HomeMy WebLinkAboutPC Agenda Statement 12-7-1992SUBJECT:
PREPARED BY:
ATTACHMENTS:
RECOMMENDATION:
BACKGROUND
AGENDA STATEMENT
PLANNING COMMISSION MEETING DATE:
DECEMBER 7, 1992
IT
(;
Eastern Dublin: Remaining Comments on the
Draft Specific Plan; Part I of the Responses
to Comments on the Draft EIR
Brenda A. Gillarde, Project Coordinator
A. Letter from Ted Fairfield, dated 9/7/92
1. Part I of Responses to DEIR Comments,
dated 12/7/92 (under separate cover)
1. Hear Staff presentation
2. Discuss responses and related issues
3. Provide direction to Staff per the
Commission Action section contained in
the agenda statement
4. Continue meeting to December 15, 1992
The previous two Planning Commission meetings dealt with responses to
comments on the Eastern Dublin Draft Specific Plan. Staff has
provided some additional responses to several comments made in the
attached letter that were not included in the October 29 presentation.
The remaining comments in this letter were covered in the October 29
agenda statement, Letter 4 from Hallgrimson, McNichols, McCann &
Inderbitzen, dated October 16, 1992.
In addition, this agenda statement provides an outline of Part I of
the responses to the Draft EIR. The responses were prepared by the
study consultant, Wallace, Roberts & Todd, and were reviewed by City
Staff. Part II of the responses will be discussed at the December 15
Planning Commission meeting.
ISSUES
A. REMAINING COMMENTS ON THE DRAFT SPECIFIC PLAN
A. Letter from Ted Fairfield, dated September 7, 1992
A-1 Comment: The floor area ratio shown for General Commercial and
Industrial Park is unrealistically low. The amount of acreage
for the high school site (55.3 acres) is 15 acres more than is
necessary.
Staff Recommendation: Staff recommends retaining the text as it
presently appears in the Draft Specific Plan.
The general plan land use category for General Commercial allows
a range of .20 to .60 FAR and for Industrial Park a maximum of
.35 FAR with an ultimate of .50 FAR in some cases. The .25 FAR
in Table 4.1 was used to estimate yield for the Specific Plan and
/eddec
for environmental review. It was not meant to imply the maximum
or minimum amount of general commercial or industrial
development.
The acreage shown for the high school is at the high end of the
range that is normally required for these types of facilities
(40-55 acres). This is due to the topography of the site which
is sloping in some areas. The actual acreage needed by the
school may be less than is shown in the Specific Plan, depending
on the design and siting of the school. Any designated school
acreage that is not needed for a school would be redesignated
residential at the same density as the surrounding area.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, or leave it unchanged, as recommended by
Staff.
A-2 Comment: Policy 6-12 (page 65) which requires detention basins
should be eliminated.
Staff Recommendation: Staff recommends retaining the text as it
presently appears in the Draft Specific Plan.
The policy does not require detention basins. It states that
retention basins are preferable to channelization. Any
improvements, including retention or detention basins, for flood
control purposes would have to be approved by Alameda County Zone
7 Flood Control.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, or leave it unchanged, as recommended by
Staff.
A-3 Comment: Policy 6-38 should only apply to major cut and fill
slopes.
Staff Recommendation: Staff recommends revising the text to
allow minor exceptions subject to approval by the Public Works
Department.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, as recommended by Staff.
A-4 Comment: The golden eagle nest is not properly located on Figure
6.2. The word "potential" conveys the feeling there are kit
foxes in the area.
Staff Recommendation: Staff recommends revising Figure 6.2 to
more accurately depict the location of the eagle nest. The
reference to potential kit fox dens should remain as it presently
appears in Figure 6.2.
Appendix E of the Draft EIR clearly defines potential kit fox
dens: "Any natural den or burrow within the species' range that
has entrances of appropriate dimensions to accommodate San
Joaquin kit foxes for which, however, there is little to no
evidence of kit fox use." (Page App-E/1) This definition is
provided by the US Fish and Wildlife Service. The dens found in
eastern Dublin fit this description and are, therefore, correctly
classified in Figure 6.2.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, as recommended by Staff.
A-5 Comment: Figure 6.3 incorrectly shows the southernmost tributary
of Tassajara Creek as the Creek. (The remainder of the comment
regarding the location of the golden eagle protection zone was
covered in the October 29 agenda statement (Comment 4-20)).
