HomeMy WebLinkAboutPC Agenda Statement 10-21-1992AGENDF TAIEI_LENT
PLANNING COMMISSION MEETING
OCTOBER 21, 1992
SUBJECT: Staff Responses to Comments Received on the Eastern Dublin
Draft General Plan Amendment
PREPARED BY: Brenda A. Gillarde, Project Coordinator
ATTACHMENTS: 1. Letter from Ted Fairfield, dated September 7, 1992
RECOMMENDATION:
1. Hear Staff presentation
2. Review October 21 and September 23, 1992 agenda
statements; discuss issues
3. Make recom mendations to Staff, via straw votes, on the
issues outlined in the October 21 agenda statement
4. Continue public meeting to October 29, 1992
FINANCIAL STATEMENT: None
BACKGROUND:
Comments on the GPA come from three sources: 1) one letter dated September 7,
1991 (see Attachment 1); 2) several public comments which primarily referenced
Specific Plan land use issues; and 3) the analysis on land use policy contained in
the Eastern Dublin Draft Environmental Impact Report (DEIR).
It is noted that a second letter on the Draft GPA/SP was received from the
attorney for Mr. Fairfield on October 16, 1992. Staff clid not have time to review
these comments in time for the October 21st meeting. Staff will submit responses
for consideration by the Commission at a subsequent meeting.
The following section addresses those comments that relate to policies contained in
the proposed GPA. Public comments relating to land use issues will be raised
during the upcoming Commission meetings on the Draft Specific Plan.
Each comment is paraphrased and is followed by a staff recommendation/
explanation. Policy modifications are denoted by shut. for deleted text and by
bold typeface for added text. The numbers in the left hand column refer the
reader to the actual wording of the comment. Required action by the Planning
Commission is indicated by bold typeface. Any direction given by the Commission
should be done by straw vote since the public comment period on the Draft EIR
remains open.
DIC,U,SSION:
1. Letter from Ted Fairfield. dated September 7. 1992.
1-1 Comment: The terms "ridgeland" and "disfigure" are subjective and could
have a major prohibitive effect on developability. (Draft GPA,
1
Policy 2.1.4 C, p. 14) In western Dublin, this prohibition only applies to
areas viewable by existing Dublin residents (Draft GPA, Policy 2.1.4 G, p.
15).
Staff Recommendation: Staff recommends that Policy 2.1.4 C on page 14 of
the Draft GPA remain unchanged.
The terms "ridgeland" and "disfigure" are contained in existing City policy
which reads "Proposed site grading and means of access will not disfigure the
ridgelands" (1985 City General Plan, p. 12). The Eastern Dublin General Plan
Amendment/Specific Plan was designed to be essentially consistent with
existing City policies. This was done in accordance with the consensus
reached by the City Council during the study sessions held in 1990 and 1991.
At that time, the consensus of the Council was to prepare a plan that
maintained existing City policies regarding development on slopes and
ridgelines.
The letter makes reference to policy modifications for western Dublin which
are less restrictive. The western Dublin General Plan Amendment was
designed to apply only to western Dublin. Because of that site's unique
physical characteristics (i.e., extensive steep topography, expansive tree
cover, low visibility of site's developable area by the public), special policy
modifications tailored to the site were necessary. If the same policy
regarding development on ridgelands were applied to eastern Dublin, no
development could occur in any area viewed by the public, which would be a
major portion of eastern Dublin. (Refer to Eastern Dublin GPA, p. 15, item
G(2).) Thus the western Dublin policy would be as, or more, restrictive in
eastern Dublin.
Commission Action Rewired: Direct Staff, by straw vote, on whether
Policy 2.1.4 C, p. 14 of the Draft GPA, should be modified or remain
unchanged as recom mended.
1-2 Comment: Development in eastern Dublin is prohibited on slopes over 30%
whereas in western Dublin it can occur if certain findings are made. (Draft
GPA, Policy 3.1 B and F, p. 17).
Staff Recommendation: Staff recommends modifying Policy 3.1 B to add the
following verbiage:
Consider development in areas over 30 percent if the area is less than
three acres in size and is located within an area designated for
development that is less than 30 percent slope.
The Draft GPA was designed to keep areas of 30 percent slope or greater
free of development. However, in order to provide contiguous areas of
development, it was necessary in some cases to include small areas of 30
percent slope. The proposed policy modification would clarify how
developable areas were identified in the Draft GPA.
Further exceptions to this policy should not be made. The slopes of eastern
Dublin are highly visible to passing motorists, unlike the western Dublin site
which was mostly obscured from views by motorists and existing residents.
