06.17.2024 - Michelle Johnson
Heather Flores
From:Michelle Johnson <cheriej2042@yahoo.com>
Sent:Monday, June 17,
To:Planning Commission
Subject:\[EXTERNAL\] Proposed Approval of Gypsum Canyon
Attachments:GeosyntecReport2024.pdf; GCReportUpdate1PrintEditionDistribution.pdf
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Dear Anaheim Planning Commission,
I am writing to object to the proposed approval of Gypsum Canyon for a cemetery for the following reasons:
1. The original land was donated in perpetuity by The Irvine Company to the County of Orange solely for
uses found in County Service Area 26 which is the area for parks. There are no provisions within this section
for a Cemetery. Then Supervisor Todd Spitzer when accepting the donation from The Irvine Company stated
that the land would be held in perpetuity as open space. For donating the land, The Irvine Company received $8
million in tax credits.
2. The site has now had 3 Geotechnical Reviews. The first Geotechnical Review was done in 2019 by
Leighton and Associates. However, Orange County Cemetery District (OCCD) withheld this report (over 1400
pages) from public scrutiny. I had to submit a public records act request to gain access to this report. OCCD
failed to provide a copy of this report to CalVet when they reviewed their portion of the site. The most current
review by Geosyntec dated May 17, 2024 points out a number of problems not only with the site but with the
Environmental Review. Specifically, there are inaccuracies regarding the disposal for waste used historically on
the project.
The Geotechnical Engineers state "The Phase I ESA concludes that a Phase 2 ESA is not warranted. This is
questionable, since it is still unclear if historical impacts from Site past industrial use have been fully mitigated
to today's regulatory requirements. Furthermore, regulatory requirements have changed since the 2005 EIR,
probably resulting in more analyses, regulatory negotiations, and potentially costly environmental remediation
if the site is developed. Additional costs associated with the potential extensive environmental remediation
work and additional required analysis necessary to meet current regulatory requirements for the type of
proposed site improvements do not appear to have been included in the final concept plan cost estimate for the
project. While these costs are dependent on several factors such as the extent and nature of remediation as
informed by additional testing and analyses and are difficult to be quantified at this time, it should be noted that
these might add significant costs to the project."
The final statement of the Geosyntec Engineers:
"Based on the above, it would be advantageous to find an alternate site that does not require such extensive
civil/geotechnical improvements due to its geologic setting or has a potential for further environmental
remediation due to its past site use. "
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Clearly the Gypsum Canyon site costs analysis and site review indicate numerous ongoing problems associated
with development of any kind. I'm attaching my Investigative Report on Gypsum Canyon where many of these
issues have been raised including landslides, seismic issues, land transfer irregularities, environmental issues
including protected plants, birds and species on the site that remain unaddressed including protected areas that
have documented mountain lion tracking.
3. OCCD in their own meeting minutes recorded their consultants telling them a new EIR would be
required. Instead of performing that required item OCCD chose to ignore that advice and now at the last minute
is attempting to circumvent the requirements they knew all along they would have to comply with. When the
OCCD Board voted on whether to proceed without a new EIR several Board members either abstained or voted
"no". One questioned whether they would get sued over their lack of a new EIR and their consultant said "yes".
This is an attempt of an abuse of power by OCCD and should be stopped immediately.
4. OCCD has not completed many items necessary for the Planning Commission to perform a complete
review. These items were identified in the CalVet study as well as the Geosyntec review. OCCD is attempting
to rush through an approval of a project that has millions of dollars in missing costs. Their attempts should be
rejected out of hand.
Please find attached my Investigative Report with sources annotated as well as the Geosyntec Report. I would
appreciate an acknowledgement of this email.
Very truly yours,
Michelle C. Johnson
Irvine, CA
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