Staff Recommendation: Staff recommends revising Figure 6.3 to
show the southernmost tributary as an intermittent stream course
rather than part of Tassajara Creek.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, as recommended by Staff.
A-6 Comment: The design guidelines for the Gateway Subarea (page
102) require orienting buildings so that they do not face
directly onto the freeway and that heavy planting be placed along
the freeway frontage to buffer the buildings. This will
excessively limit valuable freeway exposure for these buildings.
Staff Recommendation: Staff recommends retaining the text as it
presently appears in the Draft Specific Plan.
The Building Siting guidelines do not preclude buildings facing
the freeway, only that they are oriented so their backs are not
facing the community streets. Since many of the buildings will
be tall or large, building signage and freestanding signs can be
used for identification.
Landscaping along the freeway frontage can be designed so that
building signage and freestanding signs will be visible from the
freeway.
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, or leave it unchanged, as recommended by
Staff.
A-7 Comment: Action Program 7B is too exacting (page 116). Final
grading plans, etc. should not be reviewed by a design review
committee. Also perspectives/renderings should not be required
as part of design submittal.
Staff Recommendation: Staff recommends retaining the text as it
presently appears in the Draft Specific Plan.
This program does not require review by a design review
committee. The program requires submittal of certain information
to the City for review. Requiring submittal of renderings or
perspectives is a standard request in development applications.
It assists the City in determining whether the proposed
development is consistent with the design guidelines of the
Specific Plan.
3
Commission Action Required: Direct Staff, by straw vote, whether
to modify the text, or leave it unchanged, as recommended by
Staff.
B. DRAFT EIR RESPONSES TO COMMENTS
The following section contains consultant responses to a portion of
the comments received on the Eastern Dublin Draft EIR. Due to the
magnitude of comments received (over 750), responses have been
prepared in sections. Letters containing the comments addressed in
this agenda statement are attached for the reader's reference.
Two types of comments/responses are outlined in the paragraphs below:
1) Staff recommended text changes to the Draft EIR; and 2) responses
to comments addressing major adequacy issues in the Draft EIR. Staff
concurs with these responses and believes that the Draft EIR and Final
EIR fully address the adequacy issues raised by various commentors.
The remainder of the attached comments/responses are not specifically
addressed in this agenda statement but can be brought up by the
Commission if so desired. The remaining responses primarily clarify
information in the Draft EIR or answer questions raised by the
commentor about procedure, methodology and/or assumptions. Again,
Staff concurs with the responses contained herein and believes that
the issues are adequately addressed in the Draft EIR and Final EIR.
The Planning Commission is requested to review all of the
comments/responses, and take action as indicated in bold typeface. As
mentioned previously, the Commission can raise questions about other
comments/responses not specifically raised in this agenda statement.
The purpose for reviewing the comments/responses is to consider the
adequacy of the Eastern Dublin EIR. At a subsequent meeting, the
Planning Commission will make a recommendation, in the form of a
resolution, that the City Council certify the Eastern Dublin EIR as
adequate. Adequacy is based on whether the information has been
presented in accordance with State requirements and whether there has
been sufficient analysis to inform decision -makers of the
environmental consequences of a project. Adequacy is not affected by
the presence of significant impacts which cannot be mitigated and
require a statement of overriding considerations. Also, disagreement
among professionals about the severity of an impact does not affect
adequacy.
