Written Public Comment Received Prior to the Meeting — National City City Council, June 20, 2023

[email protected] | D 619-301-0456
June 20, 2023
Via Email: [email protected]
Mayor Ron Morrison
National City Councilmembers
City of National City
1243 National City Boulevard,
National City, CA 91950-4301
RE: June 20, 2023 City Council Public Hearing FGPU/SPEIR: The Alternative Site under the FGPU and SPEIR Avoids Placing Housing Immediately Adjacent to the Freeway and Complies with CEQA
Dear Mayor Morrison, Vice Mayor Molina, and City Councilmembers, My firm represents the Webster Trust, owners of the property located at 121 E. 27th Street, National City, CA 91950 (“Property”). The Property is identified, with two other adjacent properties under separate ownership, as the Alternate Project Location Alternative (“APLA” or “Alternative Site”) and the Environmentally Superior Alternative in the Supplemental Program Environmental Impact Report (“SPEIR”) for National City’s Focused General Plan Update (“FGPU”).

We request City Council to direct staff to return with the Alternative Site selected as the preferred project under the SPEIR for the FGPU. On June 5, 2023 the Planning Commission voted unanimously to recommend the City Council select the Alternative Site. The Alternative Site allows the City to yield more density in a transit-rich location well away from the Interstate 5 (“I-5”) freeway, thereby eliminating freeway air and noise pollution and health risks to future families. The Alternative Site also places housing near jobs, transit, a high school, and converts commercial and industrial use to residential within the residential Olivewood Neighborhood. By selecting the Alternative 2 Site, the City can avoid placing housing immediately adjacent to the freeway and ensure the FGPU and SPEIR comply with CEQA.

A. Property History
The Property, and the properties across A Street at 2601 and 2701 National City Boulevard, National City, CA 91950 (“Dealership Lots”), have been owned by the Webster family since the 1940s. George Webster and his family are proud of their long history with the City of National City and the Mile of Cars Way. The Dealership Lots were the site of the first Subaru dealership in the nation and Webster Pontiac. Over the years, the Property served as a secondary, undeveloped parcel for use by the Dealership Lots. Contrary to the Property’s historic use, the Property is located in the Olivewood Neighborhood and not in the Mile of Cars District.

The Property was used to store new car inventory from the Dealership Lots. The Webster family only used the Property as a parking lot; no building or useable structures exist on the site. The 1.86 acre site, surrounded by residential uses to the north, east and south is identified as a transitional block in the City’s 2021 Transit Oriented Development Overlay (“TODO”) study.

B. Alternative Site
I. Description of the Alternative Site
A description of the Alternative Site is provided in Section 3.4.5.1 of the Final SPEIR.

The Alternate Project Location Alternative would include all the same components as the Proposed Project: updates to the Land Use, Transportation, and Safety Elements and CAP, along with code and Specific Plan amendments. The sole difference between this alternative and the Proposed Project pertains to one Focus Area: the exclusion of the 24th Street Transit Station. This alternative would relocate density from the 24th Street Transit Station to a set of parcels (“Alternative Site”), which would be rezoned to High Density Multi-Unit Residential (RM-2) (see Figure 3.4-1 and Figure 3.4-2, outlined in blue). The Alternative Site is composed of a set of parcels between A Avenue, E 26th Street, E 27th Street, and D Avenue.
3 The Final SPEIR Section 3.4.5.1 states that the City would net an additional 119 dwelling units under the Alternative Site as compared to the Proposed Project, but would see a reduction of 87,705 square feet of commercial space. This reduction would stem from this location being rezoned from commercial uses to RM-2 which only allows residential uses.

The Final SPEIR states that “the Alternative Site was selected as a replacement for the 24th Street Transit Station Focus Area to reduce potential air quality and noise impacts to residential uses near the Interstate 5 (I-5) corridor.” The rationale provided is that “The Alternative Site is located approximately 2,400 feet (0.4 miles) from the I-5 corridor (as the crow flies), as compared to the 24th Street Transit Station Focus Area, which is approximately less than 200 feet from the edge of parcel to the nearest off-ramp (as the crow flies).” See Final SPEIR Section 3.4.5.1.

II. Alternative Site Is A Superior Redevelopment Site To 24th St. Station From both a practical and a planning perspective, the Alternative Site is a superior site because it offers more immediate benefits to the City.

1. If rezoned RM-2, the Alternative Site would be consistent with the existing residential to the north, east, and south, including other RM-2 zones. The 24th St. Station would be residential mixed use surrounded by commercial and industrial.

2. The Alternative Site is in a Transit Priority Area and within walking and bike riding distance to jobs, schools, retail/restaurants, and transit stops, including the 24th Street Station.

3. Alternative Site reduces vehicle miles traveled and greenhouse gas emissions compared to residential dwellings outside of Transit Priority Areas.

4. Provides important and additional housing options for current and future National City residents. Property has been studied for redevelopment with proformas created that support market rate and on-site affordable one, two and three bedroom units. The Alternative Site will provide approximately 119 more residential units than the 24th Street Station. It is unknown what type or mix of housing may be built at the 24th Street Station.

5. Property is “clean” with no known environmental contaminants or hazardous waste issues; Property has no useable structures; is large; and, can be redeveloped now. 24th Street Station has prior known environmental issues; 4 would still need to go through Metropolitan Transit System’s redevelopment process; only a portion of the property may be redeveloped with housing; and, there is an existing long-term lease on the property.

6. The Alternative Site does not expose future residents to significant air quality health risks from toxic air contaminants such as Diesel Particulate Matter (DPM) associated with freeway pollution. 24th Street Station does expose residents to significant air pollution due to location within 200 feet of the centerline of the I-5 freeway.

7. Alternative Site offers higher quality of life and amenities with no freeway noise; near Mile of Cars Way employment/retail/restaurants; near schools and transit; and in an existing residential neighborhood.

III. Alternative Site Comports with City’s Land Use Policies The positive attributes of the Alternative Site also better aligns with many of the City’s proposed FGPU land use policies including:

1. Supporting the City’s Climate Action Plan and other sustainability goals by encouraging high density development in Transit Priority Areas.

2. Prioritizing increasing housing in areas that have access to transit and resources.

3. Promoting the development of housing near employment, recreation, public services, shopping, transit, and active transportation facilities.

4. Encourage and incentivize strategic adaptive reuse and infill development of underutilized vacant land in commercial and mixed-use areas.

IV. CEQA Requires Selection of Alternative Site
Under the California Environmental Quality Act (“CEQA”), the City must chose the Alternative Site, instead of the Project, because the Alternative Site is a feasible alternative that meets the project objectives and would lessen significant environmental effects. CA Public Resource Code Section 21002 and CEQA Guidelines Section 15021.

