HomeMy WebLinkAboutREDsullivanb4For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
RECEIVED
PAGE 1 of 7
JUL19201 0
SLO CITY CLER K
RE : Council agenda report for 712012010, item B4 . Initiative Measure to enact revisions to th e
Margarita Area Specific Plan
The city staff were required to prepare a report concerning the impacts of the voter initiative measur e
amending the Margarita Area Specific Plan and the Prado Road alignment, which recently qualifie d
for the November 2010 election . Unfortunately, the report presented to Council is filled wit h
information which is misleading, or incorrect, or highly speculative. Therefore the report has littl e
value and little credibility. Council should take this into consideration before deciding on the vote r
initiative issue .
Some examples follow .
1 . Council Agenda Report at page 2 states, "It (the voter initiative) does not propose an y
alternative alignment for Prado Road, nor does it address any solutions to the resultant traffi c
impacts . The Initiative does not identify environmental or fiscal impacts associated with th e
proposed truncation of the planned East-West circulation route ."
This is misleading for two reasons :
First, by law, such an initiative may not deal with more than one subject . This is the so-called singl e
subject rule . The single subject which the initiative deals with is the prohibition of the so-calle d
Northern Alignment of Prado Road, which is designed to pass through the Damon-Garcia Sport s
Fields site. Any further expansion of the initiative to propose alternate routes for Prado Road, or t o
propose funding plans, or to propose new sports uses at Damon-Garcia Sports Fields, etc ., woul d
likely violate the single subject rule .
Second, it is in the best interest of the City and the people of the City that after this initiative passes i n
November 2010, any planning and environmental review for a revised Prado Road alignment, or any
review for additional sports and recreation uses at Damon-Garcia Sports Fields site, should follow th e
regular public review process of the City, such as Planning Commission, Parks and Recreatio n
Commission, etc.. This would also allow full environmental review, which is not required under th e
voter initiative process .
17 July 201 0
To :
City of San Luis Obispo - City Counci l
Through : City Clerk (Elaina Cane )
From :
Michael Sullivan
1127 Seaward Stree t
San Luis Obispo, CA 9340 5
Tel . 805-647-4101 (temporary message) or 805-441-6981 (cell )
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For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road. Comments from Michael Sullivan .
PAGE 2 of 7
2.Council Agenda Report at page 4 states ,
This circulation connection (meaning Prado Road) has been incorporated into the City's plannin g
documents since (1962) " This is misleading because the proposal in question, called the
Northern Alignment of Prado Road, only came into being when Council approved it 01 Feb 2000 ,
while the earlier proposed alignment of Prado Road, via Industrial Way, was not so controversial .
3. Council Agenda Report at page 4 claims that the voter initiative would mean that police, fir e
and ambulance will not be able to serve the Margarita Area well . This claim is very likely false . Th e
Margarita Area would still be connected to the west to South Higuera Street, and to the east to Tan k
Farm Road and Broad Street via the Santa Fe Road extension to Prado Road, which is not altered b y
the initiative .
4.The traffic analysis (Council Agenda Report, p . 4) is murky and uncertain .Its assumption s
are not clearly stated in the Council Agenda Report . The authors admit that this traffic model need s
to be upgraded to a better model and that potential neighborhood traffic impacts remain uncertain .
(Council Agenda Report, at p . 6 )
One thing which stands out is that on Figure 2 at Council Agenda Report page 5, the map shows n o
change in traffic volume along the Santa Fe Road extension connecting Prado Road to Tank Far m
Road . Table 1 on p . 6 also shows no significant traffic volume change for this segment . Logically ,
one would assume that if the Prado Road Northern Alignment is removed, traffic volume on th e
Santa Fe Road extension would increase significantly. The fact that such change is not include d
seems to indicate that this important segment volume from Prado Road to Tank Farm Road wa s
either ignored or is considered insignificant . That seems illogical .
Before one can make sense of the traffic analysis in the Council Agenda Report, one must know what
assumptions were made. Which, if any, of the following mitigating factors were or were no t
incorporated :
(a)Alternate design of U .S . 101 / Los Osos Valley Road (LOVR) intersection to 4 lanes ?
(b) Connection of U .S . 101 / LOVR intersection directly to Buckley Road ?
(Note : In early 2010 I, Michael Sullivan, received a letter from Tim Bochum of City of SLO, i n
response to my earlier concerns about the plan for the U .S . 101 / LOVR intersection . I had
recommended that the intersection should connect to Buckley Road directly, a concept that had been
proposed earlier . Mr . Bochum assured me that such a scheme could still be possible if Counci l
should choose to pursue it .)
(c)Elimination of planned signal at Broad Street and Prado Road ?
(d)Elimination of planned signal at Broad Street and Capitolio ?
(e)Improvement of Tank Farm Road to 4 lanes along its entire length ?
(f) Inclusion of planned U .S . 101 I Prado Road full intersection, with connection to Madonna Roa d
and also with connection from Dalidio Drive to LOVR as planned in the General Plan ?
(g)Potential improvement of Buckley Road to 4 lanes ?