1. Comments/Responses Recommending Text Changes to the Draft EIR
Comment/Response # Summary of Staff Recommended Changes
2-3 Corrects number of aircraft at Livermore Airport
3-3 Corrects three acreage figures in Figure 2-D
(Ownership Patterns)
3-7 Corrects a typographical error in the persons per
household figure (the correct figure was use in
calculations for the Draft EIR)
7-11 Recommends revision to mitigation for I-580/
Hacienda Drive eastbound ramps
7-13 Recommends revision to mitigation for I-580/Santa
Rita Road eastbound ramps
8-2 Changes policy reconciliation to recommend right-
of-way for six lanes on Tassajara Road
12-2 Corrects level of service and number of lanes for
12-4 certain roadway segments as shown in Table 3.3-9;
corresponding text revisions will also be made
12-9 Corrects Figure 3.3-B regarding number of lanes on
I-680
13-8 Adds language to specify revegetation criteria
13-9 Adds language specifying certain prohibited
invasive plant species
14-4
14-7
Adds language to discourage the use of groundwater
Adds language to minimize stream maintenance
impacts
15-1 Adds language to clarify the project is served by
four interchanges
15-3 Corrects two ownership errors on Figure 2-D
15-4 Corrects errors in Table 3.1-1 and 3.1-2 related
15-5 to Williamson Act Contract expiration dates
15-6 Corrects a typo regarding creek setbacks
15-26 Changes wording to ensure a practical approach to
fire station site acquisition
15-33 Corrects typographical error on level of impact
statement regarding park acreage
15-37 Adds language to place emphasis on the US Postal
Service to provide any necessary facilities in
eastern Dublin
15-38 Add language to place emphasis on supporting the
Alameda County Library System in providing any
necessary facilities in eastern Dublin
15-39 Adds language to clarify DSRSD wastewater
collection plans in relation to Doolan Canyon
15-43 Adds language to clarify the use of piezometers
15-44
15-58
16-11
16-12
16-14
16-19
17-2
17-18
19-1
23-11
Changes language to clarify the definition of
special- status wildlife species
Changes mitigation for burrowing owl to allow
greater flexibility
Adds information regarding capacity, projected
enrollment, student generation rates for Livermore
Valley Joint Unified School District (LVJUSD)
Changes student generated rates
Adds information regarding funding sources for
LVJUSD
Clarifies school selection areas
Recommends revision to mitigation for I-580/Airway
Boulevard westbound ramps
Adds reference to additional California Division
of Mines and Geology information
Adds reference to Alameda County's Storm Water
Management Plan
Clarifies submittal of development agreements
Staff Recommendation: Staff recommends incorporating the above
changes into the Final EIR.
Commission Action Required: Direct Staff, by straw vote, whether
to incorporate the above changes as recommended by Staff.
2. Comments/Responses Relating to Adequacy of the Draft EIR
Comment/Response # Topic
1-6 Analysis of hazards from ground rupture
1-7 "No mitigation is required" statements
3-10 Feasibility of roadway mitigation measures
7-6 Impact of overpasses on Pleasanton
7-9 List of intersections studied in EIR
7-10 Inclusion of a funding program for roadway
improvements
9-1 Impacts on the Alameda County Congestion
9-5 Management Program
9-3 Source of funding for roadways improvements
6
9-4 Relationship to Alameda Countywide
Transportation Plan
12-1; 12-6
22-5; 22-8
Use of AM and PM peak hour analysis
13-3 Use of current projections for buildout of
Tassajara Valley
14-2 Expansion of impact analysis to include
demand on regional parks
14-5 Secondary impacts of increased water demand
on Del Valle and Shadow Cliffs Recreation
areas
15-16 Methodology used for traffic analysis
15-18 Discussion of traffic impacts on areas
outside the immediate project vicinity
15-21 Need for additional information on
mitigations for Airway Boulevard
16-18 Use of Livermore School District criteria
17-3 Study of ozone precursors
17-4 Identification of CO values
17-8 Exposure of development to airport noise
20-7 Studies for the Tiger Salamander
22-11 Impacts of Camp Park operations on the
project
STAFF RECOMMENDATION
Staff recommends that the Planning Commission review the agenda
statement and attachments and direct Staff where indicated by
bold typeface. Review of the Responses to Comments does not
require direct action by the Commission. As stated previously,
the Commission will ultimately make a recommendation to the City
Council regarding certification of the Draft and Final EIR for
Eastern Dublin. In order to certify an EIR, it must be found
adequate. The Commission ultimately must determine if the Draft
EIR and Responses to Comments have adequately identified and
addressed the issues relating to the proposed development of
eastern Dublin.
7
TED C. FAIRFIELD
Consulting Civil Engineer
September 7, 1992
Laurence Tong
Planning Director
City of Dublin
6500 Dublin Blvd.
Dublin, CA 94568
Dear Larry:
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DUBLIN PLANNING
As an outgrowth of the meeting among you, Rod Andrade, Dennis Carrington and
Brenda Gillarde on 8/17/92 I am submitting comments and concerns pertaining to the
draft Eastern Dublin General Plan Amendment and Specific Plan. These comments
represent the thinking of all members of the Lin Design Team (Rod, Jim Tong,
Bob Harris and Marty Inderbitzen), in addition to myself. these comments are in
addition to the formal responses we intend to make to the EIR and planning documents
via the CEQA and public hearing procedures.
