1 Response to Wiley Canyon Project Appeal Letter, dated Sept. 30, 2025 Letter to City Clerk regarding Appeal of Wiley Canyon Mixed Use Project, dated September 30, 2025
Response 1
The comment makes claims that are not support ed by facts or other information. Specifically, no fact or evidentiary support is provided for the claims that the City of Santa Clarita Valley (City) and its Planning Commission have “ disregard[ed] mandatory local and state requirements ” and “ignore[d] … compliance with City and State planning obligations and requirements, including the City’s General Plan.” The comment also does not specify what requirements were supposedly disregarded or ignored, so it is impossible to provide more detailed responses at thi s time. The comment is part of the record and made available to the decision makers prior to making a final decision on the proposed project.
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Response 2
The comment expresses appellants ’ opinion that the Wiley Canyon project, approved by the Planning Commission, should be denied by the City Council. The comment will be part of the record and made available to the decision makers prior to making a final decision on the proposed project.
Response 3
This comment expresses opinions that are not supported by references to the record of this project.
Further, the comment does not address the adequacy of the project or environmental analysis, and therefore, no further response can be provided. Nonetheless, the comment will be part of the record and made available to the decision makers prior to making a final decision on the proposed project.
Response 4
This comment expresses opinions that are not supported by references to the record of this project.
Moreover, the comment does not address the adequacy of the project or environmental analysis; and therefore, no additional response can be provided.
Response 5
The comment cites the City ’s appeal procedures/standards and concludes generally that the City has “violated the letter and spirit of” the four appeal grounds specified in Section 17.07.040 of the Santa Clarita Valley Municipal Code, but does not support any ground with facts or evidence. The comment will be part of the record and made available to the decision makers prior to making a final decision on the proposed project.
Response 6
The comment claims generally that the City ’s determinations regarding the project are “counter ” to a list of laws and regulations, but the comment provides no facts or evidence to support the general claim. Therefore, no further response can be provided. Nonetheless, the comment will be 2 part of the record and made available to the decision makers prior to making a final decision on the proposed project.
Response 7
The comment states that the City has ignored and not enforced General Plan Circulation Element C-27 “by requiring the developer to build a 4-lane arterial highway on Wiley Canyon Road.” The comment adds that the developer has “bragged ” about not needing to comply with Circulation Element C-27, but the comment does not provide any factual or evidentiary support for its claims.
The comment concludes that the City has required “ all prior owners of the subject parcels to set aside land in support of a 4- lane arterial highway,” but again, no factual or evidentiary support is provided.
The comments are inaccurate for several reasons.
First, the topic was extensively addressed in the City’s environmental documents for this project.
For example, the Draft EIR’s project description makes clear that the project as proposed does not propose to construct a 4-lane arterial highway on Wiley Canyon Road, but instead, would install off-site traffic circulation improvements on Wiley Canyon Road and Calgrov e Boulevard, including new roundabouts, traffic signals, Class I and II bike lanes, and pedestrian trails. ( See Draft EIR, Section 3, Project Description, pp. 3- 4, 3-9-10, Fig. 3-3.) At present, Wiley Canyon Road is 2 lanes along the Project frontage to Calgrove Boulevard with no signalized intersections along this segment of the roadway. (Final EIR, Topical Response No. 3.) Second, the City’s Circulation Element (June 2011), page C-27, lists future roadway improvements to implement the recommended the City ’s long -term Highway Plan, and those future improvements list widening Wiley Canyon Road certain segments from 2 lanes to 4 lanes .
However, based on the Project ’s traffic assessment, the Project would generate approximately 3,500 daily trips, and the Circulation Element had assumed that build-out of the Project site would generate approximately 27,000 daily trips, which resulted in the City ’s long-term designation of Wiley Canyon Road as a four-lane roadway in the Circulation Element.
Third, the Circulation Element does not contain any mandatory Circulation Element goal, policy, or objective requiring such widening improvements or requiring the Project to construct such improvements.
Fourth, vehicle miles traveled (VMT) is the relatively new metric for evaluating a project ’s significant traffic impacts, and while the General Plan includes long -term build-out assumptions for certain roads, including Wiley Canyon Road, projects that increase roadway capacity (by improving roads from 2-to-4 lanes) must then consider potential impacts of inducing more travel and therefore, increasing VMT leading to greater greenhouse gas (GHG) emissions. By not requiring the widening of Wiley Canyon Road, due in part to lower daily trips from the Project, the Project avoids induced impacts, increased VMT, and greater GHG emissions.
