HomeMy WebLinkAboutItem 15 - COUNCIL READING FILE_b_CEQA Initial Study & Negative Declaration
City of San Luis Obispo
Climate Action Plan Update and
CEQA GHG Emissions Thresholds
Final
Initial Study–Negative Declaration
prepared for
City of San Luis Obispo
Office of Sustainability
990 Palm Street
San Luis Obispo, California 93401
prepared by
Rincon Consultants, Inc.
1530 Monterey Street, Suite D
San Luis Obispo, California 93401
August 3, 2020
Table of Contents
Final Initial Study– Negative Declaration i
Table of Contents
Initial Study ....................................................................................................................................... 1
Proposed Plan Title .................................................................................................................... 1
Lead Agency/Plan Sponsor and Contact ..................................................................................... 1
Plan Location and Physical Setting ............................................................................................. 1
Existing Setting .......................................................................................................................... 4
General Plan Designation and Zoning ......................................................................................... 8
Description of Plan .................................................................................................................... 8
Cumulative Projects Scenario ................................................................................................... 15
Required Approvals ................................................................................................................. 15
Environmental Factors Potentially Affected ..................................................................................... 17
Determination ................................................................................................................................. 17
1 Aesthetics .................................................................................................................... 19
2 Agriculture and Forestry Resources .............................................................................. 23
3 Air Quality .................................................................................................................... 27
4 Biological Resources ..................................................................................................... 31
5 Cultural Resources ........................................................................................................ 38
6 Energy .......................................................................................................................... 42
7 Geology and Soils ......................................................................................................... 44
8 Greenhouse Gas Emissions ........................................................................................... 48
9 Hazards and Hazardous Materials ................................................................................. 52
10 Hydrology and Water Quality ....................................................................................... 56
11 Land Use and Planning ................................................................................................. 60
12 Mineral Resources ........................................................................................................ 62
13 Noise ............................................................................................................................ 64
14 Population and Housing................................................................................................ 68
15 Public Services .............................................................................................................. 70
16 Recreation .................................................................................................................... 72
17 Transportation ............................................................................................................. 74
18 Tribal Cultural Resources .............................................................................................. 76
19 Utilities and Service Systems ........................................................................................ 78
20 Wildfire ........................................................................................................................ 82
21 Mandatory Findings of Significance .............................................................................. 84
References ...................................................................................................................................... 86
List of Citations ........................................................................................................................ 86
List of Document Preparers ..................................................................................................... 88
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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Tables
Table 1 City of San Luis Obispo 1990, 2005, & 2016 Communitywide GHG Emissions Levels ....... 8
Table 2 City of San Luis Obispo 2020 CAP Pillars, Measures, and Foundational Actions ............... 9
Table 3 City of San Luis Obispo GHG Emissions Forecast Through 2035 ..................................... 12
Table 4 Land Use Compatibility for Community Noise Exposure ................................................ 65
Table 5 Human Response to Different Levels of Groundborne Vibration ................................... 66
Figures
Figure 1 Regional Location ........................................................................................................... 2
Figure 2 Plan Location .................................................................................................................. 3
Figure 3 City of San Luis Obispo GHG Emissions Forecast, 2005 to 2035 ..................................... 11
Figure 4 Determining CEQA GHG Emissions Analysis Methodology ............................................ 14
Appendices
Appendix A Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants
Appendix B Description of Greenhouse Gases of California Concern
Initial Study
Final Initial Study–Negative Declaration 1
Initial Study
Proposed Plan Title
Climate Action Plan (CAP) Update and CEQA Greenhouse Gas (GHG) Emissions Thresholds
Lead Agency/Plan Sponsor and Contact
Lead Agency/Plan Sponsor
City of San Luis Obispo
Office of Sustainability 990 Palm Street
San Luis Obispo, California 93401
Contact Person
Chris Read, Sustainability Manager
(805) 781-7151
cread@slocity.org
Plan Location and Physical Setting
The City of San Luis Obispo’s CAP Update and CEQA GHG Emissions Thresholds apply to all areas and
plans/projects within the City of San Luis Obispo limits. Figure 1 shows the regional location, and
Figure 2 shows the plan location.
Regional Location and Setting
The City of San Luis Obispo is located in the Central Coast Region of California1 along U.S. Highway
101 (U.S. 101), approximately 230 miles south of San Francisco and 190 miles north of downtown
Los Angeles. San Luis Obispo is accessible via U.S. 101 from the north and south, State Ro ute 1 (SR 1)
from the northwest, and State Route 227 (SR 227) from the south. The City is also served by the City
of San Luis Obispo Transit Division2 as well as the South County Regional Transit Authority (RTA).3
Local Setting
The City is characterized by a mild Mediterranean climate that is moderated by the influence of the
Pacific Ocean, located approximately 10 miles to the west. The City receives approximately 20
inches of rain annually, 287 sunny days per year, with a July high temperature of 74°F and a January
low temperature of 43°F.4
1 The Central Coast Region of California consists of the coastal areas from Santa Cruz County (on the northern end) to Santa Ba rbara
County (on the southern end).
2 San Luis Obispo, City of. 2019. SLO Transit. Available a t: https://www.slocity.org/government/department-directory/public-works/slo-
transit
3 Regional Transit Authority. 2019. SoCoTransit. Available at: https://www.slorta.org/schedules -fares/
4 Best Places. 2019. Climate in San Luis Obispo. Available at: https://www.bestplaces.net/climate/city/california/san_luis_obispo
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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Figure 1 Regional Location
Initial Study
Final Initial Study–Negative Declaration 3
Figure 2 Plan Location
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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The City encompasses approximately 72,600 acres of land in a narrow valley between the coastal
Santa Lucia Mountains on the west and volcanic hills, known as the Nine Sisters, which reach an
elevation of up to 3,000 feet on the east. The San Luis Obispo Creek bisects the City and is a defining
feature of the Downtown District. The City also has a permanent open space greenbelt at its edges.
Surrounding Uses
The City is surrounded by unincorporated San Luis Obispo County land characterized by agricultural
uses (vineyards, field crops) and open space containing oak woodland and grasslands habitat.
Distinctive facilities and land uses proximate to the City include California Polytechnic State
University San Luis Obispo (Cal Poly), Cuesta College, and San Luis Obispo Military Camp to the
north, San Luis Obispo County Regional Airport and numerous vineyards and wineries to the south,
Los Padres National Forest to the east, and Montana de Oro State Park to the west.
Existing Setting
Historical and Demographic Setting
The history of San Luis Obispo dates back to 1772 when Junipero Serra founded Mission San Luis
Obispo de Tolosa. The City was officially incorporated in 1856.5 According to the population
projections included in the City’s General Plan Land Use Element, the City’s population in 2020 is
48,826. Over the last twenty years, population in the City has grown by around 3,000, an average
rate of 0.4 percent per year, while the County of San Luis Obispo has grown at an average rate of 1.1
percent per year.”6 See Section 4 (Plan Location and Physical Setting) for discussion of the physical
setting of the City of San Luis Obispo.