The City’s environmental documents state that the Alternative Site has been determined to: i) meet all project objectives; ii) reduce unavoidable significant impact to less than significant (i.e., Impact AQ-4); and, iii) is considered feasible. Since it meets all of these criteria, if the City does not choose the Alternative Site, it will be in violation of CEQA and site housing for families immediately adjacent to the freeway in violation of the City’s General Plan.
5 1. The Alternative Site Meets All Project Objectives
As indicated under Final SPEIR Section 3.4.5.2, Objectives, “The Alternate [Project] Location Alternative would meet all of the objectives of the Proposed Project, as the differences between the two are minor…” Contrary to the vague claim on page 29 of the SPEIR Findings, approval of the Alternative Site would not “incrementally reduc[e] transit-oriented development in the City”. Rather, if approved and implemented, the Alternative Site would net more housing units within a transit priority area than the 24th Street Focus Area rezone; thus increasing transit oriented development.

Specifically, the Alternative Site is situated only two blocks from 24th Street. 24th Street is an Arterial/Collector roadway 8, with MTS Bus routes 932 (north/south) and 961 (east/west) located on 24th Street and located less than one quarter of a mile from the Alternative Site. At this short distance, walking to either of these transit stops is estimated at four minutes and biking is estimated at only one minute.

Moreover, the Alternative Site is less than a 15-minute walk from the 24th Street Transit Station and only a four-minute bike ride. As such, the Final SPEIR is incorrect in identifying the Alternative Site as “incrementally reducing transit-oriented development in the City” because the project site is within easy walking and bike riding distance to several major transit stops, including the 24th Street Transit Station and would provide more housing in proximity to these major transit stops than the Proposed Project.

2. The Alternative Site Reduces Unavoidable Significant Impacts to Less than Significant
i. Air Quality
Final SPEIR Section 3.3.7.2, Mobile Sources, states:

The FGPU zoning designations for parcels within 500 feet of I-5 are generally Industrial and Commercial/Industrial. Parcels with a residential Specific Plan zoning designation that are entirely or partially within 500 feet of I-5 include the Focus Area 24th Street Transit Station. Therefore, future development consistent with FGPU may result in the exposure of sensitive receptors to substantial DPM concentrations from mobile 6 sources. Impacts of the FGPU relative to DPM exposure would be significant. (Impact AQ-4).[
1 ]
The Findings state that “sensitive receptors within 500 feet of I-5 are likely to be subject to substantial diesel particulate matter concentrations from mobile sources.” The 500-foot threshold is based on California Air Resource Board’s Air Quality and Land Use Handbook: A Community Health Perspective. The Findings continue by stating that “[s]ince the Alternative Project Location Alternative would move density from the 24th Street Transit Center Focus Area away from this range of the I-5, it would result in less air quality impacts to sensitive receptors.” Final SPEIR Findings p.

28. The City has identified that development of the 24th Street Transit Station will result in significant impacts to air quality. Conversely, the Final SPEIR states that the Alternative Site will reduce such impacts:

The Alternate Project Location Alternative would incrementally reduce the project’s significant impacts requiring mitigation associated with air quality emissions on sensitive receptors and would have less impacts in conflicting with land use plans, policies, and regulations, and in ambient noise impacts compared to the FPGU.

See Final SPEIR p. 28. However, classifying the reduction as “incremental” is incorrect and misleading. A more accurate way to characterize the reduced impact is to state that the Alternative Site, situated over 2,400 feet away from I-5, is outside the area considered to be hazardous to human health. The Final SPEIR identifies the 24 th Street
Focus Area as the only location proposing residential within 200 feet of the I-5.

Consequently, the reduction to Impact AQ-4 is not simply incremental but would be avoided entirely if the Alternative Site is selected and approved by the City. Therefore, the Alternative Site would avoid the significant and unavoidable impact associated with Impact AQ-4 (i.e., health impacts from toxic air contaminants) that would occur if the 24 th Street Focus Area is rezoned and developed with residential uses. 1 Impact AQ-4 is mistakenly referenced as Impact AQ-3 in other locations within the Final SPEIR, including within the Air Quality Section and the Executive Summary.
7 ii. Land Use and Planning Impacts
In addition, the Findings indicate on page 28 that “[t]he Alternative would result in incrementally less impacts relating to consistency with local policies since it would not propose new residential development within 500 feet of the centerline of a freeway since the 24th Street Transit Center Focus Area of the Proposed Project would be replaced by the Alternate Site.” Therefore, selection of the Alternative Site is consistent with Adopted General Plan Policy HEJ-2.3.

Again, the use of “incremental” is misleading. By avoiding placement of sensitive receptors within 500 feet of the I-5, the Alternative Site is entirely consistent with General Plan Policy HEJ-2.3.2 As such, the Alternative Site completely avoids the significant environmental impact resulting from a conflict with the General Plan policy. iii. Noise Impacts
Finally, the Final SPEIR and the Findings state that
[t]he Alternative would also have an incremental reduction in ambient noise impacts to sensitive receptors compared to the Proposed Project due to the location of the Alternate Site since freeways are sources of sustained vehicular noise that contributes to the ambient noise environment.

See Final SPEIR Findings p. 28. As such, the Alternative Site would ameliorate Impact NOI-2 since it is not located next to the freeway.

As stated repeatedly in the Final SPEIR and Findings, the Alternative Site meets all project objectives; avoids significant Impact AQ-4; avoids a conflict with Adopted 2 The adopted Health and Environmental Justice Element Policy HEJ-2.3 in the General Plan calls for the avoidance of “siting new sensitive land uses within 500 feet from the centerline of a freeway, unless such development contributes to smart growth, open space, or transit-oriented goals, in which case the development shall include feasible measures such as separation/setbacks, landscaping, barriers, ventilation systems, air filters/cleaners, and/or other effective measures to minimize potential impacts from air pollution”. (See Final SPEIR Chapter 2, CEQA Compliance Recommendations Regarding Final SPEIR and APL Alternative Responses to Comments, Response to Comment KG-2.)
8 General Plan Policy HEJ-2.3,3 and further reduces significant but mitigable impacts from mobile noise sources.

3. Alternative Site is Feasible
The City in its Findings, and Planning Commission staff report page 11, states that the alternatives presented and considered in the Final EIR constitute a reasonable range of alternatives necessary that would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project to permit a reasoned choice among the options available to the City and/or project proponent.

The City found that the Alternative Site is feasible and may be implemented if approved.

Additionally, not only does the Alternative Site comply with CEQA because it “feasibly attain most of the basic project objectives of the project”, but the City admits and states repeatedly throughout the SPEIR that the Alternative Site attains all project objectives.

See Final SPEIR p. 29. Therefore, the Alternative Site is a feasible alternative to the Proposed Project and can be implemented if approved.

V. Conclusion
We request City Council select the Alternative Site under the SPEIR for the FGPU to avoid placing housing immediately adjacent to the freeway and comply with CEQA.