Fifth, the City does not have the requisite “ essential nexus” or connection between the Project ’s traffic impacts and requiring as mitigation or a condition a large-scale road widening project such as the widening of a segment of Wiley Canyon Road from 2-to-4 lanes. In short, there must be a direct causal link or connection between a project ’s identified significant impact on the 3 environment and the mitigation measure or condition imposed on the project applicant. Such mitigation or condition is only legitimate if it addresses an impact that is the result of the project itself. This Project’ s daily trips do not provide the link needed to impose a large -scale road widening mitigation measure or condition. Further, the CEQA nexus requirement (see CEQA Guidelines section 15126.4(a)(4)) is coupled with a “ rough proportionality ” constitutional requirement addressing the nature, scope, and extent of a project’s identified impacts. This “rough proportionality” requirement also precludes the City from imposing on the Project a requirement condition to widen a segment of Wiley Canyon Road from 2-to-4 lanes.
Sixth, the Final EIR has already demonstrated that traffic volumes, including the current and expected future traffic volumes, plus the Project ’s traffic volumes, along this portion of Wiley Canyon Road and Calgrove Boulevard would be between 9,000 and 10,000 vehicle trips per day.
This volume is well below the maximum capacity of a 2- lane roadway, which has a m aximum capacity of 16,000 to 18,000 vehicle trips per day. Due to the significantly lower daily trips generated by the Project (3,500 daily trips) than is contemplated by the General Plan (27,000 daily trips) for this Project site, no nexus or proportionality can be established between the Project and build-out of a 4-lane roadway.
Based on the projected future traffic volumes, including the Project trips, it is not anticipated that this portion of Wiley Canyon Road will reach the need to be 4 lanes because these anticipated volumes fall well within the maximum capacity of a 2- lane roadway. As part of the P roject, dedication and acquisition of right -of-way will be necessary to accommodate the improvements identified in the Project ’s t raffic study. Nevertheless, the City ’s Traffic and Transportation Planning Division reviewed the proposed right -of-way width of Wiley Canyon Road and determined that, in the unlikely event 4 lanes ever becomes necessary in the future, Wiley Canyon Road could be de signed to accommodate 4 lanes along with sidewalks on both sides, even at its narrowest section measuring 53 feet. This measurement was confirmed by both the City’s engineer and the Project applicant’s engineer.
(See Final EIR, Topical Response No. 3; and see Response to SCOPE comment letter, dated April 15, 2024, Response 03-05.)
Response 8
The comment states that the Final EIR “ failed to address” 1,000 pages of comments on the Draft EIR, but the comment does not cite any particular response that is “ inadequate” under CEQA or the CEQA Guidelines.
The Final EIR, Table 2-1 identifies the 60 comment letters that the City received in response to the Draft EIR. The City has provided both Topical Responses and individual written responses addressing the environmental issues raised in those comment letters. The comment does not point to any response that is allegedly inadequate, and therefore, no further response can be provided.
Nonetheless, the comment will be part of the record and made available to the decis ion makers prior to making a final decision on the proposed project.
4 Response 9
The comment repeats the above comment and adds that “ inaccurate roadway measurements for Wiley Canyon Road” were used in responding to comments.
The comment is inaccurate. First, n o citation to any response is provided, and second, no measurements are provided. Combined, neither the Project applicant nor the City can be expected to reasonably respond further to the comment.
Additionally, however, the City has independently reviewed the information presented in both the Draft EIR and Final EIR. The City also relies on professional engineers and environmental consultants for accurate information, including roadway measurements. None of these professionals have identified any inaccurate roadway measurements for Wiley Canyon Road.
Indeed, in response to one or more individuals providing “ measurements,” both the Project applicant’s engineer and the City’s engineer determined that such measurements were not correct.
Response 10
The comment refer s to “ residents” at “public hearings” that provided “ road, street, and arterial highway measurements (in feet and inches),” but they did not produce “documentation and proof of [the] claimed measurements, ” despite requests to do so. The comment adds that resident statements cannot be relied upon as accurate or reliable without supporting information.
The comments are not correct. First, the resident testimony is not cited or provided, and second, no dates or other public hearing information is provided.