Sustainability and GHG Reduction Efforts Setting
City of San Luis Obispo Sustainability and GHG Reduction Efforts
SAN LUIS OBISPO CAP
In 2012, San Luis Obispo adopted the City of San Luis Obispo Climate Action Plan (2012 CAP) as part
of the ICLEI-Local Governments for Sustainability’s Cities for Climate Protection Campaign.7 The
2012 CAP included a baseline greenhouse gas (GHG) emissions inventory conducted
communitywide in 2005 data and forecasted GHG emissions in 2020. The 2012 CAP was adopted by
City Council in 2012 to provide guiding documentation that outlines the course of action for
identifying and implementing strategies to achieve citywide reductions in GHG emissions for both
municipal and community operations.8 The 2012 CAP was designed to:
▪ Present baseline emissions of the 2005 inventory;
▪ Forecast emissions through 2020 relative to Statewide goals;
5 See California. Mission San Luis Obispo. Available at: http://www.seecalifornia.com/missions/san-luis-obispo-mission.html
6 San Luis Obispo, City of. 2012. Economic Development Plan. Available at: https://www.slocity.org/home/showdocument?id=4901
7 San Luis Obispo, City of. 2012. Climate Action Plan. Available at: https://www.slocity.org/home/showdocument?id=2398
8 San Luis Obispo, City of. 2012. Climate Action Plan. Available at: https://www.slocity.org/home/showdocument?id=2398
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Final Initial Study–Negative Declaration 5
▪ Establish a GHG emissions reduction target of 15 percent below the baseline by the year
2020, which equates to 22 percent below the projected business-as-usual (BAU) forecast;
and
▪ Provide policies and strategies for achieving Statewide GHG emissions reduction targets for
2020.
As part of the 2012 CAP, the City adopted GHG reduction measures to demonstrate consistency
with Statewide targets set forth in AB 32. The community’s total 2005 baseline GHG emissions were
estimated to be 264,237 metric tons of carbon dioxide equivalent (MTCO2e).9
The 2012 CAP included emissions reduction strategies from the transportation and land use, energy,
and waste management sectors for each of communitywide and municipal operation scopes.
Examples of GHG reducing strategies suggested in the 2012 CAP included the creation of a Short-
Range Transit Plan, modify the Bicycle Transportation Plan, adopt a Downtown Pedestrian Plan, and
implement additional requirements for new development. The 2012 CAP included 36 strategies to
reflect currently implemented City regulations and programs expected to be ongoing to help
achieve 2020 targets.
SAN LUIS OBISPO CAP UPDATE (PROPOSED PLAN)
In 2020, as part of the CAP Update assessed herein, San Luis Obispo is actively engaged in
addressing climate change, sustainability, and reductions in GHG emissions. The City of San Luis
Obispo prepared a Draft Climate Action Plan (CAP) Update dated July 1, 2020 to reduce municipal
and communitywide GHG emissions with the goal of achieving a communitywide GHG emissions
output of 197,180 MTCO2e per year by 2030 (consistent with California Senate Bill 32 target for
2030) as well as the aspirational goal of achieving carbon neutrality by 2035 (exceeding the
California Executive Order B-55-18 target of carbon neutrality by 2045).10 The CAP Update assessed
herein builds upon the goals of the 2012 CAP, is based upon a more recently completed community-
level inventory for baseline year 2005 and 2016, and formulates additional pillars, measures, and
foundational actions to achieve the City’s sustainability goals.11
Regional Sustainability and GHG Reduction Efforts
As follows is a summary of the regional GHG emissions reduction efforts, which the City of San Luis
Obispo CAP Update is intended to be consistent with or exceed.
CALIFORNIA SENATE BILL 375
In 2008, Senate Bill 375 (SB 375) enhanced the State’s ability to reach AB 32 targets by directing
CARB to develop regional GHG emissions reduction targets to be achieved from passenger vehicles
for 2020 and 2035. In addition, SB 375 directs each of the State’s 18 major Metropolitan Planning
Organizations (MPO) to prepare a sustainable community’s strategy (SCS) that contains a growth
strategy to meet such regional GHG emissions reduction targets for inclusion in the respective
regional transportation plan (RTP).
9 The Climate Action Plan Update uses updated methods and data sources to estimate the 2005 GHG baseline inventory. As a result , the
baseline emissions estimates are different in the Climate Action Plan Update than they were in the 2012 Climate Action Plan.
10 Carbon neutrality is defined as net zero carbon emissions, which is achieved either by balancing carbon emissions with carbon removal
or by completely eliminating carbon emissions.
11 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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SLOCOG REGIONAL TRANSPORTATION PLAN/SUSTAINABLE COMMUNITIES STRATEGY
In 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by
2020 and 2035. Specifically, the San Luis Obispo Council of Governments (SLOCOG) was assigned
targets of a 3 percent reduction in GHG emissions from transportation sources by 2020 and an 11
percent reduction in GHG emissions from transportation sources by 2035. In 2019, SLOCOG adopted its
RTP, which includes the region’s SCS and meets the requirements of SB 375.12
State Sustainability and GHG Reduction Efforts
As follows is a summary of the State GHG emissions reduction efforts, which the City of San Luis
Obispo CAP Update is intended to be consistent with or exceed.
CALIFORNIA EXECUTIVE ORDER S-3-05
In 2005, the California governor issued Executive Order (EO) S-3-05, which identifies Statewide GHG
emissions reduction targets to achieve long-term climate stabilization as follows:
▪ Reduce GHG emissions to 1990 levels by 2020
▪ Reduce GHG emissions to 80 percent below 1990 levels by 2050
In response to EO S-3-05, California Environmental Protection Agency (CalEPA) created the Climate
Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT
Report”).13 The 2006 CAT Report identified a recommended list of strategies that the State could
pursue to reduce GHG emissions. These are strategies that could be implemented by various State
agencies to ensure that the emission reduction targets in EO S-3-05 are met and can be met with
existing authority of the State agencies. The strategies include the reduction of passenger and light
duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping
technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill
methane capture, among others.
CALIFORNIA ASSEMBLY BILL 32
In 2006, the California legislature signed Assembly Bill (AB) 32 – the Global Warming Solutions Act –
into law, requiring a reduction in Statewide GHG emissions to 1990 levels by 2020 and California Air
Resources Board (CARB) preparation of a Scoping Plan that outlines the main State strategies for
reducing GHGs to meet the 2020 deadline. In addition, AB 32 required CARB to adopt regulations to
require reporting and verification of Statewide GHG emissions. Based on this guidance, CARB
approved a 1990 Statewide GHG level and 2020 limit of 427 MTCO2e.
CALIFORNIA CLIMATE CHANGE SCOPING PLAN
In 2008, CARB approved the original California Climate Change Scoping Plan, which included
measures to address GHG emission reduction strategies related to energy efficiency, water use, and
recycling and solid waste, among other measures. Many of the GHG reduction measures included in
the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and-
Trade) have been adopted and implemented since approval of the Scoping Plan.