2
The issue of substantially modifying existing City policy regarding
development on slopes over 30 percent was discussed at the joint Planning
Corn mission/ City Council study sessions held in 1991. The direction given
to Staff was to develop a plan that was consistent with existing City policies
regarding development on steep slopes.
Following that directive, the Eastern Dublin GPA was designed to
substantially avoid development on slopes over 30%. The plan provides for
generous amounts of development while adhering to this policy:
approximately 18,000 units and 11.6 million square feet of corn niercial space.
Commission Action I_IssaiAd: Direct Staff, by straw vote, on whether Policy
3.1 B, p. 17 of the Draft GPA, should be modified as recommended.
1-3 Com ment: Preservation of oak woodlands, riparian vegetation and natural
creeks as open space is required in eastern Dublin but not in western Dublin.
(Draft CPA, Policy 3.1 A and E, p. 17).
,Staft Recom meridation: Staff reconi mends that Policy 3.1 A be modified as
follows:
Preserve Preservation of oak woodlands, riparian vegetation, and
natural creeks as open space for their natural resource value is of the
highest priority. Limited modification may be permitted on a case by
case basis with adequate mitigation to replace disturbed resources.
This modification provides some flexibility for those situations where it may
not be possible to fully preserve the natural resource. The Eastern Dublin
Specific Plan reflects this flexibility in several policies (Policy 6-9, 6-12 p.
64; Policy 6-15, 6-17, p. 66; Policy 6-21, p. 67). A subsequent specific plan
for the remainder of the GPA area could also incorporate this type of
flexibility.
It should be noted that vegetative conditions on the eastern Dublin site are
very different from western Dublin. The amount of tree cover is extremely
limited, thereby making it very valuable habitat. Tassajara Creek is a major
year round stream course and part of the regional park trail system. The
significance of these resources warrants their protection to the maximum
extent possible.
Commission Action Required; Direct Staff, by straw vote, on whether Policy
3.1 Al p. 17 of the Draft GPA, should be modified as recommended.
1-4 Comment; Property owners in eastern Dublin are discouraged from
cancelling Williamson Act Contracts whereas they are not in western Dublin
(Draft GPA, Policy 3.2 A and D, p. 19).
Staff Recom mendationi Staff recommends that Policy 3.2 A of the Draft
GPA remain unchanged.
Current City policy stipulates that proposals for conversion of Williamson Act
Contract lands cannot be considered until two years prior to exbiration.
3
Also current language stipulates maintaining lands currently under Williamson
Act in agriculture.
In contrast, the Draft Eastern Dublin GPA revises this wording to allow for
consideration of Williamson Act Contract cancellation and removes the two
year restriction for consideration of development proposals on such lands
(Draft GPA, Policy 3.2 A, p. 19).
Com mission Action Required: Direct Staff, by straw vote, on whether Policy
3.2 A, p. 19 of the Draft GPA, should be modified or remain unchanged as
recom mended.
1-5 Comment: Performance standards and an ordinance for runoff are proposed
for run-off in eastern Dublin but not in western Dublin. (Draft GPA, Policy
7.2 C, H and I, p. 31)
Staff Recommendation: Staff recommends that Policy 7.2 C remain
unchanged.
Policy 7.2 C is existing City general plan policy. A policy requiring erosion
control plans was adopted for western Dublin which will likely be evaluated
against any existing City programs to ensure consistency. Thus the erosion
plan for western Dublin will likely be as restrictive as that for eastern
Dublin.
Commission Action Required: Direct Staff, by straw vote, on whether Policy
7.2 C, p. 31 of the Draft GPA, should be modified or remain unchanged as
recom mended.
1-6 Comment: A fair share method needs to be developed for provision of
parkland in eastern Dublin that provides for existing as well as future needs.
(Draft GPA, Policy 3.3 G, p. 20)
Staff Recom mendation: Staff acknowledges that a funding methodology needs
to be developed for parklands as well as other infrastructure required for
eastern Dublin. Development of these types of programs will occur as part
of processing the Eastern Dublin Specific Plan, after it has been approved.
The City has begun to address the issue via the fiscal studies done for the
project; also a special presentation on funding mechanisms will be held
before the City Council in November.
Commission Action Reouired: None required at this time.
1-7 Comment: The road alignment for the extension of Doolan Canyon through
the open space violates Policy 7.7 E of the Draft GPA (p. 34).
Staff Recommendation: Staff recommends that Policy 7.7 E of the Draft
GPA remain unchanged.
This policy is current City general plan policy. An amendment is proposed
to this policy to allow for some disturbance due to difficult terrain (Draft
GPA, Policy 7.7 H, p. 34). However, the overall intent is to minimize
grading for roads through open space areas.
