ojai news at The Ojai Post :: blog, newspaper, events in Ojai, California

January 30, 2007

Gary Kaiser, Project Planner
Santa Barbara County Planning and Development Department
624 W. Foster Rd.
Santa Maria, CA 93455

Re: Draft EIR for the Proposed Diamond Rock Sand and Gravel Mine (Case #03CUP-00000-00037, 03RPP-00000-00002 & 05EIR-00000-00001) (AKA: Troesh Ready,

Dear Mr. Kaiser:

Thank you for giving the City of Ojai an opportunity to comment on the Revised Draft Environmental Impact Report (DEIR) for the proposed Diamond Rock Sand and Gravel Mine and Processing Facility.

The City’s original comment letter dated March 24, 2005 requested that the DEIR include analysis of the project’s potential traffic impacts, noise impacts and air quality impacts within the City limits of Ojai. In addition, the City requested to have the chance to review the proposed mitigation measures for the project.

Traffic
The DEIR states that the proposed mining operation would have 118 average daily trips (ADT) and a maximum number of 164 daily trips (DT) for trucks going both northbound and southbound.

Mitigation Measure (TR-1) states that truck operations on SR 33 south of Highway 150 shall be restricted as follows: 1) No southbound truck trips shall be allowed during the a.m. peak period (6:30 a.m. to 9:00 a.m.) during Monday through Saturday; and 2) No northbound truck trips shall be allowed during the p.m. peak period (3:30 p.m. to 6:00 p.m.) during Monday through Saturday. Suggested Condition (TR-3) restricts travel on SR 33 in front of Nordhoff High School from 7:00 a.m. to 8:00 a.m. and 2:30 p.m. to 3:15 p.m. during the school year.

The proposed mitigation measures may be adequate if followed, but enforcement of the multiple time restrictions and hours of commute would be impossible to monitor unless conditioned to have additional code enforcement, which will be discussed below.

Noise and Vibration
The City of Ojai has concerns with the noise of the trucks passing through the City. Based on the existing mining operations north of the City of Ojai, which create noise and vibration nuisances, the new facility and the allowance of Jake brakes through the Ojai Valley would significantly contribute to this impact unless mitigated. The DEIR states that the increased noise levels would be moderate (~5 dBA) relative to the existing ambient noise levels, and would not exceed 65 CNEL. However, the sound of trucks rumbling and braking at all times of the day and night creates an annoyance and a poor quality of life. The DEIR includes a mitigation measure prohibiting the use of Jake brakes between Ozena and the project site. This measure is not adequate. Therefore, the City recommends a mitigation measure that shall limit the use of truck’s Jake brakes on SR-33 through the City, north to the project site.

Air Quality
The DEIR discusses vehicle emissions from peak production, analyzed by using Santa Barbara County’s thresholds. However, the project’s potential air quality impacts are not limited to the Santa Barbara County border. The City previously requested that air quality impacts be analyzed within the Ojai Valley Airshed, which is limited by a threshold of significance of five pounds a day for NOx or ROC pursuant to the 2003 Ventura County Air Quality Assessment Guidelines. Tables 3.7-10 and 3.7-11 of the DEIR state that the Daily Haul Truck Emissions of NOx in Ventura in both the Average and Peak Production years are 11.7 and 17.6 pounds per day, respectively. Based upon Ojai’s threshold of significance of five pounds a day for NOx, would this project exceed this limitation? On Pages 3.7-17 and 3.7-18 of the DEIR, there is reference to Tables 3-62 and 3-63 regarding vehicular emission along SR-33 in the Ojai Planning Area. The two referenced tables were not located. However, the air quality discussion states that the route distance is 8 miles within the Ojai Planning Area, therefore peak daily truck traffic in the local airshed would be considered less than significant impact. It is unclear from reviewing Appendix B that there is data and analysis to support this statement. Since the project will send truck trips through the Ojai Valley, the analysis shall be complete or clarified prior to a project decision. The DEIR is non-responsive to the City’s original comment letter regarding air quality in the Ojai Valley.

Mitigation Monitoring
It appears that the mitigation monitoring is not fully described. The DEIR states that the applicant shall post and maintain a phone recording complaint line to report possible violations of restrictions by residents. Also, trucks owned by the applicant shall be identifiable by a placard with a unique number on the vehicle clearly visible to individuals wishing to make a complaint against an individual driver. Since the applicant has no direct control over independent truckers and their trucks, the mitigation monitoring program states that the applicant shall use the truck trip logs and the complaint logs to identify independent truckers against whom a complaint has been made as a way to resolve complaints.