12 San Luis Obispo Council of Governments (SLOCOG). 2019. 2019 Regional Transportation Plan: Connecting Communities. Available at:
https://slocog.org/2019RTP (accessed January 2020).
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Final Initial Study–Negative Declaration 7
CALIFORNIA CLIMATE CHANGE SCOPING PLAN UPDATE (2013)
In 2013, CARB approved the first update to the California Climate Change Scoping Plan. The 2013
Scoping Plan Update defined CARB climate change priorities for the next five years and set the
groundwork to reach post-2020 Statewide GHG emissions reduction goals. The 2013 Scoping Plan
Update highlighted California’s progress toward meeting the “near-term” 2020 GHG emission
reduction goals defined in the original Scoping Plan. It also evaluated how to align the State’s
longer-term GHG reduction strategies with other State policy priorities, including those for water,
waste, natural resources, clean energy, transportation, and land use.14
CALIFORNIA EXECUTIVE ORDER B-30-15
In 2015, the California governor issued Executive Order B-30-15, which established a Statewide mid-
term GHG reduction target of 40 percent below 1990 levels by 2030.
CALIFORNIA SENATE BILL 32
In 2016, the California legislature signed Senate Bill 32 (SB 32) into law, extending AB 32 by requiring
further reduction in Statewide GHG emissions to 40 percent below 1990 levels by 2030 (the other
provisions of AB 32 remain unchanged). On December 14, 2017, CARB adopted the 2017 Scoping
Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the
continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program,
as well as implementation of recently adopted policies and policies, such as SB 350 and SB 1383 (see
below).
CALIFORNIA CLIMATE CHANGE SCOPING PLAN UPDATE (2017)
In 2017, CARB approved the second update to the California Climate Change Scoping Plan. The 2017
Scoping Plan put an increased emphasis on innovation, adoption of existing technology, and
strategic investment to support its strategies. As with the 2013 Scoping Plan Update, the 2017
Scoping Plan Update does not provide project-level thresholds for land use development. Instead, it
recommends that local governments adopt policies and locally-appropriate quantitative thresholds
consistent with Statewide per-capita goals of six MTCO2e by 2030 and two MTCO2e by 2050.15
As stated in the 2017 Scoping Plan Update, these goals may be appropriate for plan-level analyses
(city, county, subregional, or regional level), but not for specific individual projects, because they
include all GHG emissions sectors in the State.
CALIFORNIA EXECUTIVE ORDER B-55-18
In 2018, the California governor issued Executive Order B-55-18, which established a new Statewide
goal of achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This
goal is in addition to the existing Statewide GHG reduction targets established by SB 32.
For more information on the Senate and Assembly Bills, Executive Orders, and Scoping Plans
discussed above, and to view reports and research referenced above, please refer to the following
websites: www.climatechange.ca.gov and www.arb.ca.gov/cc/cc.htm.
15 California Air Resources Board (CARB). 2017. AB 32 Scoping Plan. Available at: https://ww3.arb.ca.gov/cc/scopingplan/scopingp lan.htm
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
8
General Plan Designation and Zoning
The CAP would be implemented throughout the City and would occur in all General Plan
designations and in all zoning designations.
Description of Plan
2020 CAP Update
In response to the 2017 California Climate Change Scoping Plan, the City updated its baseline 2005
inventory and prepared a comprehensive, community-wide GHG emissions inventory update for the
2016 calendar year. The GHG emissions inventory update was completed in compliance with all
relevant protocols and guidance documents, including U.S. Community Protocol, Local Government
Operations Protocol (LGOP), the Global Protocol for Community Scale GHG Emissions (GPC), and the
Intergovernmental Panel on Climate Change (IPCC) Guidelines for National GHG Inventories. In
2016, San Luis Obispo’s total GHG emissions were estimated to be 339,290 MTCO2e. The City has
completed communitywide GHG emissions inventories for years 2005 and 2016, which are
summarized in Table 1. Table 2 also provides estimated 1990 GHG emissions levels for informational
purposes. As shown therein, communitywide GHG emissions declined by approximately 12 percent
between 2005 and 2016. The most notable changes occurred in the energy and solid waste sectors
due to increasing decarbonization of the State electricity grid, investments in energy efficiency, and
a decrease in the amount of solid waste generated.16
Table 1 City of San Luis Obispo 1990, 2005, & 2016 Communitywide GHG Emissions Levels
Sector
1990
(MT of CO2e)1
2005
(MT of CO2e)
2016
(MT of CO2e)
Percent Change
from 2005 to 2016
Transportation 191,580 225,390 212,980 -6%
Non-residential Energy 49,340 58,050 44,270 -24%
Residential Energy 47,130 55,450 39,410 -29%
Solid Waste 40,580 47,740 42,630 -11%
Total 328,630 386,630 339,290 -12%
MT = metric tons; CO2e = carbon dioxide equivalents
Note: Numbers are rounded to the nearest ten.
1 AB 32 sets a target of reducing GHG emissions to 1990 levels by 2020, which is considered equivalent to a 15 percent reductio n in
baseline 2005 levels according to the CARB (2008) Climate Change Scoping Plan. Therefore, to estimate 1990 emissions levels,
inventoried 2005 emissions from each sector were reduced by 15 percent.
Source: San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
Compared with the 2012 CAP, the 2020 CAP Update puts more emphasis on carbon-free electricity
and General Plan transportation mode split. Measures from the 2012 CAP Update were removed
and replaced with new foundational actions and supporting measures. The CAP Update builds upon
the goals of the 2012 CAP and is based on a more recent inventory for the City.
The CAP Update is organized into six pillars, each of which includes a long-term goal, measures, and
foundational actions. Altogether, these measures and foundational actions are intended to reduce
16 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
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Final Initial Study–Negative Declaration 9
communitywide GHG emissions by 43 percent below 1990 levels by 2030 and by 66 percent below
1990 levels by 2035, which provides substantial progress toward meeting the City carbon neutrality
goal while exceeding in time the State carbon neutrality goal. However, full implementation of the
2020 CAP Update would leave a gap of approximately 111,030 MTCO2e per year that would still
need to be addressed to achieve carbon neutrality. As such, the CAP Update acknowledges that
additional actions beyond those identified in the plan will be necessary to achieve carbon neutrality
and, therefore, provides a mechanism for updating and adopting a new climate action plan
connected to the biennial financial plan cycle.17 This allows for certainty in the updated schedule,
ensures that the carbon neutrality work is directly tied to the City’s financial decision making and
prioritization process and allows for constant integration of learning, best practices, and new
measures and technologies to further the City toward meeting its goal of carbon neutrality.
Furthermore, in order to execute the CAP, City staff would implement the following administrative
actions: regularly update the Climate Action Plan; monitor and report CAP implementation; ensure
transparency by reporting GHG and CAP information to public disclosure programs; and develop a
mitigation program for new development to illustrate consistency with the CAP. The proposed six
pillars/ goals, measures, and foundational actions of the 2020 CAP are listed below in Table 2.
