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31 (326) Susana Barrios From:Robert Krueger <rkruegeroc@gmail.com> Sent:Tuesday, October To:Public Comment Subject:\[EXTERNAL\] FW: commentary on proposed SALT/Deer Canyon development Attachments:2024-10-27_Anaheim_City_Council_Mayor.pdf You don't often get email from Learn why this is important Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message. From: Robert Krueger < Date: Sunday, October 27, 2024 at 3:49 PM To: publiccomments@anaheim.net <publiccomments@anaheim.net>, nmeeks@anaheim.net <nmeeks@anaheim.net> Cc: aaitken@anaheim.net <aaitken@anaheim.net>, jodiaz@anaheim.net <jodiaz@anaheim.net>, cleon@anaheim.net <cleon@anaheim.net>, nrubalcava@anaheim.net <nrubalcava@anaheim.net>, sfaessel@anaheim.net <sfaessel@anaheim.net>, citymanager@anaheim.net <citymanager@anaheim.net> Subject: commentary on proposed SALT/Deer Canyon development Dear Members of the Anaheim City Council, Mayor Aitken, City Manager VanderPool, Although quite late in the process, attached are my comments on the proposed SALT/Deer Canyon development. These comments are specifically directed at the impact on traffic, which are, in my opinion, poorly addressed in the Environmental Impact Report. I hope that the Council will show more concern for the citizens of Anaheim than did the Planning Commission and reject this development as currently proposed. Thank you for considering these comments. Robert R Krueger 1 2024-10-27 Subject: Proposed SALT development in Anaheim Hills To: Anaheim City Council and Mayor’s Office From: Robert R Krueger, APN I was disappointed to learn that the Anaheim Planning Commission approved the proposed SALT development in the Anaheim Hills area in spite of opposition from “City staff” Planning commission approves 498-unit Anaheim Hills apartment complex – Orange County Register . I read this piece of news while at Roosevelt Drive north of Santa Ana Canyon Road, vainly attempting to turn left…however, traffic was backed up into the intersection and I was not able to get to SAVI Ranch that evening. This is, unfortunately, not uncommon…at times, traffic is backed up on Santa Ana Canyon from Gypsum Canyon to Lakeview I realize that I am late in commenting on this project, but I am writing to urge the council not to approve this project due to its adverse impact on traffic. There may be other areas that are problematic, but I did not have time to review the EIR in its entirety. I did review the section on traffic circulation https://www.anaheim.net/DocumentCenter/View/55867/Appendix-L_Traffic as the impact on traffic may be the largest problem with this proposed project. As a lay person, I did not find this section credible. There are a number of areas that are problematic and, if I were peer-reviewing this, I would have returned it to its authors for revision. I am not sure why these issues were overlooked by the Commission, which presumably has more expertise than I in evaluating these documents. I drive between Lakeview Road and Weir Canyon Road on Santa Ana Canyon Road daily, switching in that area to shared transportation, as I have done for 20 years. Therefore, my comments are colored by extensive personal observations. Regarding the referenced “Appendix-L”, it apparently only considered traffic between Imperial and Weir Canyon. Yet, the proposed development would also affect traffic west of Imperial and east of Weir Canyon, particularly on Santa Ana Canyon Road between Weir Canyon and Gypsum Canyon. This section is already often gridlocked during commute hours. In addition, the proposed project will also most probably further degrade the already over- crowded Riverside 91 Freeway. Section 3.4 states that traffic “observations” on which the analysis was prepared were made on only 2 days. This is an unacceptably low number of observations on which to base models. Typically, models would be based on a high number of observations monitored over a much longer period of time than the May and December period used here. It should be noted that the dates of observation stated are inconsistent, further calling into question the meticulousness of this analysis. Section 3.7 States that LOS D is "minimum acceptable condition" but is only "fair" as per Table 3-1. It is stated that "LOS C (V/C not to exceed 0.80) is the performance standard that has been adopted for the study area circulation system by the City of Anaheim." So this apparently does not meet that standard. LOS D is already a low LOS and it is unclear why a project that will further degrade it is considered acceptable. The study states that the further degradation is insignificant (Table 7-1) but it would seem that further degradation of an already marginal LOS is not in the interests of the residents. Section 3.8 admits that some sections already do not meet the minimal LOS. It also references an “Appendix C” but there are no appendices in this portion and other appendices labelled C are not relevant. The data shown in some of the figures (for instance, Figures 5-2 through 5-7) does not seem credible. For instance, there appears to be a 20 – 30 % decrease and increase in traffic between Eucalyptus and Festival, eastbound and westbound, respectively, even though there is nothing there but the self-storage facility. Comparison of Tables 5-1 and 6-2 appears to show that SALT project will add greater traffic load than the other 8 projects combined. In addition, Tables 12-2 and 12-3 show project will adversely affect already unacceptable conditions in 2029 and in the General Plan build out. City of Anaheim "Traffic Impact Analysis Guidelines for CEQA Analysis" https://www.anaheim.net/DocumentCenter/View/32774/City-of-Anaheim-TIA-Guidelines-for- CEQA-Analysis-62020 shows this area already has high Vehicle Miles Travelled (higher than OC average and highest in the City of Anaheim). The proposed stoplight at the driveway into the proposed project will further degrade the already poor flow of traffic on Santa Ana Canyon Road. In addition, the proposed mitigation measures https://anaheim.net/DocumentCenter/View/56013/10_Executive_Summary basically encourage the use of alternative transportation so potentially do not mitigate at all. It is stated that the installation of a sidewalk will increase pedestrian traffic. Pedestrians already walk between the project area and Festivals and Eucalyptus Dr. In addition, walking between the proposed project and Festivals would do nothing to mitigate the main effect on commuter traffic. My comments are those of a lay person rather quickly reading through sections of the report. I am sure that trained personnel would find even more problematic sections. As it is, the poor quality of this section calls into question the reliability of the other sections (although they are not all generated by the same entities). The remarks by the developer regarding the sidewalks are misleading. Other remarks made by the developer are also misleading, perhaps intentionally so. The developer states that Deer Canyon is “inaccessible” and “under- utilized”, although no criteria are stated for the latter. In fact, Deer Canyon is accessible by at least 4 or 5 entrances. I, and others, utilize this resource on a regular basis. This calls into question the developer’s honesty and integrity. The developers knew the zoning of this parcel when they acquired it and it is unclear as to why they would develop a proposal incompatible with the zoning. According to https://www.ocregister.com/2024/10/01/planning- commission-approves-498-unit-anaheim-hills-apartment-complex , SALT Development had notified the city that if the project were denied they would be pursuing a builder’s remedy application, allowing them to bypass current density limits and build a much larger project. Their builder’s remedy plans would see 1,280 units built in the Hills with 20% being affordable. This is bullying and sounds like extortion. In sum, in my opinion the effects of the SALT project on traffic alone should disqualify it for approval by the Council. If this project is approved, it will further cement the image of Anaheim as “a secretive cabal” https://calmatters.org/commentary/2023/08/anaheim-corruption-southern-california-cities/ that is more interested in assisting outside special interests than in the best interests of its citizens. I therefore urge the council to reject this proposal.