In any event, in response to “ measurements” offered of Wiley Canyon Road, including its right - of-way, both the Project applicant ’s engineer and the City ’s engineer determined that such measurements were not correct, and we understand that the City is relying upon the information and measurements from the City’s engineer and the Project applicant’s engineer.
Response 11
The comment provides a “partial list” of alleged deficiencies to show that the City Planning Commission decision is not supported by the record. The first “example” is that the City allegedly did not “evaluate the potential impacts on local neighborhood streets from vehicles avoiding new traffic-slowing [calming] features on Wiley Canyon Road and Calgrove Boulevard, nor assess “the generalized increase in vehicle trips from the project.” The comment states that the City ’s inclusion of Condition TE20 (traffic count requirement) “acknowledges” this alleged “deficiency.” The comment claims that Condition TE20 is improper deferral under CEQA.
The comments are incorrect for the reasons set forth below.
First, as shown in the Draft EIR, Section 3, Project Description, page 3- 4, the Project would provide traffic calming features that includes roundabouts at intersections and marked crosswalks 5 on Wiley Canyon Road, and a roundabout on site. (See also Draft EIR, Section 4.16, Transportation, page 4.16-20.) The City guidelines state that when pedestrian/bicycle safety and traffic calming measures are provided in excess of the City’s requirements, vehicle miles travelled, or VMT, can be expected to be reduced. This strategy aligns with the General Plan Policy C 1.1.7.
The Project roadways are designed consistently with City standards, and the Project applicant will work with the City to design the roadways in such a way to reduce motor vehicle speeds and encourage bicycle and pedestrian trips, and thereby reduce VMT consistent with state and local standards. Accordingly, these Project features are not traffic “diverters” or “impacts,” but rather tools to reduce VMT and associate GHG emissions.
Second, the comment provides no facts or evidence to support the claim that pedestrian/bicycle safety and traffic calming features result in traffic diversions to avoid these roadway safety and calming features. To the contrary, b ased on research published in the National Cooperative Highway Research Program (NCHRP) Report, roundabouts are used as traffic calming devices and regulate the movement of traffic by reducing speed and delay for all vehicles. The roundabouts achieve traffic calming effects on streets by reducing vehicle speeds using geometric design rather than traffic control devices or traffic volume. As a result, speed reduction can be realized at all times of day and on streets of any traffic volume. (See pages 2-9 and 2-10, Chapter 2/Roundabout Consideration. National Academies of Sciences, Engineering, and Medicine. 2010. Roundabouts:
An Informational Guide – Second Edition. Washington, DC: The National Academ ies Press. https://doi.org/10.17226/22914.) Based upon the data, roundabouts constructed for the P roject would not result in changing the traffic pattern in the area or resulting in cut-through traffic. In fact, they typically improve traffic flow and reduce delays at and through the intersections. They also manage traffic more efficiently than traditional stop -sign or signal -control intersections as they eliminate the “stop-and-go” aspects of stop signs and traffic signals. By improving capacity and efficiency, and reducing delays, roundabouts generally prevent traffic diversion. Further, t he Project’s traffic analysis included in Appendix K -5 is adequate. No change or addition to the environmental analysis is required as a result of this comment.
Third, i t is not anticipated that traffic would divert to streets within the Oak Ridge Estates neighborhood because these routes do not provide a time or distance savings for drivers. However, as part of the Project conditions of approval, the Project applicant will be required to conduct traffic counts in the Oak Ridge Estates area both before and after Project implementation. Should these counts demonstrate a significant diversion of vehicles into the neighborhood, the Project applicant will be required to implement appropriate traffic calming measures to discourage such diversion. This is not improper deferred “mitigation,” but rather a valid protective condition of approval based on the actual operation of Project traffic in conjunction with other traffic in the immediate vicinity.
Fourth, for responsive information regarding increases in traffic, please refer to Topical Response No. 3 – Traffic and Circulation, Final EIR, Section 4.16, Transportation, and the traffic analysis provided in EIR Appendix K-5.
Response 12
6 The comment states that the City “ignored” the “finding in the DEIR that the project site just meets the maximum eight-minute response time that is used by the Los Angeles County Fire Department for planning purposes.” The comment adds that the project’s increased traffic will “compound” the response time and that the project ’s traffic-calming features on two new roads will increase response times.