Sincerely,

CYNTHIA MORGAN-REED
Cc: Carlos Aguirre, Director of Housing
Ben Martinez, Acting Director of Community Development
Scott Huth, Interim Deputy City Manager
Martin Reeder, Planning Manager
3 State CEQA Guidelines Appendix G, Environmental Checklist Form, Section XI, Land Use and Planning, part b. “Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?” Yes because the Proposed Project would site residential dwellings within 200 feet from the centerline of the freeway (i.e. HEJ-2.3) resulting in a significant and unavoidable impact on human health.

City of National City
Focused General Plan Update
Supplemental Environmental
Impact Report
Cynthia Morgan-Reed, Morgan Reed Law
Joseph Smith, AICP, California Coastal Works
Advocacy for Alternate Project Location
Alternative (“Alternative Site”)
City must select the Alternative Site under
FGPU and SPEIR to ensure compliance with
the California Environmental Quality Act
(“CEQA”) and National City’s General Plan.

Alternative Site
24th St Transit Station Site
Alternative Site Benefits under SPEIR

1.Reduces potential air quality and noise impacts to residential uses because it is further away from Interstate 5 (I-5) corridor. Alternative Site over 2,400 feet away from I-5 vs. 24th Street within 200 feet of the I-5.

2.City’s Adopted General Plan Policy HEJ-2.3 calls for the avoidance of “siting new sensitive land uses within 500 feet from the centerline of a freeway” unless it meets City’s goals and includes measures that minimize potential impacts from air pollution.

Final SPEIR and Findings repeatedly found
Alternative Site:

1. Meets all project objectives

2. Avoids significant Air Pollution Impact AQ-4

3. Avoids a conflict with Adopted General Plan
Policy HEJ-2.3

4. Further reduces significant but mitigable impacts
from mobile noise sources.

Alternative Site Complies with CEQA
• City of National City, as the CEQA lead agency, is
prohibited from approving a project when a feasible
alternative exists that meets the central project
objectives and would lessen significant environmental
effects. Public Resource Code section 21002 and CEQA
Guidelines Section 15021.
24th Street Issues

1. Proposed Project exposes future residents to significant air quality health risks from toxic air contaminants such as Diesel Particulate Matter (DPM) associated with freeway pollution.

2. 24th Street Station has other known environmental issues.

3. Proposed Project would still need to go through Metropolitan Transit System’s redevelopment process, which can be lengthy.

4. Only a portion of the property can be redeveloped with housing if transit is to remain: bus turnaround, overhead power lines;

5. There is an existing long-term lease on the property with Sweetwater Unified.

Alternative Site Offers

1. Alternative will provide 119 more units than the Proposed Project.

2. Webster site (1 of 3 parcels) can provide 131 units with on-site affordable included.

3. Webster site will redevelop an underutilized vacant parking lot.

4. Alternative is in a residential neighborhood surrounded by residential.

5. Within half a mile of trolley and close to two bus stops = Transit Priority Area.

6. Webster site has no impediments to redeveloping now.

From: Ted Godshalk
To: Public Comment
Cc: Luz Molina; Ditas Yamane
Subject: Public Comment from Mr. Ted Godshalk for item 9.1 on June 20, 2023.

Date: Tuesday, June 20, 2023 2:41:19 PM
Attachments: App_A.2_Public Comments_AllBracketed.pdf
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Public Comment from Mr. Ted Godshalk for item 9.1 on June 20, 2023.

Council and Mayor,
As you consider tonight’s item to Update the city’s Focused General Plan, I would like to make you aware of several inconsistencies with policies designed to make our community a safer place for all.

The issue I am referring to is the closure of 19th Street under I-5 and the change to two-way traffic on 18th street. The agenda item in front of you, if you are viewing it online (html version), is found by following the attachment #1 for item 9.1 called “Review of the Supplemental Environmental Impact Report…) Beginning on page 3 and continuing on page 4, you will see the section entitled: Transportation Element Update. On page 4 you will see the following:

In addition, the Transportation Element Update incorporates TODO Network recommendations, including:

Road diets on 24th Street, 30th Street, and Hoover Avenue Closure of 19th Street under Interstate 5 (I-5)
Conversion of one-way to two-way traffic on 18th Street under I-5 Signal at National City Boulevard and 22nd Street
Due to the unsafe conditions that will occur from closing 19th Street and going to two-way traffic in the other underpass, I am recommending that you make a finding that deletes from the Transportation Element and all maps and figures, the second and third bullet points above.

I have given Council members tours of the site, I have spoken at all of the important meetings on this issue, I have contacted Caltrans, city staff, and its consultant, and it is now time for you to take action to protect pedestrians, motorists, bicyclists, and the neighborhood.

The two proposals should be removed from the Transportation Element and the Bicycle Master Plan because they are in contradiction with the following SECTIONS AND GOALS in the General Plan:

MOBILITY FRAMEWORK
Goal T-5: A comprehensive circulation network that is safe and efficient for all modes of travel.

Policy T-5.7: Improve circulation for specific areas of the City such as Harbor Drive/Tidelands/Civic Center Drive Intersection and the area west of National City Boulevard, south of 22nd Street and north of Mile of Cars Way.

Policy T-5.9: Maintain a roadway circulation system with multiple alternative routes, to the extent feasible, to ensure mobility in the event of emergencies, and to minimize the need for capacity increases on particular streets.

Policy T-5.16: Prioritize safety for all users of the mobility system through the combination of design, enforcement, and education. Minimize harm through the development and implementation of a Local Road Safety Plan…

PUBLIC TRANSIT
Policy T-3.2: Ensure that access, boarding, bus stop and shelter facilities meet the needs of transit users.

Conclusion: The bus service needs to be expanded to the west of I-5. Amazing that it hasn’t been done, in light of all of the employees in the area. The bus route would most naturally connect under I-5 on the 18th/19th Street pair. We will need more space street for buses in the future if we follow Policy T-3.2. In addition, the design of a bike path should not be done at the expense of a circulation system that is currently safe and adequate. Please follow the recognized GOAL and POLICIES above. Lastly, plan now for new development but respect the needs of the current people who walk, drive, and bike in the area. Safety for all is paramount.

NEW INFORMATION
First, the Focused General Plan Update includes a Tables T1 and T2 of the NC Transportation Element from Revised Appendix B. If you search hard enough you will find this table from the Attachments in your agenda item 9.1. These tables list over 30 recently completed pedestrian and bicycle projects in our community. Not a single one of these projects required a street closure to meet the goals. Closing 19th Street is not necessary, is unequal treatment for our neighborhood, and would be very unsafe.

Second, it has just appeared for our consideration two more new pieces of information that are very pertinent to this issue. In this Focused General Plan Update there is a section in Appendix Set A that I have attached below. The last letter in the Public Comments is from Mr. Maurice Eaton of the District 11 of Caltrans. As on April 3, 2023, Mr Eaton was communicating with the City of National City that his discretionary review was still required for the work under the freeway. I believe that the City can and should make the changes I have advocated because there is still time to get the approval for new plans. We should not be locked into an unsafe and not fully considered project.

