Sully Miller (trails at Santiago Creek)
Milan’s proposal is inconsistent with the Orange General Plan, the OPA Specific Plan, East Orange General Plan and the Santiago Creek Greenbelt Plan
The Recirculated Draft Environmental Report (RDEIR) is flawed and fails to analyze the true impacts and should not be certified by the City because it violates the Cal Environmental Quality Act (CEQA).
Land use for the site is governed by three separate planning documents. The East Orange General Plan, OPA Specific Plan and the Santiago Greenbelt Plan designate 96 acres to be open space. Milan wants to change the Orange General Plan, OPA Plan and East Orange Plan to accommodate 128 dwellings on 40 acres. Residential zoning only exists on 12 acres adjacent to Mabury Ranch.
Milan’s project is directly at odds with the goals and policies of the Orange General Plan and OPA Plan. These plans do not promote changing Open Space to Residential.
Milan’s project adds unnecessary risks and detrimental impacts that we should not have to absorb:
- Traffic – The real construction and ongoing traffic will be significant and unavoidable.
- Mining – Historic sand and gravel mining has left deep silt ponds on the project site that have never been properly reclaimed. There is no reclamation plan.
- Grading – The ‘grading plan’ is ill defined and inadequate to meet the state standards.
- Air Quality – Impacts due to grading and earthwork activity have been grossly understated.
- Open Space management or landowner – The County has not agreed to take the greenbelt -open space conveyance. The City will not take it. HOAs are not reliable or have the capability or experience to take on such a liability.
- Health and Safety issues are significant and unavoidable – The project adds unnecessary risks as it is to be built in a flood plain, next to a landfill that is prone to natural hazards – dam inundation, methane gas, wildfires, earthquakes and liquefaction – that are high-risk liabilities.
- Public safety evacuation due to wildfire and flooding is a major issue.
- Taxpayer Liability – Ignoring the significant and unavoidable impacts to health and safety issues could create liabilities for the city that would be shifted to taxpayers.
- Creates additional property rights – The landowner will have the ability to add additional homes than agreed upon with 3 votes from the City Council based on the new Milan zoning.
The General Plan Amendment and Zone Changes are legislative actions at the discretion of City Council. The City Council has the right to DENY this proposal.
Milan has no existing property rights for houses on the Sully Miller site as is being proposed. The land was supposed to be reclaimed when mining ceased. The East Orange and OPA Specific Plans designate it open space. Not a single plan ever identified this property for residential use.
- This project sets an extremely bad precedent for Orange.
- The City should not expose taxpayers to unnecessary liabilities.
- Existing plans must be honored including the property rights of existing residents.
Milan has no legitimate expectation that these approvals would be granted. Milan is seeking to enhance their entitlements on Sully Miller to help bail out their investors.
The RDEIR is inadequate. The City is not obligated to approve bad projects.
Approval of this project would violate the State Planning and Zoning Law.