The comment further states that the project should mitigate, by “possibly … including a fire station site on the 32-acre project site, but the EIR determined that there was no impact and therefore, no need for mitigation, but that this EIR determination was based on “ inaccurate information” and “not supported by the record.”
The comments are not correct for several reasons.
First, the comment itself acknowledges th e Draft EIR’s findings that the Project site meets the eight-minute response time used by Los Angeles County Fire Department (LACFD), and therefore, there is no legitimate basis to impose mitigation or conditions on the Project. There is no impact requiring mitigation under CEQA or the CEQA Guidelines.
Second, the Draft EIR, Section 4.14, Public Services, acknowledges that the Project ’s operations would increase the demand for fire protect ion and emergency medical services , but that, in suburban areas such as the Project site, the LACFD response standard is eight minutes for the first arriving unit and emergency medical services , and 12 minutes for paramedic units. In correspondence with the LACFD, the D epartment stated that Fire Station 124, the nearest to the Project site, would have an average response time of 8 minutes , which is consistent with the LACFD response standard of eight minutes for the first arriving unit and emergency medical service units. However, to offset the costs of additional resources needed to serve the growing City and the Project itself, the Project applicant is still required to pay development fees established by LACFD.
Accordingly, since there are no response ti me significant impacts, there is no legitimate basis to impose any mitigation under CEQA or the CEQA Guidelines.
Response 13
The comment cites the public health and safety “exception” under the Housing Accountability Act, stating that “a project that brings 232 townhome/detached condominium units and a senior/assisted living facility with 120 units within the 500 -foot setback from the I-5 Freeway … violat[ing] the residential planning standards of both the California Air Resources Board (CARB) and the South Coast Air Quality Management District (SCAQMD) and for which no site characterization sampling for air quality was performed.”
The comments are not correct for several reasons.
First, the Draft EIR evaluated the Project ’s air quality impacts related to the freeway, including toxic air contaminants (TACs) such as diesel particulate matter, in Section 4.2 of the Draft EIR.
As detailed under methodology, guidance on mobile source emissions by the California Air Resources Board (CARB) states TAC exposure and health risk drops substantially within the first 7 300 feet from a freeway and generally recommends avoiding sensitive land uses within 500 feet of a freeway (See Draft EIR, p. 4.2-27.)
The closest lane of traffic on the I-5 freeway would be approximately 66 feet to 115 feet from the project site property line where the proposed development would occur. The proposed townhomes along the project site’s western boundary would have an additional buffer distance ranging from approximately 5 feet to 24 feet from the property line. Due to the proximity, Dudek completed a Health Risk Assessment (HRA), included as EIR Appendix B, to disclose the potential risk to future occupants of the Project. The analysis shows that potential acute and chronic health impacts are well below established significance thresholds at all locations . And, in accordance with Title 24 of the California Code of Regulations that require installation of window filters, impacts were determined to be less than significant. As such, no mitigation measures are required.
Second, CARB ’s handbook recommendations are advisory and not regulatory; and they were considered and balanced against other considerations. The CARB guidance recognizes that local land use agencies have a responsibility to balance other considerations, including housing and transportation needs, economic development priorities and other quality of life issues and to consider site-specific project design features that reduce air pollution exposures. In addition, the CARB guidance recognizes that health risks from mobile sources, in particular diesel particulate matter, would decrease over time as cleaner technology phases in.
Response 14
Since t he comment does not raise any specific issue s regarding the adequacy of the a nalysis provided by the EIR, no further response can be provided. However, the comment will be part of the record and made available to the decision makers prior to making a final decision on the proposed project.
Response 15
The comment consists of the concluding remarks of the appellants. The comment will be included as part of the record and made available to the decision makers prior to making a final decision on the proposed project. However, the comment does not address the adequacy of the project or the environmental analysis provided by the EIR; and therefore, no further response can be provided.
Response 16
The comment attaches a one-page listing of the “individuals and groups” that appeal. The comment will be part of the record and made available to the decision makers prior to making a final decision on the proposed project. However, the comment does not address the adequacy of the project or the environmental analysis provided by the EIR; and therefore, no further response can be provided.
Response 17
The comment is the 2-page invoice covering the cost of the filed appeal. The comment will be part of the re cord and made available to the decision makers prior to making a final decision on the 8 proposed project . However, the comment does not address the adequacy of the project or the environmental analysis provided by the EIR; and therefore, no further response can be provided.
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cont'd