Table 2 City of San Luis Obispo 2020 CAP Pillars, Measures, and Foundational Actions
Pillars/Goals Measure Foundational Action
Lead by Example
The goals of the “Lead by Example”
Pillar are to create of a Municipal
Action Plan by the year 2020 and
achieve carbon neutral government
operations by the year 2030. The
proposed measures and actions are
expected to reduce emissions by 7,500
MTCO2e by the year 2035.
Leadership 1 – Municipal
Carbon Neutrality Plan
Leadership 1.1 – Adopt a municipal carbon
neutrality plan in 2020.
Leadership 2 – Green
Local Economy
Leadership 2.1 – Include carbon neutrality, social
equity, and a focus on developing a green local
economy in the updated Economic Development
Strategic Plan.
Leadership 2.2 – Research methods to support
local contractors and labor.
Leadership 3 –
Community
Collaboration
Leadership 3.1 – Create a formal approach to
support and empower community collaboration
for climate action.
Clean Energy Systems
The goal of the “Clean Energy Systems”
Pillar is to achieve 100 percent carbon
free electricity by 2020. The proposed
measures and actions are expected to
reduce emissions by 26,050 by 2030
and 39,010 MTCO2e by the year 2035.
Energy 1 – Monterey Bay
Community Power
Energy 1.1 - Launch Monterey Bay Community
Power and achieve a 98% participation rate while
advocating for programs and that support equity
and achieve maximum local benefit.
Energy 2 – Local Grid
Reliability and Storage
Energy 2.1 - Work with MBCP and PG&E to
develop a regional grid reliability strategy.
Energy 3 – Natural Gas Energy 3.1 - Partner with SoCal Gas to research
options for reducing greenhouse gas emissions
associated with the existing natural gas grid.
Green Buildings
The goals of the “Green Buildings”
Pillar are to generate no net new
building emissions from on-site energy
Buildings 1 – Carbon
Neutral New Buildings
Buildings 1.1 - Adopt and implement the Clean
Energy Choice Program for New Buildings and
review opportunities for improvement in the
2022 code cycle.
17 San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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Pillars/Goals Measure Foundational Action
use by the year 2020 and achieve a 50
percent reduction in existing building
emissions (after accounting for MBCP)
by the year 2030. The proposed
measures and actions are expected to
reduce emissions by 11,980 in by 2030
and 26,740 MTCO2e by the year 2035.
Buildings 2 – Energy
Retrofitting
Buildings 2.1 - Conduct comprehensive retrofit
program study and develop and implement a
strategic and equity focused building retrofit
program by 2021.
Connected Community
The goals of the “Connected
Community” Pillar are to achieve the
General Plan Mode Split Objective by
the year 2030 and have 40 percent of
Vehicle Miles Travelled (VMT) come
from electric vehicles by the year 2030.
The proposed measures and actions
are expected to reduce emissions by
45,240 MTCO2e by 2030 and 64,170
MTCO2e by the year 2035.
Connected 1 –
Innovation and
Coordination
Connected 1.1 – Establish a consistent method
for tracking and reporting mode split metrics.
Connected 1.2 – Research and develop an
approach to a “Mobility as a Service” platform for
people to easily use all modes of low carbon
mobility in the City.
Connected 2 – Active
Transportation
Connected 2.1 – Complete Active Transportation
Plan and begin implementation immediately.
Connected 2.2 – Launch micro mobility program
by 2021.
Connected 3 – Parking Connected 3.1 – Establish a policy and strategic
approach to leveraging existing and new parking
garages for downtown residential and visitor
serving uses and to allow for further
implementation of the Downtown Concept Plan.
Connected 4 – Transit Connected 4.1 – Develop a transit electrification
strategic plan and begin implementing in 2020.
Connected 4.2 – Shorten transit headways
through accelerated implementation of the
existing Short-Range Transit Plan.
Connected 4.3 – Explore additional innovative
transit options in the 2022 Short-Range Transit
Plan (e.g., on-demand deviated routes, electric
fleet expansion, micro transit, Bus Rapid Transit,
Transit Signal Priority, etc.).
Connected 4.4 – Assess feasibility of a “free to
the user” transit ridership program.
Connected 5 – Housing Connected 5.1 – Complete the 2019-21 Housing
Major City Goal, including the Housing Element
of the General Plan Update and Flexible Zoning
Requirements for Downtown.
Connected 6 – Electric
Vehicles
Connected 6.1 – Develop and begin
implementing electric mobility plan to achieve a
goal of 40 percent electric vehicle miles traveled
(VMT) by 2035.
Circular Economy
The goals of the “Circular Economy”
Pillar are to achieve 75 percent
diversion of landfilled organic waste by
the year 2035, and 90 percent
diversion by the year 2035. The
Circular Economy 1 –
Organic Waste Diversion
Circular Economy 1.1 – Adopt an ordinance
requiring organic waste subscription for all
residential and commercial customers by 2022.
Circular Economy 1.2 – Develop and implement
program to increase edible food rescue by 20
percent.
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Final Initial Study–Negative Declaration 11
Pillars/Goals Measure Foundational Action
proposed measures and actions are
expected to reduce emissions by
37,410 MTCO2e by the year 2030 and
47,300 MTCO2e by the year 2035.
Circular Economy 1.3 – Develop and implement a
waste stream education program for
HOA/Property Managers and the commercial
sector.
Circular Economy 2 –
Administrative Capacity
Circular Economy 2.1 – Update the Municipal
Code solid waste section and bin enclosure
standards.
Circular Economy 2.2 – Develop a Solid Waste
section in the Utilities Department.
Natural Solutions
The goal of the “Natural Solutions”
Pillar is to increase carbon
sequestration on the San Luis Obispo
Greenbelt and Urban Forest through
compost application-based carbon
farming activities and tree planting.
These activities will be ongoing
through 2035. The proposed measures
and actions are expected to reduce
emissions by 3,610 MTCO2e by 2030
and 7,050 MTCO2e by the year 2035.
Natural Solutions 1 –
Carbon Farming
Natural Solutions 1.1 – Conduct Carbon Farming
Study and Pilot Project in 2020 and if feasible,
begin implementation by 2023.
Natural Solutions 2 –
Tree Planting
Natural Solutions 2.1 – Prepare the City’s first
Urban Forest Master Plan by 2021 and plant and
maintain 10,000 new trees by 2035.
Source: San Luis Obispo, City of. 2020. Draft Climate Action Plan Update.
Figure 3 and Table 3 summarize the communitywide GHG emissions forecast under three scenarios:
1) business-as-usual, 2) implementation of State laws and programs, and 3) implementation of State
laws and programs and the CAP. As shown therein, under the business-as-usual scenario,
communitywide GHG emissions are forecasted to increase by approximately 21 percent between
1990 and 2035 based on anticipated economic and population growth. However, with
implementation of State laws and programs, communitywide GHG emissions would decline by
approximately 22 percent between 1990 and 2035. Furthermore, full implementation of the CAP
alongside State laws and programs would reduce communitywide GHG emissions by approximately
66 percent below 1990 levels by 2035.