The other new information concerns a project now at the Planning Department that involves the BNSF property at 18th and 19th Streets west of Cleveland Avenue. This project is called the Fuel Transfer Facility. Not to address this new increase in traffic now, as circulation is planned to be modified in the area by the City Engineer, would be a mistake. The fuel transfer facility, much larger than a gas station, with high volumes of fuel moved through our city daily, is a project that proposes to have no odors or fumes, and protective barriers for spills, however it will be located to the west of the McKinley Apartments and the sensitive young and old residents who live there.

One thing that is certain, is the applicant’s projection for 115 trucks per day for seven days a week that will enter and exit this property. Some trucks are slated to move in the area during the night shift. These fuel trucks will be able to use the underpass to get to Wilson Avenue and the I-5 on ramps. If 19th Street is closed, the trucks will pass the apartments very closely on 18th and have potential noise, traffic conflicts, and other unforeseen risks. The trucks will share the two-way road if 18th Street is taken away.

I think I have shown you all that this “taking” in order to meet a State Grant that no one in the area wanted in the first place, is a bad idea. The hazards from these new fuel-laden vehicles on our streets is enough for you to reconsider the underpass plan.

To review, I am recommending the following change to the Focused General Plan proposed tonight:

Due to the unsafe conditions that will occur from closing 19th Street and going to two-way traffic in the other underpass, I am recommending that you make a finding that deletes from the Transportation Element and all maps and figures, the second and third bullet points above and makes appropriate changes to the Bicycle Master Plan to meet the requirements of the State grant and to provide Class I or II bicycle path in both directions under I-5 while allowing traffic to continue to use one lane in both directions.

Good evening,
Ted Godshalk
A.2 COMMENTS RECEIVED
1 Lee, Annie
From: Martin Reeder <[email protected]>
Sent: Monday, February 20, 2023 9:45 AM
To: Lee, Annie; Whitmore, Stephanie A.

Cc: Lake, Tara; Carlos Aguirre
Subject: FW: ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT SEIR comment #1
Not really related to the FGPU. This is a recently rezoned site not subject to any changes in the FGPU.

Martin
Martin Reeder | AICP
Planning Manager
Community Development Dept. – Planning Division
City of National City
1243 National City Blvd., National City, CA 91950
T: 619.336.4313 ❘ [email protected]
Website ❘ Facebook ❘ Instagram ❘ Twitter ❘ LinkedIn
From: Noel Meza, Jr. [mailto:[email protected]]
Sent: Thursday, February 16, 2023 6:31 PM
To: Martin Reeder <[email protected]>
Subject: Fwd: ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Hello Martin,
Under the Housing Strategic Plan, would the City be interested in building homes on the 16th and M site? ---------- Forwarded message ---------
From: City of National City <[email protected]> Date: Thu, Feb 16, 2023, 6:00 PM
Subject: ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT To: <[email protected]>
Review and comment by April 3 , 2023
Comment no. NM-1
2 ANNOUNCEMENT OF AVAILABILITY OF A DRAFT SUPPLEMENTAL PROGRAM

ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT FOR

NATIONAL CITY, CALIFORNIA
Proposed Project:

The City of National City invites you to comment on the draft Supplemental Program Environmental Impact Report (SPEIR) prepared for the Focused General Plan Update.

To address changes in State legislation, a changing regional context and forecasted future growth, National City is conducting a Focused General Plan Update. The Focused General Plan Update will include updates to policies and supporting updates to codes, ordinances, and development standards. Policy updates will be reflected in the Land Use Element, Transportation Element, Safety Element, and Climate Action Plan (CAP), which were last updated in 2011. The Focused General Plan update takes into account separate recent planning documents, including the 24th Street Transit Oriented Development Overlay (TODO) study. Recommendations from this predecessor planning study have been carried forward to all components of the Focused General Plan Update per City Council direction. In addition, the General Plan will be expanded to include the annexation of approximately 50 acres of the unincorporated community of Lincoln Acres into the City of National City, which was completed in 2020.

A. General Plan - Element Updates
The goals, policies, and actions in the General Plan will guide development and conservation in National City through the horizon year in 2050. These documents will supersede the current City of National City General Plan, which was last updated in 2011, and portions of the current Municipal Code.

The Land Use Element is required by State law (Government Code Section 65302). The Element designates the general distribution, location, and extent of uses of land for housing, businesses, industry, open space, etc. It is implemented through the Land Use Code (Municipal Code Title 18 Zoning), which establishes regulations for the use and development of land. The Land Use Element will be updated to reflect the City’s vision for managing the region’s growth.
3 The Transportation Element guides the City's decision making related to transportation for the future. The update will build on the focused studies and plans that were completed since the last 2011 General Plan update, including integrating findings from the Safe, Multi-modal, Accessible Routes To (SMART) Foundation Plan (2014), Downtown Specific Plan (2017), INTRAConnect (2020), Homefront to Waterfront Connectivity Study (2020), Bicycle Master Plan, Parking Plan, and Americans with Disabilities Act (ADA) Master Plan. It will also include new modelling to encompass anticipated growth in the region.

The Safety Element addresses the potential short and long-term risks of fires, floods, earthquakes, landslides, climate change, hazards, emergency services and disaster response, and other locally relevant safety issues. Due to updates in state legislation, including Senate Bill (SB) 379, which requires safety element updates to include climate adaptation and resilience strategies, and SB 1035, which requires that the Safety Element be revised no less than every eight years, the Safety Element must be updated to reflect these new requirements.

The Climate Action Plan addresses the major sources of greenhouse gas (GHG) emissions in National City and sets forth a detailed and long-term strategy that the City and community can implement to achieve GHG emissions reduction targets. It provides an updated 2018 emissions inventory and guides the City in its efforts to reduce its GHG emissions through proposing reduction targets, policies, and measures.

House National City is a new program to incentivize affordable and mixed income housing in strategic areas across the city. In exchange for affordable housing, qualifying projects receive a Floor Area Ratio (FAR) bonus.

The City also proposes to adopt updates to the zoning code, specific plan amendments, and objective design standards as a means to implement the FGPU.

B. Zoning Code Updates
Updates to regulations and development standards in National City’s zoning code to accelerate housing production in all income categories in a manner consistent with the goals of National City’s Housing Element and recent State legislation. This includes updates and revisions to floor-area ratios, maximum allowable heights, and parking requirements, as well as, updated density bonus regulations, and other incentives to increase housing production.

C. Objective Design Standards
Objective design standards developed to provide architectural and design requirements aimed at streamlining the approval process for qualifying multi-unit residential developments based on zoning, general plan land use designations, and percentages of residential use designated square footages. These standards will serve as the minimum requirements and will be mandatory for any eligible project for which a streamlined approval process is requested under state law provisions that reference objective design standards. The objective design standards will be incorporated into the municipal code.

