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HomeMy WebLinkAbout8/12/2020 Item 2, Cooper Wilbanks, Megan From:Allan Cooper < To:Corey, Tyler; Scott, Shawna; Advisory Bodies Subject:Letter To The Planning Commission Attachments:808_08_20...lettertopc.pdf Dear Tyler and Shawna - Would you kindly forward the letter attached below to the Planning Commission? This letter pertains to their August 12, 2020 review of the Froom Ranch EIR. Also, could you include this in the City's correspondence file? Thanks and hoping you are staying safe and well. - Allan 1 Save Our Downtown ______________________________________________________________________________ Seeking to protect and promote the historical character, design, livability and economic success of downtown San Luis Obispo. To: San Luis Obispo Planning Commission, Tyler Corey and Shawna Scott Re: August 12, 2020 Review of the Froom Ranch Final EIR From: Allan Cooper, Secretary Save Our Downtown Date: August 8, 2020 On Wednesday, August 12, 2020 you will be tasked with the certification of the Froom Ranch Final EIR including adoption of the CEQA Findings and the Statement of Overriding Considerations, approval of the Mitigation Monitoring and Reporting Plan, the Froom Ranch Specific Plan (based on findings that the project is consistent with the General Plan) and related project entitlements, including initiation of annexation. This Final EIR found the following significant and unavoidable impacts: 1) exceedance of projected population growth; 2) exceedance of established reactive organic gas (ROG), nitrogen oxide (NOX) and other greenhouse gas (GHG) emission thresholds; 3) exacerbation of wild fire risks and (evacuation) hazards; 4) exacerbation of queuing and peak hour traffic for automobiles on Los Osos Valley Road; 5) poor levels of service for pedestrians and bicycle modes; 6) change of the existing visual character; and 7) loss of three contributing historic structures. By the way, there should be one more significant and unavoidable impact added to this list. This is the significant hazard of debris flows which accompany wild land fires. In addition to a description of the severity and extent of these debris flows (preferably accompanied by a map), partial mitigations, in the form of debris flow dams, should be included in this document. However, all of these impacts can be supposedly “overridden” through achieving any one of the following considerations: 1) increased sales tax revenues; 2) creation of new construction- related and permanent jobs; 3) an internal circulation system that results in the reduction of per capita vehicle trips; 4) the provision of park facilities; 5) variety of housing types that will address unmet housing needs; and 6) open space protection and creek restoration. We are protesting the extremely low bar set for these “overriding considerations” especially when there are so many significant and unavoidable impacts attributed to this project. According to Article 7. EIR Process § 15093. Statement of Overriding Considerations 14 CA ADC § 15093, “the statement of overriding considerations shall be supported by substantial evidence in the record.” We do not believe that these considerations, as described in your staff report, have been supported by “substantial evidence”. Permit us to further elaborate on this. 1.All mixed-use projects by their very nature meet the first two criteria, i.e., increased sales tax revenue and the creation of new jobs. However, it remains to be seen whether that portion of the project generating sales taxes, i.e., the 100,000 sq.ft. of Madonna Froom commercial development, will ever materialize as it is relegated to Phase 3. What are the repercussions for the developer if he reneges on his commitment to Phase 3? 2.The third overriding consideration, i.e., an internal circulation system resulting in the reduction of per capita vehicle trips, is hard to reconcile with the finding that there will be “poor levels of service for pedestrians and bicycle modes”. Perhaps this can be explained more fully. 3.The provision of park facilities is already a requirement of the City’s Subdivision Regulations where the subdivider is required to meet additional local park demand resulting from the subdivision. However, it remains to be seen if the pro-ratio requirement of park space for this development (which does not include undeveloped open space) has been met. 4.Every mixed-use project must provide affordable housing consistent with the intent of California Government Code Section 65915, and in compliance with City policies and the Housing Element. However, it has not been stated in any specificity what “unmet housing needs” will be provided. Yes, providing low-income housing is one of the developer’s stated goals and, yes, there is mention of a “qualified low-income housing developer” who will “satisfy the Inclusionary Housing requirements”. But there is no mention of the specific number of deed-restricted, low-income housing units that this development will provide. And again, it is not clear if this housing will ever be built as it is relegated to Phase 3. 5.In our opinion, the only benefit remaining that has been supported by “substantial evidence” is open space protection and creek restoration which is thankfully included in Phase 1. As always, I hope you are all staying safe and well!