(h)Also, concerning the several junctions along Prado Road within the Margarita Area, and th e
junction of Tank Farm Road and Santa Fe Road : Would it make a difference if these junctions wer e
roundabouts rather than signals? Why or why not?
For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 -Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
PAGE 3 of 7
Council Agenda Report at p . 7 (bottom) claims that it should not be taken for granted that a n
alternative (Prado Road alignment) with sufficient capacity is readily available to take the place o f
Prado Road . However, various feasible alternatives are possible . One possibility is explained
below, in a comment made by a civil engineer in regard to the City of SLO's Final Program
Environmental Impact Report, Airport Area and Margarita Area Specific Plans and Related Facilitie s
Master Plans, Volumes 1 and 2, of September 2003 .
"ROADS A. Prado Rd . Consider an additional alternative to the Prado Rd . extension to Broad St .
An alternative not shown would be to extend Prado Rd . in a SE direction from the Margarita Area t o
connect to Tank Farm Rd . near the junction of the proposed Public Facilities zoning with the Ope n
Space Zoning (see newsletter map) and thereafter use Tank Farm Rd . as the arterial access to Broa d
St. This would create a wye intersection at the junction with only one conflicting traffic movement .
This alternative would eliminate the need to construct approximately 112 mile of the Prado Rd .
extension to Broad St., would create less environmental damage, would eliminate the conflicts wit h
the Damon-Garcia sports fields and eliminate the need for an additional signalized intersection o n
Broad St . Traffic movement (particularly trucks) can be better accommodated at the Tank Farm Rd .
intersection with Broad than at the proposed new intersection shown on the plan . In my view thi s
alternative is clearly superior to any of the other alternatives shown on the plan ."
The above are comments of Dave Romero, in : City of San Luis Obispo . Final Program Environmental Impact Report .
Airport Area and Margarita Area Specific Plans and Related Facilities Master Plans . Volumes 1 and 2 . September 2003 .
Page 98 .
Mr. Romero continued with suggestions for (1) including the southern frontage of Buckley Road within the Airport Are a
Specific Plan (2) to plan Buckley Road as an Urban Arterial Highway from Broad to a connection with Los Osos Valle y
Rd . at Higuera.
For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
PAGE 4 of 7
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Source : City of San Luis Obispo . Final Program Environmental Impact Report . Airport Area and
Margarita Area Specific Plans and Related Facilities Master Plans . Volumes 1 and 2 . September
2001 . Page 98 .
5.Council Agenda Report at p . 8 - City Housing and Land Use Impact s
The Council Agenda Report assumes that the removal of the Prado Road northern alignment woul d
automatically cause a limitation of housing development . This is highly speculative, because th e
traffic analysis in the Council Agenda Report is preliminary and does not include various potentia l
mitigation measures as mentioned previously herein .
6.Council Agenda Report at p . 9 - Fiscal Impacts
The introductory statements on page 9 are highly speculative . For example, the report states (p .9 )
that "there are costs to the community in increased travel time, lack of community amenities ,
difficulty in attracting and retaining head of household jobs, and decrease in the number of familie s
able to afford to live in San Luis Obispo ."
- Without Prado Road northern alignment, travel time in the east west direction would be negligibl e
in the easterly direction, such as from South Higuera to the Airport, since the travel distance by th e
alternative route from Prado Road to Tank Farm Road to Broad Street is just about the same as b y
way of the Prado northern alignment . Travel times west bound would only be slightly longer, about a
minute or so, in certain routes, for example from Broad St . junction at Orcutt Road to South Higuera,
but about the same for other routes, for example from the airport to South Higuera.
For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
PAGE 5 of 7
- Community amenities will not be significantly affected . The public park within the Margarita Are a
Specific Plan can still be built. Damon-Garcia Sports Fields will be greatly enhanced and wil l
potentially be able to be expanded to include other recreational uses in the approximately 4 acre s
which would otherwise be used for a highway through the Sports Fields area.
-The claim of "difficulty in attracting and retaining head of household jobs" is a great exaggeration .
The city has always had this problem, since competition for jobs in the city is high, and th e
manufacturing base is limited . A realignment of Prado Road will not affect these factor s
significantly .
-The biggest exaggeration of all is that the voter initiative would decrease the number of familie s
able to afford to live in San Luis Obispo . The main constraints to affordability in SLO are (a)a
naturally high market value of land and housing because of desirable location ; (b) constraints o n
density of housing due to public opposition to infill. The voter initiative does not affect these factors .
7 .Council Agenda Report at p. 11 - Impacts to Parks, Recreation and Air Quality
The voter initiative does not state that the northern alignment of Prado Road presently encroache s
into the South Hills open space, nor does it claim that existing sports fields would be impacted
directly by encroachment of Prado Road into such sports fields . The initiative does state, correctly ,
that the proposed Prado Road northern alignment would take up about 4 acres, or roughly 15 %, o f
the existing Damon-Garcia Sports Fields site area, which could potentially otherwise be used fo r
recreational purposes at the Sports Fields site if the northern alignment were not implemented . The
initiative includes prohibition of a public roadway (similar to Prado Road northern alignment )
through a specific portion of the South Hills Open Space Area which lies directly adjacent to th e
Sports Fields area.