Figure 3 City of San Luis Obispo GHG Emissions Forecast, 2005 to 2035
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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Table 3 City of San Luis Obispo GHG Emissions Forecast Through 2035
Sector
1990
(MT of CO2e)
2005
(MT of
CO2e)
2016
(MT of
CO2e)
2030
(MT of CO2e)
2035
(MT of CO2e)
Percent
Change
(1990-
2035)
Business-as-Usual
Transportation 191,580 225,390 212,980 234,570 242,280 26%
Non-residential
Energy
49,340 58,050 44,270 51,860 54,880 11%
Residential
Energy
47,130 55,450 39,410 45,660 47,990 2%
Solid Waste 40,580 47,740 42,630 49,880 52,560 30%
Total 328,630 386,630 339,290 381,970 397,710 21%
Implementation of State Laws and Programs1
Transportation 191,580 225,390 212,980 161,290 142,830 (25%)
Non-residential
Energy
49,340 58,050 44,270 33,690 27,720 (44%)
Residential
Energy
47,130 55,450 39,410 35,660 33,180 (30%)
Solid Waste 40,580 47,740 42,630 49,880 52,560 30%
Total 328,630 386,630 339,290 280,520 256,290 (22%)
Implementation of State Laws and Programs and City’s Climate Action Plan
Transportation2 191,580 225,390 212,980 116,050 78,660 (59%)
Non-residential
Energy3
49,340 58,050 44,270 29,710 21,000 (57%)
Residential
Energy3
47,130 55,450 39,410 27,680 13,160 (72%)
Solid Waste4 40,580 47,740 42,630 12,470 5,260 (87%)
Carbon
Sequestration5
0 0 0 (3,610) (7,050) n/a
Total 328,630 386,630 339,290 182,300 111,030 (66%)
MT = metric tons; CO2e = carbon dioxide equivalents; () denotes a negative number
Note: Numbers are rounded to the nearest ten.
1 State laws and programs include State vehicle fuel efficiency standards, the Renewable Portfolio Standard, and triennial upda tes of
Title 24.
2 Includes implementation of Pillar 4: Connected Community.
3 Includes implementation of Pillar 2: Clean Energy Systems and Pillar 3: Green Buildings.
4 Includes implementation of Pillar 5: Circular Economy.
5 Includes implementation of Pillar 6: Natural Solutions.
Source: San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
Implementation of the CAP Update measures identified above could result in physical changes to
the environment that could potentially have an impact on the environment. While individual
projects resulting from these measures have not been identified for the purposes of this document,
the types of actions that could result from realization of the CAP measures are taken into account in
considering potential environmental impacts that could occur through implementation of the CAP
Initial Study
Final Initial Study–Negative Declaration 13
Update. For example, the use of carbon-free electricity discussed per the Clean Energy Systems
pillar may require the installation of new infrastructure to accommodate use and transmission of
alternative and renewable fuels. Similarly, the use of electric vehicles identified per Action
Connected 6.1 would require the installation of electric vehicle charging stations and supporting
infrastructure. Additionally, implementation of Actions Connected 2.1 through 2.3 may require the
installation of new bicycle or pedestrian facilities. These types of activities would introduce physical
changes, such as the temporary presence and operation of construction vehicles and equipment
during installation of required facilities, and the long-term presence of new facilities such as bike
and pedestrian facilities, solar arrays, and electric vehicle charging stations, which could alter
pedestrian and vehicular traffic patterns. Future plans or projects requiring discretionary approval
would be subject to environmental review under CEQA, and individual impact analyses will identify
required plan- or project-specific mitigation measures where applicable.
CEQA GHG Emissions Thresholds
In 2007, SB 97 acknowledged that climate change is an environmental issue that requires analysis in
California Environmental Quality Act (CEQA) documents, and in 2010 the California Natural
Resources Agency adopted amendments to the State CEQA Guidelines for the feasible mitigation of
GHG emissions or the effects of GHG emissions. The adopted guidelines gave lead agencies the
discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs
and climate change impacts. Specifically, Section 15183.5(b)(1)A -G of Title 14 of the California Code
of Regulations was amended to state that a qualified GHG Reduction Plan, or a Climate Action Plan,
may be used for tiering and streamlining the analysis of GHG emissions in subsequent CEQA project
evaluation, provided that the GHG Reduction Plan or CAP does the following:
▪ Quantifies GHG emissions both existing and projected over a specific period of time,
resulting from activities within a defined geographical area
▪ Establishes a level, based on substantial evidence, below which the contribution to
greenhouse gas emissions from activities covered by the plan would not be cumulatively
considerable
▪ Identifies and analyzes the GHG emissions resulting from specific actions or categories of
actions anticipated within the geographic area
▪ Specifies measures or a group of measures, including performance standards, that
substantial evidence demonstrates, if implemented on a project-by-project basis, would
collectively achieve the specified emissions level
▪ Establishes a mechanism to monitor the plan's progress toward achieving the level and to
require amendment if the plan is not achieving specified levels
▪ Be adopted in a public process following environmental review.
Therefore, the City proposes to also adopt quantitative efficiency thresholds for use in evaluating
whether a plan or project’s GHG emissions would result in a potentially significant environmental
impact under CEQA for plans or projects with pre-2030 buildout or initial operation years. The CEQA
GHG emissions thresholds would be applied to plans or projects that cannot tier from the
environmental analysis for the City’s CAP (as contained in this IS/ND) due to one of the following
circumstances, which are illustrated in Figure 4:
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
14
▪ The plan or project would not be consistent with the 2014 General Plan land use and zoning
designations for the project site and would result in greater GHG emissions than existing on-
site development; or
▪ The plan or project would not be consistent with the CEQA GHG Emissions Analysis
Compliance Checklist.
Figure 4 Determining CEQA GHG Emissions Analysis Methodology
These thresholds are set at the level of GHG emissions that new development would need to
achieve to be consistent with the CAP’s communitywide emissions reduction target of 43 percent
below 1990 emissions levels by 2030. The efficiency thresholds, listed below, are expressed in terms
of MTCO2e per service person18 and are applicable to plans or projects with pre-2030 buildout or
initial operational years:
18 Per the method used by the San Luis Obispo Community Development Department, the service popu lation is equal to the residential
population plus half the number of jobs (City of San Luis Obispo 2019).
Initial Study
Final Initial Study–Negative Declaration 15
▪ 0.7 per resident
▪ 0.7 per employee
▪ 0.9 per service person19
Efficiency thresholds for beyond 2030 would be established later in conjunction with subsequent
CAP Updates.
Plans or projects that do not tier from the City CAP Update IS/ND that would generate GHG
emissions in excess of these thresholds would result in a potentially significant impact on the
environment related to GHG emissions and climate change. Mitigation measures would be required
to be identified to reduce potentially significant impacts resulting from such plans or projects. Plans
or projects that are unable to reduce GHG emissions below these thresholds through
implementation of identified mitigation measures would result in a significant and unavoidable
environmental impact. The GHG Emissions Thresholds provide guidance during CEQA review and do
not propose development or changes to land use and zoning. Thus, implementation of the GHG
Emissions Thresholds would not have direct construction or operational impacts.