D. Housing Strategic Plan
Four-year Housing Strategic Plan to guide the investment of the National City Housing Authority’s resources and assist the City in meeting its Regional Housing Needs Allocation (RHNA). The Strategic Plan provides recommendations to direct the agency's financial and real estate assets towards housing production. The plan identifies resources to fund the construction for 650 to 750 new units and establishes property-specific guidelines to inform future requests for proposals (RFPs) for development. The Strategic 4 Plan creates an implementation roadmap and quantifiable metrics for the National City Housing Authority to accelerate housing production within the first four years of the 6th Housing Element Cycle.

E. Specific Plan Amendments
Amending the Downtown Specific Plan and Westside Specific Plan policies, including development zones (allowed uses, densities, FARs, heights, and other development standards), design guidelines, and parking requirements to encourage housing production. The policies aim to streamline housing production for all income categories and align with updates to the Zoning Code and General Plan. Amendments to these Specific Plans center on specific conformance with recently adopted plans and those being concurrently revised through the updates to the General Plan, and do not serve to create new plans.

G. Bike Master Plan Update
Updates to the Bike Master Plan to incorporate new changes to the General Plan and other recently competed planning documents, such as the Harbor Drive Corridor Study, the INTRAConnect plan, and the 24th Street Transit Oriented Development Overlay (TODO) study. This update revises the Citywide bicycle network to guide the City in planning for a more connected, safe, and accessible network. Design guidelines will be updated to align with current best practices and City plans. The plan will identify priority projects for implementation and will update recommendations for programs for education, bicycling encouragement, enforcement, and evaluation. Estimated network costs and resources to fund construction will be identified.

Public Review Period: The 45-day public review period for the SPEIR begins on Friday, February 17, 2023 and ends on Monday, April 3, 2023.

Where to find the SPEIR: The SPEIR is available at the Planning Division (1243 National City Blvd, National City, CA 91950) at the public counter. The report can also be accessed from the City website: https://www.nationalcityca.gov/fgpu.

Pursuant to CEQA Guidelines Section 15082, responsible and trustee agencies and other interested parties, including members of the public, must submit any comments in response to this notice to later than 6:00 p.m. on April 3, 2023. Please include your name, address, and contact information in your correspondence to Martin Reeder, AICP, Principal Planner at [email protected]. Written comments can also be mailed to the Planning Division (Attn: Planning Division, Focused General Plan Update, 1243 National City Blvd, National City, CA 91950) postmarked no later than April 3, 2023.

Focused General Plan Update
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1 Lee, Annie
From: Martin Reeder <[email protected]>
Sent: Monday, February 20, 2023 9:46 AM
To: Lee, Annie; Whitmore, Stephanie A.

Cc: Lake, Tara; Carlos Aguirre; Whipple, Ryan O.; Roberto Yano Subject: FW: ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT SEIR comment #2
Thanks,
Martin
Martin Reeder | AICP
Planning Manager
Community Development Dept. – Planning Division
City of National City
1243 National City Blvd., National City, CA 91950
T: 619.336.4313 ❘ [email protected]
Website ❘ Facebook ❘ Instagram ❘ Twitter ❘ LinkedIn
From: Zulma Santana (OW - School Principal) [mailto:[email protected]] Sent: Friday, February 17, 2023 6:31 AM
To: Martin Reeder <[email protected]>
Subject: Re: ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Thank you ! Greatly appreciated. Our families, students and staff have concerns on the crossing of 24th and F street. They are concerned of how dangerous it is for students and families to cross the street and report many almost hits. Can you look into it?
On Thu, Feb 16, 2023 at 6:00 PM City of National City <[email protected]> wrote:

Review and comment by April 3 , 2023
Comment no. ZS-1
2 ANNOUNCEMENT OF AVAILABILITY OF A DRAFT SUPPLEMENTAL PROGRAM

ENVIRONMENTAL IMPACT REPORT FOR PUBLIC REVIEW AND COMMENT FOR

NATIONAL CITY, CALIFORNIA
Proposed Project:

The City of National City invites you to comment on the draft Supplemental Program Environmental Impact Report (SPEIR) prepared for the Focused General Plan Update.

The City also proposes to adopt updates to the zoning code, specific plan amendments, and objective design standards as a means to implement the FGPU.

Public Review Period: The 45-day public review period for the SPEIR begins on Friday, February 17, 2023 and ends on Monday, April 3, 2023.

Focused General Plan Update
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Thank you,
Zulma Santana
Zulma Santana
Principal
Olivewood Elementary School
National School District
Ph: (619) 336-8750
Creating Successful Learners NOW....

NSD Staff Account
1 Lee, Annie
From: Martin Reeder <[email protected]>
Sent: Monday, March 20, 2023 2:16 PM
To: Whitmore, Stephanie A.; Lee, Annie
Cc: Lake, Tara
Subject: FW: City of National City Safety Element Update FYI
Martin Reeder | AICP
Planning Manager
Community Development Dept. – Planning Division
City of National City
1243 National City Blvd., National City, CA 91950
T: 619.336.4313 ❘ [email protected]
Website ❘ Facebook ❘ Instagram ❘ Twitter ❘ LinkedIn
From: Washington, Terrance@CalOES [mailto:[email protected]] Sent: Monday, March 20, 2023 1:37 PM
To: Martin Reeder <[email protected]>
Cc: CalOES Mitigation Planning <[email protected]> Subject: City of National City Safety Element Update
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Good Afternoon
Cal OES has reviewed the Safety Element Update to the General Plan. Our office has a couple of comments.

The Safety Element addresses the following Natural hazards:
 Earthquake
 Landslide
 Liquefaction
 Flooding
 Dam Failure
 Tsunami
 Coastal Storms
 Coastal Erosion
 Urban Fire
 Wildfire
 Climate Change
When reviewing your most recently submitted draft 2023 Local Hazard Mitigation Plan, we found that the identified hazards are as follows:

Comment no. TW-1
2 • Earthquake
• Wildfire
• Dam Failure
• Floods
• Structure Fires
• Tsunami
Below Is the link to the California Office of Planning and Research Safety Element Guidelines General Plan Guidelines, Chapter 4: Required Elements (ca.gov) Required Contents the safety element must, consistent with Government Code Section 65302(g), provide for the protection of the community from any unreasonable risks associated with the effects of:
• Seismically induced surface rupture, ground shaking, ground failure • Tsunami, seiche, and dam failure
• Slope instability leading to mudslides and landslides • Subsidence
• Liquefaction
• Other seismic hazards identified pursuant to Chapter 7.8 (commencing with Section 2690) of Division 2 of the Public Resources Code, and other geologic hazards known to the legislative body • Flooding
• Wildland and urban fires
• Climate change
Thank you for the opportunity to review and comment.

