November 18, 2024
Kim Stater, Assistant Community Development Director
City of Highland
27215 Base Line
Highland, California 92346
LAFCO
Dear Ms. Stater:
Please accept the following comments from the Local Agency Formation Local Agency Commission for San Bernardino County (LAFCO) on the Notice of Intent (NOI) Formation Commission to Adopt a Mitigated Negative Declaration for the Southeast Corner 5'h Street for San Bernardino County and Victoria Avenue Warehouse Project. LAFCO will be acting as a Responsible Agency under the California Environmental Quality Act (CEQA) for this project, which will require the Commission to review and consider a reorganization proposal and companion spheres of influence amendments.
The following are the LAFCO comments, concerns, and/or questions:
1.1 Project Overview
COMMISSIONERS Page 1: When listing the approvals for the project, it might be appropriate to separate the items related to the City's approval and the items related to LAFCO. Note that this project will require the following LAFCO actions:
• Sphere of influence amendments for the City of Highland (expansion), City of San Bernardino (reduction), and San Bernardino County Fire Protection District (reduction).
• Annexation to the City of Highland and detachments from the City of San Bernardino, the San Bernardino County Fire Protection District (SBCFPD), SBCFPD Valley Service Zone, and SBCFPD Service Zone FP-5.
amendments and the proposed reorganization (annexation/detachments) area
ALTERNATES
not only includes the parcel itself but also its adjacent road right-of-way along 5th Street and Victoria Ave. In addition, because the San Bernardino County Fire Protection District (County Fire) serves the City of San Bernardino, the detachment from the City of San Bernardino will also require the detachment from County Fire since the City of Highland has its own fire service.
It is suggested that the last sentence be revised to say, "A portion of the project-APN 1192-551-01 and its adjacent southerly road right-of-way along 5th Street and its adjacent easterly road right-of-way along Victoria Avenues currently within the City of San Bernardino. In order to place this said portion into the City of Highland's jurisdiction, it will require amendments of the spheres
EXECUTIVE OFFICER
of influence for the City of Highland (expansion), the City of San Bernardino (reduction) and the San Bernardino County Fire Protection District (reduction) and a reorganization to include annexation to the City of Highland and detachments from the City of San Bernardino, and the San Bernardino County Fire Protection District and its Service Zones, requiring approval by the Local LEGAL COUNSEL Agency Formation Commission (LAFCO). APN 1192-551-01 and its adjacent FAUCA DE SOUSA road rights-of-way total approximately 0.95' acres." ' Note: Verify the actual acreage of the parcel including its adjacent road rights-of-way.
LAFCO Comment Letter
NOI to Adopt MND for 5th Street & Victoria Ave Warehouse Project
Airport (SBIA)".
should probably not be referenced here.
2.3 Project Characteristics
Sanitary Sewer, Page 5: As noted in the discussion related to wastewater treatment under Utilities and Service Systems (Item c, last paragraph, page 115), the Sterling WWTP is now operational; therefore, the discussion regarding wastewater treatment should be revised.
CCB flows into Twin Creek and then Twin Creek flows into the Santa Ana River.
2.4 Project Construction and Phasing
revised to reflect current dates.
2.5 Project Approvals
section since the list outlines the approvals by the City as the Lead Agency. Regarding approval of the sphere amendments and the reorganization (annexation/detachments), LAFCO will be acting as Responsible Agency under CEQA.
Initial Study Checklist
identify the LAFCO actions which include the sphere of influence expansion for the City of Highland, sphere of influence reductions for the City of San Bernardino and San Bernardino County Fire Protection District, and the reorganization to include annexation to the City of Highland and detachments from the City of San Bernardino, the San Bernardino County Fire Protection District, its Valley Service Zone, and its Service Zone FP-5. It should also be clearly identified that the sphere of influence amendments and the proposed reorganization area not only includes the parcel itself but also its adjacent road right-of-way along 5th Street and Victoria Avenue.
Valley Water District sanitary sewer system.."
Airport..."
recommended that the project be required to implement a construction traffic management plan as mitigation to ensure emergency access is maintained.
LAFCO Comment Letter
NOI to Adopt MND for 5th Street & Victoria Ave Warehouse Project
the IVDA/SBIAA own the channel south of 3rd Street. If any encroachment occurs south of 3rd, the IVDA/SBIAA must be contacted for an encroachment permit.
it might be appropriate to insert "former" before Norton. Also, what data is the finding in the paragraph based upon, i.e., what substantiation.
side of 3rd Street, authorization would need to be obtained from the IVDA/SBIAA.
regarding the sphere of influence amendments (expansion/reductions) and the reorganization that include annexation and detachments.
reduction of San Bernardino County Fire Protection District (County Fire), and the detachment of County Fire and its Service Zones.
County Fire.
needed here? If not, why not?
that the East Valley Water District is now the wastewater treatment provider since its Sterling WWTP is now operational, as noted on the second paragraph.
LAFCO Comment Letter
NOI to Adopt MND for 5th Street & Victoria Ave Warehouse Project
Thank you for allowing LAFCO to provide comments to the NOI. By addressing these comments, LAFCO believes the Initial Study/MND will provide sufficient substantiation to support the LAFCO decisions as a CEQA Responsible Agency.
If you have any questions concerning the information outlined above, please do not hesitate to contact me at (909) 388-0480. Please maintain LAFCO on your distribution list to receive further information related to this process. We look forward to working with the City on its future processing of this project.
Sincerely,
strating
SAMUEL MARTINEZ
Executive Officer
CC: Tom Dodson, Tom Dodson and Associates, LAFCO Environmental Consultant Carlos Zamano, City Manager, City of Highland
Rochelle Clayton, City Manager, City of San Bernardino
Martin Serna, Deputy Chief of Operations, San Bernardino County Fire Protection District (County Fire)
Bertral Washington, Deputy Chief of Administration, County Fire Gary Jager, Assistance Chief, Division 1 (East Valley), County Fire