Cumulative Projects Scenario
For purposes of CEQA cumulative impacts analysis of the City of San Luis Obispo 2020 CAP Update,
the cumulative projects scenario is buildout of the San Luis Obispo General Plan per the 2014 Land
Use and Circulation Elements Update. The San Luis Obispo 2014 General Plan buildout assumes a
total population of 48,550 persons and 23,204 housing units by the horizon year of 2035.
Required Approvals
City of San Luis Obispo
Required approvals include:
▪ adoption of the CAP Update/GHG Emissions Thresholds Initial Study-Negative Declaration;
▪ approval of the CAP Update; and
▪ adoption of a CEQA GHG Emissions Thresholds resolution.
Although individual plans or projects may be implemented later under the umbrella of the CAP
Update, each individual plan or project would be subject to separate environmental review under
CEQA.
Other Public Agencies
The City of San Luis Obispo has sole approval authority over the CAP Update. There are no other
public agencies whose approval is required.
19 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
16
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Environmental Factors Potentially Affected
Final Initial Study–Negative Declaration 17
Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least
one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as
indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
□ Air Quality
□ Biological Resources □ Cultural Resources □ Energy
□ Geology/Soils □ Greenhouse Gas
Emissions
□ Hazards & Hazardous
Materials
□ Hydrology/Water Quality □ Land Use/Planning □ Mineral Resources
□ Noise □ Population/Housing □ Public Services
□ Recreation □ Transportation □ Tribal Cultural Resources
□ Utilities/Service Systems □ Wildfire □ Mandatory Findings
of Significance
Determination
Based on this initial evaluation:
■ I find that the proposed project COULD NOT have a significant effect on the environment,
and a NEGATIVE DECLARATION will be prepared.
□ I find that although the proposed project could have a significant effect on the
environment, there will not be a significant effect in this case because revisions to the
project have been made by or agreed to by the project proponent. A MITIGATED
NEGATIVE DECLARATION will be prepared.
□ I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed project MAY have a “potentially significant impact” or “less than
significant with mitigation incorporated” impact on the environment, but at least one
effect (1) has been adequately analyzed in an earlier document pursuant to applicable
legal standards, and (2) has been addressed by mitigation measures based on the earlier
analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is
required, but it must analyze only the effects that remain to be addressed.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
18
□ I find that although the proposed project could have a significant effect on the
environment, because all potential significant effects (a) have been analyzed adequately
in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b)
have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION,
including revisions or mitigation measures that are imposed upon the proposed project,
nothing further is required.
Lead Agency Representative Signature Date
Lead Agency Representative Printed Name Title
Environmental Checklist
Final Initial Study–Negative Declaration 19
Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Have a substantial adverse effect on a scenic
vista? □ □ ■ □
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings within a
state scenic highway? □ □ ■ □
c. In non-urbanized areas, substantially degrade
the existing visual character or quality of
public views of the site and its surroundings?
(Public views are those that are experienced
from a publicly accessible vantage point). If
the project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light or
glare that would adversely affect daytime or
nighttime views in the area? □ □ ■ □
1a, 1c. Would the project have a substantial adverse effect on a scenic vista? In non-urbanized areas,
substantially degrade the existing visual character or quality of public views of the site and its
surroundings? (Public views are those that are experienced from a publicly accessible vantage
point). If the project is in an urbanized area, would the project conflict with applicable zoning
and other regulations governing scenic quality?
The San Luis Obispo General Plan Conservation/Open Space and Circulation Elements identify
viewing corridors and scenic roadways with high or moderate value as well as visual landmarks.20,21
The applicable goals and policies from these City General Plan elements include:
▪ 9.1.1 Preserve Natural and Agricultural Landscapes: The City will implement the following
policies and will encourage other agencies with jurisdictions to do likewise:
□ Natural and agricultural landscapes that the City has not designated for urban use shall
be maintained in their current patterns of use.
20 San Luis Obispo, City of. 2014. General Plan Circulati on Element. Last amended in 2017. Available at:
https://www.slocity.org/home/showdocument?id=20412
21 San Luis Obispo, City of. 2006. General Plan Open Space and Conservation Element. Available at:
https://www.slocity.org/home/showdocument?id=6651
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
20
□ Any Development that is permitted in natural or agricultural landscapes shall be visually
subordinate to and compatible with the landscape features. Development includes, but
is not limited to buildings, signs (including billboard signs), roads, utility and
telecommunication lines and structures. Such development shall:
− Avoid visually prominent locations such as ridgelines, and slopes exceeding 20
percent.
− Avoid unnecessary grading, vegetation removal, and site lighting.
− Incorporate building forms, architectural materials, and landscaping, that respect
the setting, including the historical pattern of development in similar settings, and
avoid stark contrasts with its setting.
− The City’s non-emergency repair, maintenance, and small construction projects in
highly visible locations, such as hillsides and downtown creeks, where scenic
resources could be affected, shall be subject to at least “minor or incidental”
architectural review.
▪ 9.1.3 Utilities and Signs: In and near public streets, plazas, and parks, features that clutter,
degrade, intrude on, or obstruct views shall be avoided. Necessary features, such as utility
and communication equipment, and traffic equipment and signs should be designed and
placed so as to not impinge upon or degrade scenic views of the Morros or surrounding
hillsides, or farmland, consistent with the primary objective of safety. New billboard signs
shall not be allowed, and existing billboard signs shall be removed as soon as practicable, as
provided in the Sign Regulations.
▪ 9.1.5 View Protection in New Development: The City will include in all environmental review
and carefully consider effects of new development, streets, and road construction on views
and visual quality by applying the Community Design Guidelines, height restrictions, hillside
standards, Historical Preservation Program Guidelines, and the California Environmental
Quality Act and Guidelines.
▪ 9.2.1 Views to and from Public Places, including Scenic Roadways: The City will preserve and
improve views of important scenic resources from public places and encourage other
agencies with jurisdiction to do so. Public places include parks, plazas, the grounds of civic
buildings, streets and roads, and publicly accessible open space. In particular, the route
segments shown in Figure 10 are designated as scenic roadways.
□ Development projects shall not wall off scenic roadways and block views.
□ Utilities, traffic signals, and public and private signs and lights shall not intrude on or
clutter views, consistent with safety needs.
□ Where important vistas of distant landscape features occur along streets, street trees
shall be clustered to facilitate viewing of the distant features.
□ Development projects, including signs, in the viewshed of a scenic roadway shall be
considered “sensitive” and require architectural review.
▪ 9.3.5 Visual Assessments: Require evaluations (accurate visual simulations) for projects
affecting important scenic resources and views from public places.
▪ 9.3.6 View Blockage along Scenic Highways: Determine that view blockage along scenic
roadways is a significant impact.