Siempre,
Terrance Washington, Emergency Services Coordinator
Local Hazard Mitigation Planning
Recovery - Hazard Mitigation Assistance Branch
California Governor’s Office of Emergency Services
Cell: 916-917-4540
Desk: 916-636-2945
[email protected]
www.caloes.ca.gov/Mitigation
Comment no. TW-2
DEREK R. GADE

INTERIM DIRECTOR

DEPARTMENT OF PUBLIC WORKS
5510 OVERLAND AVENUE, SUITE 410
SAN DIEGO, CA 92123-1237
(858) 694-2212
www.sdcounty.ca.gov/dpw/
March 23, 2023
Mr. Martin Reeder
National City Planning Division
1243 National City Blvd.

National City, CA 91950

DRAFT SUPPLEMENTAL PROGRAM ENVIRONMENTAL IMPACT REPORT FOR PUBLIC

REVIEW AND COMMENT FOR NATIONAL CITY, CALIFORNIA
Dear Mr Reeder:

Please find below two general comments from The County of San Diego Department of Public Works Traffic Division:
1) The City's Focused General Plan Update (FGPU) will include their Transportation Element. Sweetwater Road and Bonita Road are County Mobility Element roads that traverse both the County and the City's jurisdictions. As part of the City's FGPU effort and public outreach, City staff should coordinate closely with County staff for any proposed plans related to Sweetwater Road and Bonita Road's Mobility Element classification and near-term and long-range road design. The County will want to ensure compatibility and consistency between the City and the County's roadway design and conformance with the County's Public Road Standards.
2) The Sweetwater Community Planning Group should be part of the City's FGPU public outreach effort and a key stakeholder.

Please let me know if you have any questions. My contact information is Sue Waters, [email protected].

Sue Waters
County of San Diego
Department of Public Works
Land Use/Environmental Planning Manager
Environmental Services Unit
5510 Overland Avenue, Ste. 410
San Diego, CA 92123-1239
(619) 372-2533
Mail Stop O-332
Comment no. SW-1
Comment no. SW-2
1 [email protected] | D 619-
301-0456
April 3, 2023
Via E-mail: [email protected]
Martin Reeder, Planner
City of National City
1243 National City Blvd.

National City, CA 91950

SUPPORT FOR CITY OF NATIONAL CITY FOCUSED GENERAL PLAN UPDATE

SUPPLEMENTAL ENVIRONMENTAL IMPACT REPORT ENVIRONMENTALLY

SUPERIOR ALTERNATIVE
Dear Mr. Reeder:

My firm represents the Webster Trust, owners of the property located at 121 E. 27th Street, National City, CA 91950 (“Property”). We have reviewed the draft Supplemental Environmental Impact Report (“SEIR”) for the Focused General Plan Update (“FGPU”) and the analyzed proposed project (“Project”). The Property and addresses 202 E. 26th Street, 190 E. 26th Street and 199 E. 27th Street are delineated on Figure 8.3-2, SEIR p. 8-7 as the Alternate Project Location Alternative (“APLA”). The SEIR concludes that the APLA is the Environmentally Superior Alternative and we support this conclusion.

We request the City consider the issues raised in this comment letter and revise the SEIR to strengthen and clarify the SEIR. We urge City decision makers to support staff’s decision that the APLA is the Environmentally Superior Alternative and approve the SEIR.

I. Residential Zoning
The SEIR proposes rezoning the APLA properties from commercial to high density multiunit residential (RM-2) zoning. The City’s Transit Oriented Development Overlay Plan (“TODO”) also recommends that the properties be rezoned to residential. In comparison to the Project, the APLA could provide 119 additional residential units. RM2 is appropriate for the APLA properties because properties to the north and east are also zoned RM-2 as with additional residential properties close to Sweetwater High Comment no. CMR-1
Comment no. CMR-2
2 School. Therefore, such high density multiunit zoning is not inconsistent with other adjacent properties. Also, the majority of the surrounding property uses are residential.

The Property is set back a block from commercial uses along National City Boulevard.

Furthermore, the Property is large at 1.86 acres and relatively flat with no existing buildings; it is a prime candidate for redevelopment. The large size will allow for largescale redevelopment without requiring assemblage of any smaller lots. This will make redevelopment less costly and more efficient. The Property can support a design that includes dense residential while respecting the continuation of commercial uses to the west. We urge the City to rezone the APLA properties to RM-2 residential zoning.

II. Hazardous Waste Not Present on Property
The SEIR erroneously states that there is hazardous waste on the properties of the APLA properties. The Property has never been the site of a hazardous waste cleanup and we do not believe hazardous waste exists on the Property. We are unaware if the other three APLA properties have hazardous waste. However, the SEIR itself seems to indicate they do not. The SEIR’s GeoTracker Hazardous Waste Site map does not show either an open or closed hazardous waste case on any of the APLA properties.

See Figure 4.5-1 GeoTracker Hazardous Waste Sites, SEIR p. 4.5-3. The map does appear to reflect open Hazardous Waste Sites for properties adjacent to the APLA properties along D Avenue to the east.

If the SEIR has mis-identified the APLA properties as having hazardous waste, then the SEIR’s comparison of the APLA to the Project is wrong. See Table 8.4-1 Alternative Significance Comparison SEIR p. 8-8. The table states the APLA has significant impacts the same as the Project because a hazardous waste site is part of the APLA.

SEIR Section 8.4.2.5 repeats the claim. See SEIR p. 8-15. We know this statement is erroneous for the Property. We urge the City to verify if the other APLA properties have hazardous waste sites. If the APLA properties do not have hazardous waste sites, then the APLA would have less significant impacts on hazardous waste than the Project.

Therefore, the APLA would have another reason to be chosen as the Environmentally Superior Alternative to the Project.

III. Noise Impacts
The SEIR is inconsistent in how it treats the APLA’s noise impacts in comparison to the Project. Since the Project includes the 24th Avenue Transit Station (“Transit Station”), which is within 500 feet of the I-5 freeway, noise impacts are reduced under the APLA since it does not include the Transit Station and is not located near the freeway. Noise reduction is identified as a lesser impact for the APLA under SEIR Section 8.3.2.1 and in Table 8.4-1 but not under Section 8.4.2. See SEIR p. 8-13. Section 8.4.2 provides the Environmental Analysis for the APLA and it should identify that in addition to air quality, noise reduction will also result in less impacts for the APLA. We believe noise reduction is another strong reason for the City to choose the APLA as the Environmentally Comment no. CMR-3
Comment no. CMR-4
3 Superior Alternative and we urge a strong and consistent analysis of noise reduction throughout the SEIR.

IV. Traffic Impacts
The SEIR identifies that the vehicle miles traveled (“VMT”) between the Project and the APLA do not differ significantly and traffic impacts are less than significant for both. We agree with this analysis. The APLA properties are in a prime location for walkability and supported by transit. The TODO identifies the properties are in a Transit Priority Area with major transit options surrounding them. See TODO p. 81. It is only a short seven block walk to the Transit Station. Also, numerous bus stops are within 1,000 feet walking distance to the east along D Avenue and near Sweetwater High School.

