement of said program. - 9 - 15) There is no mitigation measure which addresses vehicle miles traveled. 16) The mitigation measure addressing the air quality impacts of construction does not adequately address the impact in that the acceptable level of mitigation is not quantified. 17) The noise effects of the vehicle miles traveled on the highway from Laguna Beach to Newport Beach are not addres- sed and no mitigation measures are proposed. 18) Mitigation measures should be included in the noise section addressing limits on construction during weekends and also limiting the hours of construction to specific hours of the day. 19) The Land Use Section does not address the cumulative and secondary impacts the plan will have on land use and recreational facilities in the adjacent communities. 20) The plan states that the people living in the trailer park and Crystal Cove will be relocated to Laguna Beach or Newport Beach. Is this possible considering the housing'costs found in these communities? The plan also states that the Park Ranger and maintenance staff will also live in Newport Beach or Laguna Beach. The same question regarding housing costs appli-es. 21) How does the mitigation regarding relocation assistance to qualified persons per'California Government Code Section 7260 relate to the relocation of the equestrian center? 22) Mitigation measures for the effects of fire hazard should include development of a program to be adopted and approved by the County of Orange and all adjacent jurisdictions for cooperative fire -fighting agreements and plans. 23) The locations of fire and paramedic services should be dis- cussed in the plan. 24) It is proposed that parking areas not be lighted. Why can't the beach be used after dark for such activities as cook- outs, etc.? 25) The section on Public Services should address the response times for Orange County Sheriff and Fire Department and be compared to those of adjacent jurisdictions. 26) Mitigation measures for transportation include additional signals on Pacific Coast Highway as well as widening. Who would pay for such improvements and how would they be phased with park development? Also, the development of Sand Canyon and Pelican Hill Roadsshould provide additional access to the park•. Shouldn't these roads be constructed prior to any further improvements on Pacific Coast Highway. 10 - 27) It appears that a total of 670 parking spaces is to be , added to the existing total of 900 spaces. Is this correct? The cumulative and secondary impacts on adjacent communities is not discussed. The number of parking spaces on Coast Highway to be removed is not discussed, 28) Does the number of vehicle trips generated, shown on Table 2, include those who park on Pacific Coast Highway? 29) There is no discussion of the capacity of Pacific Coast High- way in adjacent communities. 30) Mitigation measure for transportation should include needed signals, highway widening, and the construction of Pelican Hill and Sand Canyon Roads. 31) The discussion of alternatives to the proposed project is inadequate in the following areas: a) There is no documentation for the statements made in the Increased Intensity of Development Section. b) The statement that the decreased intensity of development alternative would not allow maximum public access appears to be inconsistent since the proposed project limits public access. c) The alternative for camping on the coastal shelf states that the LCP fqr the area calls for small- scale development oriented to day -•use visitors, yet the proposed project calls for little additional facilities and the elimination of some existing facilities. This does not appear to meet the needs of either the day -use visitor or the overnight visitor. 32) The discussion of growth -inducing impacts of the proposed project does not address the impacts on the adjacent communi- ties. 33) There is no discussion of secondary or cumulative impacts.