The following statement (p . 11 of Council Agenda Report) is somewhat misleading :
"When the Council considered purchasing the Damon-Garcia Sports Complex site, the additional 3 .5
acres along the northern site boundary was explicitly included for the purpose of building Prado Roa d
and this use was considered in the land value appraisal that informed negotiations for the property
with the Damon and Garcia families ." Even if this statement is true, the fact remains that very fe w
people of San Luis Obispo ever knew of these details, and even today, before this voter initiative
came forward, very few people of San Luis Obispo knew of the Prado Road northern alignment .
It seems rather improper that apparently the City negotiated a land purchase deal which included a
planned road through the Sports Fields site, in 1999, a year before the General Plan was amended (0 1
Feb . 2000) to allow such a change .
Alternative sports and recreation uses possible at the Damon-Garcia Sports Fields can be determine d
through the standard planning processes of the City. As mentioned above, the purpose of th e
initiative was not to include recommendations for specific plans for such uses, because that woul d
probably violate the single-subject rule for voter initiatives .
It remains uncertain and highly speculative to assert that the voter initiative would significantly dela y
development of the Margarita Area and Airport Area . The City of SLO Final Progra m
Environmental Impact Report (EIR), Airport Area and Margarita Area Specific Plans and Related
For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
PAGE 6 of 7
Facilities Master Plans, Volumes 1 and 2, September 2003, points out that the transportation and lan d
use plans for these areas are analyzed as a Program EIR . A "Program EIR" states the general policie s
and mitigations for a large development which will be done in phases . In many cases, actua l
development of these plans will involve subsequent CEQA review, whether the voter initiative passe s
or not . If the voter initiative passes, the change in Prado Road alignment may require a focused EI R
to look mainly at traffic issues. A focused EIR can be developed and processed more quickly than a
traditional full-scope EIR .
8. Environmental benefits of the Voter Initiativ e
The subsequent environmental review undertaken by the City will hopefully finally enable Prad o
Road to be seen in its whole regional context, rather than in segments .
The planning for Prado Road has been done incrementally, in piecemeal fashion, which violates th e
California Environmental Quality Act (CEQA).
For example, the Prado Road northern alignment was apparently approved tacitly (in 1999) as part o f
the purchase agreement for Damon-Garcia Sports Fields, before there was any General Pla n
amendment to authorize such a change (which did not occur until Feb . 2000). General Plan
amendments generally require full environmental review .
A second example of segmented environmental review : The General Plan amendment of Feb . 200 0
which changed Prado Road from Industrial Way alignment to the northern alignment was done with a
mitigated negative declaration . (It is interesting to note that the city Planning Commission ha d
recommended in Oct. and Dec . 1999 that the City should use a full EIR review of the Prado Norther n
Alignment before going forward with the proposed general plan amendment .) It wasn't until 200 3
that the broader environmental impact of Prado Road northern alignment in relation to the Airpor t
Area and beyond was studied in detail in the Final EIR for the Airport Area and Margarita Are a
Specific Plans and Related Facilities Master Plans (Sep . 2003), AFTER the Prado Road norther n
alignment had already been approved in Feb . 2000.
Further segmentation of environmental review of Prado road includes the separate review of Prad o
Road in relation to the Orcutt Area and the separate review of the U .S . 101 1 Prado Road interchang e
with connection to Madonna Road .
9. Certain stated "facts" of the Council Agenda Report are incorrect
The proposed voter initiative has not been presented in its entirety in the Council Agenda Report . I t
ends at Figure B-05-5 of the initiative, which is on page 24 of 52 of the initiative as it was circulated
in the petition signature gathering process of Spring 2010. Thus, 28 pages of the circulated initiativ e
are not presented .
For City of San Luis Obispo - Council meeting of 20 July 2010 - Item B-4 - Voter initiative regarding Prad o
Road . Comments from Michael Sullivan .
PAGE 7 of 7
False statement in Council Agenda Report Realit y
Report at p. B4-72
Other : Zoning Map . Comment : Prado Roa d
extension to Broad is shown on Zoning Map .
Amendment to zoning map will be required .
Zoning map amendment is included in
Attachment F of the Voter initiative (seen a
pages 45-47 of initiative as circulated )
MASP p . 87 . Table 14 . Other parks and
greenways . Comment : Funding source fo r
additional 4 acres of park has not bee n
identified .
Voter initiative does not specifically requir e
that 4 acres of park should be developed and
financed, it simply states (p . I and 2 o f
circulated petition, "Reasons for the petition")
that more area would be available (at Damon -
Garcia sports fields site) for recreational use .
If such park use is decided by later Cit y
Council actions, funding proposal would
probably come at that time .
CONCLUSIONS :
The recommendations and logic of the Council Agenda Report reply largely on a flawed, quickly -
done traffic analysis, whose methodology and assumptions remain murky and questionable .
Therefore, the major conclusions of the report are probably not credible .
Council should approve the voter initiative . But, even if it does not, we are confident that the voter s
will do so in November 2010 .
Michael Sullivan
1127 Seaward St .
San Luis Obispo 9340 5