Our initial comments pertain to the Eastern Dublin General Plan Amendment. Most of
these comments have to do with how much more the proposed GPA constrains
development in Eastern Dublin as compared to the development constraints proposed
for Western Dublin (i.e., those properties covered by the Western Dublin Specific
Plan). Examples of this are as follows:
— In East Dublin, site grading and access roads cannot "disfigure" the ridgelands
(p. 14). In West Dublin, this prohibition exists only where ricigelandc will he
viewed from existing Dublin development (p. 15). Ridgelands are prominent
features of the East Dublin area. "Ridgelands" can also be subjectively
interpreted, and depending on how the terms "ridgeland" and "disfigure" are
defined, this prohibition could have a major impact on the developability of the
area.
— In East Dublin, development is to be prohibited in areas over 30% slope. In
West Dublin, this restriction can be eliminated if three simple findings can be
made by the City (p.17).
— East Dublin developers are required to preserve oak woodlands, riparian
vegetation and natural creeks as open space. This directive does not seem to
apply to West Dublin (p.17)./TM .-
P.O. Box 1148 • 5510 Sunol Blvd. . Pleasanton, California 94566 • (415) 462-1455
PAGE _L._ OF
• September 7, 1992
Laurence Tong
Page 2
— Property owners in Fast Dublin are discouraged from applying for cancellation
of Williamson Act contracts where those in West Dublin aren't (p. 19).
— Performance standards and an ordinance regulating run-off are proposed for
East Dublin. No such mechanisms are proposed for West Dublin (p. 31).
— East and West Dublin have arbitrarily been treated differently. The value
judgements made in West Dublin need to be applied consistently throughout the
General Plan, including Fast Dublin!
We have two other concerns about the GPA. First of all, Guiding Policy G under
Amendment 3.3 states "Provide active parks and facilities which are adequate to meet
citywide needs for open space, cultural, and sports facilities, as well as the local needs
of the Fastern Extended Planning Area." This seems to indicate that development in
East Dublin will pay for citywide recreation facilities even though there already may be
a current need for such facilities. A means of everyone paying their fair share should
be developed. Secondly, Implementing Policy E under Amendment 7.7 states that
roads which pass through open space areas shall be designed to minimize grading to the
maximum extent possible. This policy was not followed by WRT in laying out the
alignment of the Doolan Canyon connector.
The balance of the comments in this letter pertain to the Specific Plan.
— Section 3.5.1 calls for preservation and enhancement of the area's stream
corridors, which are defined as Tassajara Creek and four intermittent stream
corridors. Elsewhere the Plan seems to indicate that all watercourses (natural
stream courses, stream courses, etc.) be preserved and enhanced. Figures 4.1
and 6.1 seem to show 8 open space corridors located in stream valleys. I
assume Figures 4.1 and 6.1 govern, but it is important that this matter be
clarified. Every swale in the plan area is a watercourse and if they all have to
be preserved, then virtually no development can take place. The plan must be
specific in which natural elements must be preserved. This comment also
extends to section 3.5.2 where grading is discussed. Avoidance of extensive
grading must be limited to sensitive areas defined in the plan. The amount of
grading must not be the focus here, but rather the aesthetics quality of the
developed product should be the plans concern.
— Table 4.1 shows a floor area ratio of .25 for General Commercial and Industrial
Park. This figure is unrealistically low. This same table shows the high school
site at 55.3 acres. This is probably 15 acres larger than is necessary.
September 7, 1992
Laurence Tong
Page 3
— The first sentence in Section 4.4.1 says 1,975 acres are devoted to residential
land uses. This doesn't correspond with Table 4.1 which shows 1,703 acres of
this designation.
— Action Programs 4F and 4G call for development of an inclusionary housing
program and in -lieu fees for Eastern Dublin. Why wouldn't such programs
apply to the entire City? It is not equitable to assign responsibility of such a
social problem to only the builders in East Dublin! As we have mentioned in
the past, we don't feel inclusionary zoning is practical or workable. An in -lieu
affordable housing fee would he much more effective.