Like the Transit Station, the APLA properties have numerous multi-modal mass transit options available. Therefore, the SEIR correctly identified that traffic impacts are less than significant for the Project and the APLA. The lack of significant traffic impact for the APLA is another reason to support the APLA as the Environmentally Superior Alternative.

V. House National City Support
We also support the House National City plan being considered by the City simultaneously with the FGPU and SEIR. Planning Consultant to the Webster Trust, Joseph Smith, submitted a letter to the Planning Commission’s Housing Advisory Committee on February 6, 2023 analyzing and providing feedback for the House National City plan. See Exhibit A. We believe that the House National City plan, along with the FGPU, will allow the City to incentive high density housing and encourage redevelopment of underutilized properties throughout the City.

We urge the City’s decision makers to direct staff to implement our proposed changes to the House National City plan and incorporate those changes through revisions to the SEIR.

Comment no. CMR-5
Comment no. CMR-6
4 VI. Conclusion
We request the City consider the issues raised in this comment letter and revise the SEIR to strengthen and clarify the SEIR. We urge City decision makers to support staff’s decision that the APLA is the Environmentally Superior Alternative because it has less impacts to air quality and noise than the Project. We urge the City to analyze if the APLA also has less impacts than the Project to hazardous waste. The fact that the APLA can also provide more housing than the Project should be considered. We urge the City to approve the FGPU and the SEIR with our revisions.

Sincerely,

CYNTHIA MORGAN-REED
Cc: Tara Lake - via email
Lara Gates – via email
Joseph Smith- via email
Comment no. CMR-7
5 Exhibit A
House National City Plan Comment Letter
6 7
April 3, 2023
RE: EHC’s Comments on the City’s Focused General Plan Update (FGPU) EHC’s goal in engaging with the Focused General Plan Update is to ensure the very best outcomes for the City’s existing residents, particularly within Old Town National City. We have attended all project workshops to date and actively engaged with City staff. We appreciate the land use data, interactive tools and information presented by the city and EHC has been actively engaging with Old Town residents to participate in the process. After reviewing the documents, it is evident that development throughout National City is a priority in the FGPU. We recognize that environmental concerns are raised and addressed in the FGPU, but we urge the city to remain diligent in monitoring the impact development will have on the surrounding communities. After review, we want to uplift the following elements of the Focused General Plan Update with our comments:

Comments and Recommendations:

Housing, Land Use, and Air Quality
 The updates suggest an increase in housing throughout the city, prioritizing an increase in housing in areas that have access to transit and other resources. The development of any future housing must consider the pollution caused by development, and implement mitigations to address increasing pollution and the air quality in National City – specifically the Westside where communities are already overburdened with pollution.  Site apartment units as far as possible from the source of air pollution.  Double glaze all windows in the housing units to reduce exposure to air pollution.  Avoid or limit the placement of balconies on the side of the building facing the freeway/high volume roadway.
 Install MERV 13 filters (or above) on the air handling units for the HVAC system and replace them on a quarterly basis or whatever basis is recommended by the filter/HVAC system manufacturer. Identify who will replace the MERV filters, ensure that personnel are trained on their responsibilities, and conduct regular inspections to ensure that filters are being replaced as recommended.
 Locate outdoor air intakes for the HVAC system as far as possible from the freeway/roadway, the freeway off-ramp, and the parking area.  Maximize the sound transmission co-efficient (STC) for the interior/exterior walls to limit indoor noise and air pollution.
 Design buildings with varying shapes and heights to help break up air pollution emission plumes, increase airflow, and help reduce pollutants such as particulates and noise.  Plant additional trees on neighborhood streets surrounding the housing development to further mitigate air pollution.

Comment no. KG-1
Comment no. KG-2
 Encourage occupants to use zero-emission vehicles by providing preferential parking for these vehicles and by providing charging stations.
 Provide bicycle parking and parking spaces for car-sharing programs.

Climate Action Plan
 As recognized in the 2023 update, in order for National City to align with the statewide goals of GHG emission reductions the city would need to decrease the 2018 baseline 40% by 2023 and 80% by 2050. The plan suggests reductions in VMT and encourages residents and businesses to take alternative methods of transportation and use zeroemission vehicles. The encouragement from the city alone will not be enough to see a large enough shift needed to yield sufficient results. Therefore, we recommend that the city should ensure that alternative transportation methods are widely known and accessible to the community, and require new businesses to use ZEVs and require existing businesses to transition to ZEVs. This should be enforced and monitored diligently and the city must be prepared to have the necessary infrastructure to support the use of zero emission vehicles. As stated, the GHG emissions from residential and commercial/industrial increased since 2011 due to residential and economic growth. If the growing population of the city will result in higher GHG emissions, mitigations need to be not just encouraged, but also enforced.
 At a city level, work on not only encouraging but educating and incentivizing the transition to ZEVs at both an individual and commercial level.  As a city, be prepared to invest in the necessary infrastructure needed to accommodate zero emission vehicles.

Thank you for your time,
Kelsey Genesi
National City Policy Advocate
Environmental Health Coalition
Comment no. KG-3
Comment no. KG-4
“Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 11
4050 TAYLOR STREET, MS-240
SAN DIEGO, CA 92110
(619) 709-5152 | FAX (619) 688-4299 TTY 711
www.dot.ca.gov
April 3, 2023
11-SD-5
PM 10.4
National City Focused General Plan Update/Supplemental DEIR SCH 2010051009
Mr. Martin Reeder,
City of National City
1243 National City Blvd.

National City, CA 91950
Dear Mr. Reeder:

Thank you for including the California Department of Transportation (Caltrans) in the Supplemental DEIR review process for the National City Focused General Plan Update, located near State Route I-5. The mission of Caltrans is to provide a safe and reliable transportation network that serves all people and respects the environment. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities.

Safety is one of Caltrans’ strategic goals. Caltrans strives to make the year 2050 the first year without a single death or serious injury on California’s roads.

We are striving for more equitable outcomes for the transportation network’s diverse users. To achieve these ambitious goals, we will pursue meaningful collaboration with our partners. We encourage the implementation of new technologies, innovations, and best practices that will enhance the safety on the transportation network. These pursuits are both ambitious and urgent, and their accomplishment involves a focused departure from the status quo as we continue to institutionalize safety in all our work.

Caltrans has the following comments:

Traffic Analysis

2.3.2 Key Transportation Network Changes
• Closure of 19th Street under Interstate 5 (I-5)
• Conversion of 1-way to 2-way traffic on 18th Street under I-5 Comment no. ME-1
Mr. Martin Reeder
April 3, 2023

Page 2 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment” Please continue coordinating with Caltrans on the proposed street closure of 19th Street and roadway modification to 18th Street under I-5.