▪ 9.3.9 Undergrounding Utilities: Place existing overhead utilities underground, with highest
priority for scenic roadways, entries to the city, and historical districts.
Environmental Checklist
Final Initial Study–Negative Declaration 21
The GHG Emissions Thresholds provide guidance during CEQA review and does not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to scenic vistas, visual
character, and scenic quality. The CAP Update would not involve land use or zoning changes. Rather,
the CAP Update would promote infrastructure development and redevelopment that is already
accounted for in the General Plan and is assessed in the General Plan EIR. As a policy document, the
CAP Update would not result in impacts related to scenic vistas and visual character. However,
implementation of the following CAP Update foundational actions and measures may promote
infrastructure development and redevelopment.
The CAP Update includes Action Buildings 2.1, which could include installation of on-site solar arrays
within the City. Action Connected 6.1 would require the installation of electric vehicle charging
stations and supporting infrastructure. Additionally, implementation of Actions Connected 2.1
through 2.3 may require the installation of new bicycle or pedestrian facilities. Additionally,
Measure Natural Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires
planting and maintaining 10,000 new trees by the year 2035. Planting new street trees and private
trees may slightly change the visual character of the City. As such, the CAP Update could result in
impacts related to scenic vistas and visual character in rural areas or scenic quality in urban areas.
However, discretionary development would be required to adhere to City development regulations
and General Plan policies, including San Luis Obispo Street Tree Ordinance No. 1544, to retain
character of the City and minimize environmental impacts. In addition, discretionary development
would be reviewed for consistency with the General Plan and other applicable regulatory land use
actions prior to approval. Thus, the CAP Update would result in a less than significant impact
related to scenic vistas and visual character or scenic quality.
1b. Would the project substantially damage scenic resources, including but not limited to, trees, rock
outcroppings, and historic buildings within a State scenic highway?
The City’s General Plan Conservation and Open Space Element and Circulation Element identifies
viewing scenic roadways with high or moderate value, including but not limited to portions of U.S.
Highway 101, South Higuera Street, Broad Street, Tank Farm Road, Los Osos Valley Road, and Santa
Rosa Street.22 In 1996, the City established a permanent open space greenbelt at the edge of the
community.
The GHG Emissions Thresholds provide guidance during CEQA review and does not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to visual character and
scenic quality. The CAP Update would not involve land use or zoning changes. Rather, the CAP
Update would promote infrastructure development and redevelopment that is already accounted
for in the General Plan and is assessed in the General Plan EIR. As a policy document, the CAP
Update would not result in impacts related to scenic resources such as trees, rock outcroppings, and
historic buildings in a State scenic highway. However, implementation of the following CAP Update
foundational actions and measures may promote infrastructure development and redevelopment.
The CAP Update includes Action Buildings 2.1, which could include installation of on-site solar arrays
within the city. Action Connected 6.1 would require the installation of electric vehicle charging
stations and supporting infrastructure. Additionally, implementation of Actions Connected 2.1
through 2.3 may require the installation of new bicycle or pedestrian facilities. Additionally,
22 San Luis Obispo, City of. 2014. General Plan Circulation Element. Last amended in 2017. Available at:
https://www.slocity.org/home/showdocument?id=20412
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
22
Measure Natural Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires
planting and maintaining 10,000 new trees by the year 2035. Planting new street trees and private
trees may change such scenic resources within a State- or City-designated viewing scenic roadway.
However, discretionary development would be required to adhere to City development regulations,
General Plan policies, and the San Luis Obispo Street Ordinance No. 1544, in order to retain
character of the City and minimize environmental impacts. In addition, discretionary development
would be reviewed for consistency with the General Plan and other applicable regulatory land use
actions prior to approval. Thus, the CAP Update and GHG Emissions Thresholds would result in a
less-than-significant impact related to scenic resources such as trees, rock outcroppings, and
historic buildings in a State scenic highway.
1d. Would the project create a new source of substantial light or glare that would adversely affect
daytime or nighttime views in the area?
The GHG Emissions Thresholds provide guidance during CEQA review and does not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to light and glare. The CAP
Update would not involve land use or zoning changes. Rather the CAP Update would promote
infrastructure development and redevelopment that is already accounted for in the General Plan
and is assessed in the General Plan EIR. As a policy document, the CAP Update would not directly
result in impacts related to light and glare. However, implementation of the following CAP Update
foundational actions and measures may promote infrastructure development and redevelopment.
The CAP Update includes Action Buildings 2.1, which could include installation of on-site solar arrays
within the City that could result in new glare. Additionally, Action Connected 6.1 would require the
installation of electric vehicle charging stations and supporting infrastructure, and implementation
of Actions Connected 2.1 through 2.3 may require the installation of new bicycle or pedestrian
facilities that could result in new light or glare. However, discretionary development would be
required to adhere to City development regulations and General Plan policies to minimize
environmental impacts. In addition, discretionary development would be reviewed for consistency
with the General Plan and other applicable regulatory land use actions prior to approval. Thus, the
CAP Update and GHG Emissions Thresholds would result in a less-than-significant impact related to
light and glare.
Cumulative Impacts
As determined in the General Plan Land Use and Circulation Elements Update EIR, all development
that adheres to the General Plan policies, including General Plan buildout, would result in less-than-
significant aesthetic impacts. Cumulative General Plan buildout could impact scenic vistas, visual
character, and scenic quality as development intensity increases; however, this change is consistent
with the General Plan vision for the rural and urban environments of the City. As such, cumulative
impacts related to scenic vistas, visual quality, and scenic quality would be less than significant.
Although impacts to light and glare could incrementally change due to implementation of the CAP
Update, this change is anticipated to be minimal and consistent with the General Plan vision of the
City. As such, cumulative impacts related to light and glare would be less than significant.
Furthermore, as a guidance document, the GHG Emissions Thresholds would not result in
cumulative impacts. Therefore, implementation of the CAP Update and GHG Emissions Thresholds
would result in an overall less-than-significant cumulative impact related to aesthetics.
Environmental Checklist
Final Initial Study–Negative Declaration 23
2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ ■ □
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ ■ □
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or conversion
of forest land to non-forest use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest use? □ □ □ ■
2a, 2b, 2e. Would the project:
▪ Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
(Farmland), as shown on maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non -agricultural use?
▪ Conflict with existing zoning for agricultural use or a Williamson Act contract?
▪ Involve other changes in the existing environment which, due to their location or
nature, could result in conversion of Farmland to non -agricultural use?
Chapter 17.12 of the San Luis Obispo Municipal Code outlines development standards for the
Agricultural (AG) Zone.23 Properties currently zoned AG are concentrated in the southern city
boundary, near Buckley Road, and northwestern city boundary.24 Additionally, most of the land
23 San Luis Obispo, City of. Municipal Code. Available at: https://sanluisobispo.municipal.codes/Code/1 7.12
24 San Luis Obispo, City of. Zoning Map. Available at: https://www.slocity.org/home/showdocument?id=5857
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
24
within the City’s greenbelt is designated by the County for agriculture or open space. Agricultural
lands allow agricultural cultivation and keeping livestock as well as single family detached dwellings
and public and quasi-public land uses.