Citizen complaints to do the monitoring on a project of this magnitude in size and scale shall not be considered an adequate mitigation monitoring program. The City of Ojai strongly recommends that the County work with Ventura County in providing a unified mitigation monitoring program and/or CUP Compliance Program for all three aggregate mines in the area. At the very least, the County shall consider, in addition to the log book prepared at the mining facility that describes the trucks loads, time of trip, etc., that the project pay to employ a County code enforcement officer. This could include the applicant (or all three mines) paying the salary for a full or part-time position that is dedicated to mitigation monitoring/CUP compliance. Considering the significant environmental costs of non-compliance of mitigation measures and conditions of approval, a paid monitor is a relatively minor cost to ensure compliance.

Although not a mitigation measure, it seems like there should be some stiff monetary penalty for non-compliance of the permit.

For years, the City has been copied on several letters to both Ventura County and Santa Barbara County from Ojai Valley residents who live on or near Maricopa Highway that have issues and concerns with the current mines north of the City. If the project is approved, it is critical that the new plan shall include mitigations to the impacts that can be easily monitored and enforced. The current mitigation monitoring plan is inadequate, and should be addressed prior to permit approval.

Thank you for the analysis on “Quality of Life” issues in the DEIR regarding the project. The City of Ojai City Council is strongly opposed to this project, because the cumulative effects to the Ojai Valley’s Quality of Life would be negatively affected. The City of Ojai asks that the Santa Barbara decision makers pay close attention to the DEIR analysis of the Class I impact to the Quality of Life impacts to the surrounding communities and deny the project.

Again, thank you for the opportunity to comment. If you need any clarification, please contact me via e-mail at schmidt@ci.ojai.ca.us or by phone at (805) 640-2555 x. 113.

Sincerely,

Katrina Rice Schmidt, AICP
City Planner
City of Ojai

cc: City Council
Jere Kersnar, City Manager

March 24, 2005

Larry Appel, Supervising Planner
Gary Kaiser, Project Planner
Santa Barbara County Planning and Development Department
624 W. Foster Rd.
Santa Maria, CA 93455

RE: Draft Environmental Impact Report (DEIR) for the Proposed Diamond Rock Sand and Gravel Mine and Processing Facility (Case # 03CUP-00000-00037, 03RPP-00000-00002 & 05-EIR-00000-00001) – Troesh Ready-Mix, Inc.

Dear Mr. Appel and Mr. Kaiser:

Thank you for the opportunity to review the DEIR for a proposal to develop a new sand and gravel mine and processing facility on a 133-acre site located in the Cuyama River channel, located 5.9 miles south of its junction with State Highway 166 in unincorporated Santa Barbara County.

The Traffic and Air Quality Impacts sections of the DEIR state that based on the analysis, the proposed project would not result in any significant traffic or air quality impacts. This assumes that traffic resulting from the project would be shifted from other existing sources and demands. The City of Ojai finds that the analysis is inadequate, and should be analyzed with a more conservative approach, assuming that this is a new project. Given that building materials are needed in areas outside of Santa Barbara County, it is quite possible that demand for such materials would increase from other growing counties. If that were the case, Ventura County, and specifically the City of Ojai would see greater increases in both truck traffic and air emissions as a result of this project.

The City of Ojai requests that the DEIR include an analysis of the project’s potential traffic impacts and air quality impacts within the City Limits of Ojai, per the thresholds established in the City of Ojai’s General Plan and Initial Study Assessment Guidelines. Specifically, we request that the DEIR include an analysis of the project-specific and cumulative traffic impacts for Highway 33 / Highway 150 through the City limits and the air quality impacts of the Ojai Valley Airshed, which is limited by a threshold of significance of five pounds a day for NOx or ROC pursuant to the 2003 Ventura County Air Quality Assessment Guidelines. In addition, the City requests to review all proposed mitigation measures that are provided if traffic or air quality impacts within the City limits are determined to be significant.

Mitigation measures could include placing a maximum daily number of truck trips through the City on Highways 33 and 150 through town, with specific travel times that would avoid peak pedestrian and vehicle traffic in the morning, lunch hour and evening peak hour work and school periods.

In addition to traffic and air quality, please address the additional noise impacts to existing residences along Highway 33 through Ventura County. Mitigation measures should be included in the EIR.

Thank you for the opportunity to comment. Please contact me if you have any questions.

Sincerely,

Daniel Singer
City Manager

for Robert Casias, AICP
Community Development Director