— Policy 4-26 calls for residential and employment generating uses to be
developed concurrently. This is unworkable since employment usually follows
creation of a work force.
— Action Program 4N says credit toward parkland dedication will be given only
for level or gently sloping areas suitable for active recreation use. It seems to
me there is some recreation value to more steeply sloping land, therefore, some
credit should be given for this type of terrain. Also it is unreasonable to think
that naturally flat parksites exist in East Dublin. Much as the area needs to be
graded for homes and "developed" uses; parks, too, will have to be created by
grading efforts.
— We have a number of questions and concerns regarding action Program 5A.
Some of the curves on Fallon Road extension are in the 1,000 ft. radius range,
but the minimum curve radius called out for arterial streets is 1,400 ft; on -street
parking should probably be prohibited on major collector streets; the maximum
grade on residential streets should be 15 % rather than 12%; and more flexibility
is needed on the length of cul-de-sac streets.
— Action Program 5C calls for a minimum 300 ft. wide buffer between the
Tassajara Creek trail and adjacent development. Depending upon where the
trail is located, this could mean a set -back of 350 ft. to 400 ft. or more from the
creek. This distance is excessive. Setbacks should be measured from creek
banks and a minimum of 100' should be adequate.
— Action Program 5F calls for businesses with 50 or more employees to prepare a
TSM program. However, Section 3.4.6 says this will be required only of
businesses with 500 or more employees.
— Action Program 6A talks about open space management plans and calls for
review of such plans by applicable agencies such as the Department of Fish and
3
PAGE OF 7
September 7, 1992
Laurence Tong
Page 4
Game. We would urge that such review occur only when stipulated by the
regulations of those agencies, e.g., in conjunction with a stream alteration
permit in the case of Fish and Game. This comment also applies to Policy 6-9.
— What is the rationale of requiring replacement of riparian habitat on a 3:1 basis
(Policy 6-10)?
— Policy 6-11 must apply only to the stream corridors shown on Figures 4.1 and
6.1 and then only in those areas where development has an impact on the stream
corridors. When revegetation does take place, why is Fish and Game approval
required? Why isn't City approval alone satisfactory?
— Policy 6-12 requiring detention basins should be eliminated. It is likely that
piping systems will be necessary to control erosion; not provide increased A2.
capacity. Where major downstream facilities have been built and planned to
accommodate more water, detention basins make little sense.
— Policy 6-14 calls for avoidance of development which backs directly on a stream
corridor. Policies such as this can sometimes place unreasonable constraints on
development.
— Action Program 6E is too broadly worded. Applicants should have to submit
plans to the COE and Department of Fish and Game only in accordance with the
official and formally adopted regulations of those agencies.
— Action Program 6G should apply only to the stream corridors shown on Figures
4.1 and 6.1.
— Policy 6-17 should apply only to rare and endangered species known to exist in
the East Dublin area.
— Action Program 6M is totally unreasonable. The cost of placing transmission
lines underground would break any project.
— Policy 6-29 seems to indicate development will not be allowed on the
foreground hills and ridgelines if at any one spot on a defined scenic route, a
backdrop of natural ridgelines does not remain visible. This is too draconian;
development of such areas should be allowed when the general intent of not
creating a silhouette is achieved. The same comment applies to Policy 6-30.
— Policy 6-33 says grading shall not "disfigure" the foreground hills. What does
disfigure mean? Some disturbance of these ares will be necessary in order to
PAGE a. o
September 7, 1992
Laurence Tong
Page 5
implement the plan. This should be acceptable provided such areas are properly
restored.
— Policies 6-34 through 6-36 get to the heart of our major concern about the
Specific Plan. Figure 4.1 shows the developable areas and open space areas in
Eastern Dublin. It is our opinion that grading must be allowed everywhere in
the developable area if even the average densities shown in Figure 4.1 (and
reflected in Table 4.1) are to be achieved. If Policies 6-34 through 6-36 (and
many of the guidelines described for the Foothill Residential Subarea) are
followed, it would be surprising if development at one-half of those residential
densities could be achieved, at least as far as the Single Family and much of the
Medium Density and Medium High Density Residential designations are
concerned. Tassajara Village could not be constructed in any manner similar to
the design shown in Chapter 7 if these policies and design guidelines are
implemented. Therefore, instead of 12,500 units, the Plan would likely
accommodate development in the range of only 9,000 to 10,000 units. This is
an obvious inconsistency which is not reflected in other parts of the Specific
Plan. Such a design concept jeopardizes the fiscal feasibility of the Specific
Plan and reduces the Plans ability to provide moderately priced housing for the
future jobholders in the area. This concern will be discussed further in our
comments on Chapter 7.
