On June 19, I provided Carlsbad comments on its 2014 General Plan Environmental Impact Report. Today’s and next week’s blog quote from those comments.
1. “The GP-EIR Ignores the Environmental Impacts of the County [McClellan-Palomar] On-Airport Projects:
Despite the size and impact of McClellan-Palomar [Palomar] operations on the environment of Carlsbad, the GP-EIR comments little on Palomar. Few facilities in Carlsbad create as much of a noise impact as Palomar. No other facility in Carlsbad so restricts surrounding area development and so many property owners. And few Carlsbad facilities have the capacity that Palomar does to create a hazardous waste nightmare.
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Citizens signaled their concern over Palomar Airport noise impacts when 742 citizens filed a letter opposing the 2009/2010 Palomar Airport Land Use Compatibility Plan.
The Palomar EIR discussion is fundamentally flawed. County and Carlsbad dispute the planning and zoning authority that Carlsbad may exercise over county and county tenants at Palomar. Hence, the GP-EIR key CEQA assumption fails. That key assumption says that projects undertaken within the GP area will be sufficiently mitigated because they will satisfy Carlsbad planning policies and conditions.
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Available facts – including the county’s repeated refusal to landscape the Palomar slopes – show that Carlsbad neither imposes nor enforces its restrictions against the county at the Palomar Airport facility.
The GP-EIR does not clearly distinguish between “On-Airport” and “Off-Airport” regulation thereby creating the false impression that all issues have been addressed previously.
The GP-EIR does not disclose any attempt of Carlsbad to address on-airport Palomar problems including storm water contamination that can result from the 3 Palomar Airport landfills and from toxic leaks from Palomar aviation storage tanks owned by the county and county tenants.”
2. “The GP-EIR Analysis is Defective Because it Rests on the Assumption that Carlsbad Will Redefine the Term “Expansion” in Carlsbad Ordinance 21.53.015 and CUP 172 to mean “Geographic Expansion.”
The GP seeks to modify the Carlsbad Ordinance 21.53.015 voter requirement by limiting Palomar Airport expansions of concern to only “geographic expansions.” Carlsbad is saying that voters need not approve a Palomar 900-foot runway extension even though the State Aeronautics Act in PUC § 21664.5 defines an airport expansion as including runway extensions. Similarly, the GP “geographic expansion” policy language is inconsistent with Airport expansion conditions 1, 8, and 11 of CUP 172. This attempted redefinition again emphasizes that Carlsbad does not have the will, and perhaps not the power, to apply or enforce Carlsbad planning and zoning regulations against the county at Palomar Airport.”
Next Week: (1) The General GP-EIR Analysis Method Does not Comply with CEQA and (2) The GP-EIR Provides No Real Discussion of How to Mitigate the Serious Erosion of Traffic Levels of Service.