Complete Streets
Caltrans views all transportation improvements as opportunities to improve safety, access, and mobility for all travelers in California and recognizes bicycle, pedestrian, and transit modes as integral elements of the transportation network. Caltrans supports improved transit accommodation through the provision of Park and Ride facilities, improved bicycle and pedestrian access and safety improvements, signal prioritization for transit, bus on shoulders, ramp improvements, or other enhancements that promote a complete and integrated transportation network.

Caltrans released the “Contextual Guidance for Bike Facilities” Memorandum in March 2020 to identify the preferred bikeway facility type in areas where bikeway facility installations are planned. Please utilize this guidance memorandum as a tool for selecting the most appropriate bicycle facility type in locations where improvements are proposed in Caltrans’ right-of-way.

The following is a link to the “Contextual Guidance for Bike Facilities” Memorandum: https://dot.ca.gov/-/media/dotmedia/programs/transportation-planning/documents/office-of-smart-mobilityand-climate-change/planning-contextual-guidance-memo-03-11-20- a11y.pdf.

Noise
The applicant must be informed that in accordance with 23 Code of Federal Regulations (CFR) 772, the Department of Transportation (Caltrans) is not responsible for existing or future traffic noise impacts associated with the existing configuration of I-5, and State Route 54 (SR-54).

Broadband
Caltrans recognizes that teleworking and remote learning lessen the impacts of traffic on our roadways and surrounding communities. This reduces the amount of VMT and decreases the amount of greenhouse gas (GHG) emissions and other pollutants. The availability of affordable and reliable, highspeed broadband is a key component in supporting travel demand management and reaching the state’s transportation and climate action goals.

Comment no. ME-2
Comment no. ME-3
Comment no. ME-4
Mr. Martin Reeder
April 3, 2023

Page 3 ends

“Provide a safe and reliable transportation network that serves all people and respects the environment” Right-of-Way
Any work performed within Caltrans’ Right of Way (R/W) will require discretionary review and approval by Caltrans. As part of the encroachment permit process, the applicant must provide an approved final environmental document, corresponding technical studies, and necessary regulatory and resource agency permits, specifically, any CEQA determinations or exemptions.

If you have any questions or concerns, please contact Roger Sanchez, LDR Coordinator, at (619) 987-1043 or by e-mail sent to roger.sanchez[email protected].

Sincerely,
Maurice A. Eaton

MAURICE EATON
Branch Chief
Local Development Review
Comment no. ME-5
From: [email protected] on behalf of eSCRIBE.Admin To: Shelley Chapel
Subject: Public Comment Approval Request
Date: Tuesday, June 20, 2023 3:53:23 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

User Ted Godshalk has enter the following comment(s):

I believe it is important to include community members on an interview committee for our next City Manager. This process will allow for a diversity of opinions and hopefully lead the hiring of a person who is responsive to the real needs of the community. for Verbal Report-Out of Salary and Benefits in the Employment Agreement of the Interim City Manager as required by the Brown Act in Regular City Council Meeting 6/20/2023 6:00:00 PM
Please log into eSCRIBE to review the submitted comment(s).

From: Jacqueline Luna Reynoso
To: Public Comment
Subject: Public Comment Cannabis Licences Item 10.

Date: Tuesday, June 20, 2023 3:40:23 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

BCD and Cali Mota, the only publicly known and local owner social equity applicants, are demanding a fair and transparent evaluation process. Cali Mota ownership is the only cannabis business with all BIPOC women owners, lifetime residents of National City and South County and with the requisite experience to run a cannabis operation. Cali Mota scored 94%, filed for a hearing to rescore our application, but was denied additional points. Our writ mandate, which will be made a public document, outlines the clear negligence in the process and scoring We want resolution to our legal proceeding before the City moves to approve 3 additional cannabis licenses.

1. First, we demand expedient resolution of pending lawsuits before awarding more cannabis agreements.

2. The City has awarded "local owner" bonus points to the top 6 firms. However, to date, their "local" status has not been validated. Mayor Ron Morrison and Councilmember Ditas Yamane have raised this concern. Nonetheless, 3 agreements have been issued to top scorers, and now they are considering the next 3, without proper validation. Pause the review process to validate local ownership, rescore, and re-rank.

3. We find the city's behaviour to agendize this item on Tuesday, June 20th is egregious for its lack of transparency and disregard for the legal and administrative process.

5. If the law suits are upheld in court, and the city has moved ahead with issuing new licences, now the city has to expend additional resources to remedy what could have been addressed administratively, and timely.

6. Uphold the City's reputation as a leader in social equity. The City is dismissing the need to address current legal claims from its own residents, first, essentially squeezing them out of an opportunity to invest in their community, and favoring outside corporate interests that are known to game the system and prey on locals.

Sincerely,
Cali Mota
--
Jacqueline L. Reynoso
MPP, 2006
John F. Kennedy School of Government
Harvard University
(619)890-6614
From: Ted Godshalk
To: Public Comment
Subject: Public comment from Mr. Ted Godshalk for item 10.2 on 6/20/2023.

Date: Tuesday, June 20, 2023 3:03:17 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

Public comment from Mr. Ted Godshalk for item 10.2 on 6/20/2023.

Council,
I am against the issuance of any agreements for Cannabis in our city at this time. My neighborhood will be impacted by the numerous negative consequences including noise, illegal drug use in vehicles, increased traffic violations, the public sale and use of drugs. The City of National City may incur unforeseen costs and possible reduction in services due to its endorsement of Cannabis. Please place a hold on all agreements in our community.

Ted Godshalk
From: [email protected] on behalf of eSCRIBE.Admin To: Shelley Chapel
Subject: Public Comment Approval Request
Date: Tuesday, June 20, 2023 3:31:13 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

User Ted Godshalk has enter the following comment(s):

Please explain the accounting deficiencies in the Audit Findings at the end of the the powerpoint report and the safeguards that will be implemented in the future. for City of National City Annual Comprehensive Financial Report (ACFR) for the Fiscal Year Ended June 30, 2022. in Regular City Council Meeting 6/20/2023 6:00:00 PM Please log into eSCRIBE to review the submitted comment(s).

From: [email protected] on behalf of eSCRIBE.Admin To: Shelley Chapel
Subject: Public Comment Approval Request
Date: Tuesday, June 20, 2023 3:31:19 PM
CAUTION: This email originated from outside your organization. Exercise caution when opening attachments or clicking links, especially from unknown senders.

User Ted Godshalk has enter the following comment(s):

At an earlier Budget meeting, I made the comment that the title of the expenditure as "District Budget" was incorrect and it should be instead called "Council and Mayor Department." I also said the idea of equity in this matter should be discussed as policy first. That was not done.

Now that the Council has posted a $400,000 increase for their operations, it is even more important that fair purposes be laid out in policy. I think that council members should be more careful with our money.
for Resolution of the City Council of the City of National City Adopting a Budget for Fiscal Year 2024 in Regular City Council Meeting 6/20/2023 6:00:00 PM Please log into eSCRIBE to review the submitted comment(s).

National City City CouncilJune 20, 2023

National City City Council
June 20, 2023