4
The alignment for Doolan Canyon extension is conceptual; however, Staff
Concurs that the alignment shown in the Draft General Plan Amendment may
require steep grades and/or substantial grading. Staff is working with the
consultant to devise an alternate layout. A recommendation will be
presented at a subsequent Planning Com mission meeting.
Commission Action Requited: None required at this time.
2. Draft EIR_ corn ments on_the_ r2rP.PQ_90 ...Eaggril QPIIRAILEian
Amendment
The Draft Eastern Dublin EIR made several observations on potential
inconsistencies between existing General Plan policies which have been
carried over unchanged into the Draft GPA and the proposed Draft Specific
Plan. These potential inconsistencies between the Draft GPA and the Draft
Specific Plan are listed below along with Staff recorn menclations. The
Com mission action required is described at the end of this com ment/response
section.
2-1 Com ment: Potential inconsistency between existing City Policy 3.1 A which
requires preservation of oak woodlands, riparian vegetation and natural creeks
as open space and the Draft Specific Plan which says "wherever possible".
(Draft EIR, p. 3.1-25)
Staff Recommendation: See response to corn ment
2-2 Com ment: Potential inconsistency between existing City Policy 3.1 B which
maintains slopes over 30 percent as open space and the Draft Specific Plan
which allows for some development in 30 percent areas. (Draft EIR, p. 3.1-
25)
Staff Recommendation; See response to comment
2-3 Comment: Potential inconsistency between existing City Policy 8.2.3 A
which preserves woodlands and the Draft Specific Plan which allows some
removal under special circumstances. (Draft EIR, p. 3.1-32)
Staff_ Recom merglation• Staff recoil) mends modifying Policy 8.2.3 A as
follows:
Protect riparian vegetation and prohibit removal of woodlands,
wherever possible. Replant vegetation according to the standards in
the Eastern Dublin Specific Plan. Renityval---fyf-an---411€1440.lektal-f)elt-tree
They +e--e efts -Were +hrettg9t--tlie-pF eie et- -rev4ew tyr-o e e se:
Also include a reference to General Plan policy 3.1 A, as modified (see
response to comment 1-3).
2-4 Com ment; Potential inconsistency between existing City Policy 8.2.3 C
which prohibits woodland removal and the Draft Specific Plan which allows
some removal under special circumstances. (Draft EIR, p. 3.1-32)
5
Staff Recommgndation: Staff recommends modifying Policy 8.2.3 C to add
the words "wherever possible" after the first sentence and to add c reference
to Policy 3.1 Al as modified (see response to comment 1-3).
2-5 Comracnt.: The Draft EIR identifies additional potential inconsistencies
between the following existing general plan policies and the proposed Eastern
Dublin Specific Plan:
CP 3.2A - Williamson Act lands (DEIR, p. 3.1-26)
IP 7.7B - Restriction of lands designated as open space (DEIR, p. 3.1-26)
IP 4.1B - Coordination with school districts (DEIR, p. 3.1-27)
GP 4.3A - Expansion of wastewater facilities (DEIR p. 3.1-27)
GP 4.4A - Planning and provision of water (DEIR p. 3.1-28)
5taff _Recommendation: Staff recommends that no modifications be made to
these policies.
Staff finds that the Specific Plan is consistent with these policies and will
make recommendations to the Planning Commission at a later date regarding
appropriate wording for the Final EIR.
Commission Action Requireck Direct Staff, by straw vote, on whether the
staff recommendation for comments 2-1 through 2-5 should be followed or
should alternate actions be taken.
EX,OIVIM EN DADON
1. Review October 21 and September 23, 1992 agenda statements
2. Discuss issues
3. Take action as outlined under "Commission Action Required"
4. Continue the public meeting to October 29, 1992
siedoct21
6
TED C. FAIRFIELD
Consulting Civil Engineer
September 7, 1992
Laurence Tong
Planning Director
City of Dublin
6500 Dublin Blvd.
Dublin, CA 94568
Dear Larry:
cc = -
I V E D:
iu92
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 ridgelandc will be
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
'
`• l
West Dublin, this restriction can be eliminated iminated i f three simple findings can be �•20
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).
P.O. Box 1148 • 5510 Sunol Blvd. • Pleasanton, California 94566 • (415) 462-1455
i
• September 7, 1992
Laurence Tong
Page 2
— Property owners in East Dublin are discouraged from applying for cancellation l-M
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). 1"
— 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 East 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 is
of the Eastern 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 thaf -
roads which pass through open space areas shall be designed to minimize grading to the \-1
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 Fast 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
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 .revegetati.on 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
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
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.
— 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
feeling there are kit foxes in the area when there have been no confirmed
sightings.
— 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
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.
— 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.
— Action Program 7B is too exacting. Final grading plans, etc. should not be
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:dim