— Policy 6-38 must apply to major cut and fill slopes only.
A-3
— Figure 6.2 is misleading. First of all, the golden eagle nest is not properly
located. Secondly, even though the word potential is used, it conveys the A`14
feeling there are kit foxes in the area when there have been no confirmed
sightings.
01.14
— There are two discrepancies in Figure 6.3. The southernmost tributary of
Tassajara Creek is shown as Tassajara Creek, this is incorrect; and the boundary A• J
of the golden eagle protection zone is not remotely similar to the area earlier
agreed upon.
— The design guidelines for Fallon Village call for buildings in the residential
neighborhood south of the Transit Spine to be sited so they are not visible in
views of the open space preserve from the south. This restriction may not be
achievable without a severe impact on the developability of the residential
neighborhood.
— The design guidelines for Tassajara Village prohibit culverts or channelizing
Tassajara Creek. Does this mean all of the crossings shown on the Tassajara
September 7, 1992
Laurence Tong
Page 6
Village Concept Plan must be bridges? This would be very expensive. Some
channelization/stabilization of the Creek may be necessary in order to
implement that village plan. We are concerned with the overall design of
Tassajara Village as shown in Figure 7-28; there are too many (5) expensive
crossings of Tassajara Creek, property lines haven't been respected and
topographic constraints may cause problems.
Much of the Foothill Residential Subarea is shown as Single Family Residential
on the Land Use Map (Figure 4.1). Large areas are devoted to Medium
Density Residential as well. The Foothill residential design guidelines are
impractical under the densities described in the Plan. These are the types of
guidelines which would be used for custom homes in hillside areas at a density
of about two units per acre or less!! As I mentioned previously, we feel it will
be necessary to grade the entire developable area (as shown on Figure 4.1 but
excluding Rural Residential) in order to achieve the densities called for in the
Specific Plan. The maximum 65 % of parcel grading limitation is especially
bothersome. Stepped building pads are not envisioned but elevation differences
would take place between pads. Development would be very similar to the
Vintage Hills section of Pleasanton. As I understood it from conversations with
City staff, you were mainly concerned about streets which ramp directly up hill
faces and extensive graded slopes between tiers of lots especially where this
could be seen from scenic corridors. Our intention has always been to avoid
this type of development, but to do so by grading relatively flat areas partially
behind hills or berms, or in front of ridgeline backdrops so the development
won't be obtrusive from off -site.
illumemo
— The design guidelines for the Gateway Subareas prohibit buildings adjacent to
I-580 from being directly oriented toward it. Also heavy planting is called for
along the freeway right-of-way to buffer these buildings. Exposure for
buildings on this very valuable property is, therefore, going to be severely
inhibited.
— In some instances road rights -of -way standards are overly generous. this is
especially true with regard to the widths of sidewalks. Also they include an
over abundant amount of landscaping for this era of reduced water availability.
A- b
— Action Program 7B is too exacting. Final grading plans, etc. should not be A'7
reviewed by a design review committee. Also perspectives/renderings should
not be required as part of a design submittal.
— Policy 8.2 should be modified by substituting "occupancy" for development in
the second to last line.
September 7, 1992
Laurence Tong
Page 7
— Policy 8.3 should be amended by adding "according to state standards" at the
end.
— Action Program 8H should be modified to require City of Dublin approval of
any DRFA standards.
— We wonder why the Plan proposes combining the Camp Parks and Alameda
County turnouts into the DSRSD system?
— In view of the new NPDES requirements we feel Program 9T is unnecessary.
— On p. 145 where DRFA impact fees are discussed, it mentions four fire stations
will be required for the eastern Dublin build -out. Section 8.3.1 states two new
stations will be needed.
Larry, I realize this is a rather exhaustive list of comments, but I think they are all
important. All of these items need to be addressed at this time in order for the
development stage of the process to run smoothly. If you have any questions, please
don't hesitate to contact me.
Sincerely,
Ted C. Fairfield
TCF:dlm
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