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not result in construction or operational impacts related to conversion of
agricultural land to non-agriculture uses. The CAP Update would also not involve land use or zoning
changes. Rather the CAP Update would address infrastructure development that is already
accounted for in the General Plan and assessed in the General Plan EIR.
As a policy document, the CAP Update would not result in impacts related to conversion or loss of
farmland. Nevertheless, implementation of Action Natural Solutions 1.1 facilitates conducting a
carbon farming study and pilot program at Johnson Ranch Open Space and City Farm (also known as
“Calle Joaquin Agricultural Reserve”) starting in 2020, with monitoring through 2023. Common
agricultural uses, including driving a tractor, tilling the soil, over-grazing, using fossil fuel-based
fertilizers, pesticides and herbicides result in carbon dioxide (CO2) release. Alternatively, carbon can
be stored long term (decades to centuries or more) beneficially in soils in a process called soil
carbon sequestration. Carbon Farming involves implementing practices that are known to improve
the rate at which CO2 is removed from the atmosphere and converted to plant material and/or soil
organic matter. If determined feasible and cost-effective, compost would be applied to the first
annual 100 acres by the year 2023. Physical implementation of carbon farming could include
compost application surrounding existing grazeland areas. As such, the CAP Update could result in
minor disruption or minor conversion of agricultural lands. However, carbon farming would be
beneficial to agricultural uses, because it would likely increase rangeland or crop productivity.
Therefore, the CAP Update and GHG Emissions Thresholds would result in a less-than-significant
impact related to degradation of agricultural resources or conversion of agricultural land to non-
agriculture uses, nor would there be a conflict with existing zoning.
2c, 2d, 2e. Would the project:
▪ Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public
Resources Code Section 12220(g)); timberland (as defined by Public Resources Code
Section 4526); or timberland zoned Timberland Production (as defined by Government
Code Section 51104(g))?
▪ Result in the loss of forest land or conversion of forest la nd to non-forest use?
▪ Involve other changes in the existing environment which, due to their location or
nature, could result in conversion of forest land to non -forest use?
The City does not contain forest or timberland resources.25 Therefore, the CAP Update and GHG
Emissions Thresholds would result in no impact related to degradation of forestry resources or
conversion of forest land to non-forest uses, nor would there be a conflict with existing zoning.
25 California Department of Fish and Wildlife. California Forests and Timberlands in the California Department of Fish and Wildl ife
Regions. Available at: https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109919&inline
Environmental Checklist
Final Initial Study–Negative Declaration 25
Cumulative Impacts
As discussed in the General Plan Land Use and Circulation Elements Update EIR, adherence to
General Plan policies and applicable State and Federal regulatory requirements would reduce
cumulative agriculture and forestry resources impacts resulting from buildout of the City under the
General Plan to a less-than-significant level. Implementation of the CAP Update would not involve
land use or zoning changes that would result in cumulative impacts related to conversion or loss of
farmland or forest land. Furthermore, as a guidance document, the GHG Emissions Thresholds
would not result in cumulative impacts. Thus, implementation of the CAP Update would result in a
less-than-significant cumulative impact related to agricultural and forestry resources.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
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Environmental Checklist
Final Initial Study–Negative Declaration 27
3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Conflict with or obstruct implementation of
the applicable air quality plan? □ □ □ ■
b. Result in a cumulatively considerable net
increase of any criteria pollutant for which
the project region is non-attainment under an
applicable federal or state ambient air quality
standard? □ □ ■ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
3a. Would the project conflict with or obstruct implementation of the applicable air quality plan?
San Luis Obispo is located in the South Central Coast Air Basin (the Air Basin), which includes San
Luis Obispo, Santa Barbara, and Ventura Counties. The plan area is under the jurisdiction of the San
Luis Obispo County Air Pollution Control District (SLOCAPCD). As the local air quality management
agency, SLOCAPCD is required to monitor air pollutant levels to ensure that State and Federal air
quality standards are met and, if they are not met, to develop strategies to meet the standards.
Depending on whether or not the standards are met or exceeded, San Luis Obispo County is
classified as being in “attainment” or “nonattainment.” Under State law, air districts are required to
prepare a plan for air quality improvement for pollutants for which the district is in non -attainment.
San Luis Obispo County is designated as nonattainment for the State standards for suspended
particulate matter (PM10) and ozone.26 San Luis Obispo County is designated as attainment or
unclassified for all other Federal and State standards.
In 2002, SLOCAPCD adopted the 2001 Clean Air Plan, and in 2005 SLOCAPCD adopted a Particulate
Matter Report in order to update the jurisdiction’s control measures for particulate matter, as
required by SB 656. In 2015, SLOCAPCD adopted an Ambient Air Monitoring Network Assessment in
order to identify and analyze its historic and current air monitoring sites. In 2019, SLOAPD updated
the Ambient Air Monitoring Network Assessment and adopted an Ozone Emergency Episode Plan, in
compliance with the Federal Clean Air Act, in order to provide the basis for taking actions when
ambient ozone concentrations reach a level that could endanger public health in San Luis Obispo
County. The sources, health effects, and typical controls associated with criteria pollutants are
described in Appendix A.
26 California Air Resources Control Board (CARB). 2017. AB 32 Scoping Plan. Available at:
https://ww3.arb.ca.gov/cc/scopingplan/scopingplan.htm
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
28
The Federal Clean Air Act Amendments (CAAA) mandate that states submit and implement a State
Implementation Plan (SIP) for areas not meeting air quality standards. The SIP includes pollution
control measures to demonstrate how the standards will be met through those measures. The SIP is
established by incorporating measures established during the preparation of Air Quality
Management Plans (AQMP) and adopted rules and regulations by each local APCD and AQMD,
which are submitted for approval to CARB and the U.S. EPA.27 The goal of an AQMP is to reduce
pollutant concentrations below the National Ambient Air Quality Standards (NAAQS) through the
implementation of air pollutant emissions controls.
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts. Additionally, the CAP Update would not involve land
use or zoning changes. Rather the CAP Update would promote infrastructure development and
redevelopment that is already accounted for in the General Plan and is assessed in the General Plan
EIR. Implementation of proposed foundational actions and supporting measures would be beneficial
by helping San Luis Obispo meet applicable air quality plan goals and generally reduce sensitive
receptor exposure to pollutant concentrations. Although the purpose and intended effect of the
CAP Update is to reduce GHG emissions generated in the City to help reduce the effects of climate
change, many of its actions would also reduce air quality emissions. The CAP Update includes Action
Connected 4.1 which would develop a strategic electrification plan for the City’s transit fleet, which
would reduce diesel fuel combustion in the City. Action Connected 1.2 is aimed at making active
transportation and transit more accessible, therefore reducing the number of on-road vehicles trips.
Action Circular Economy 1.1 would require organic waste subscription for all residential and
commercial customers, which would lower the total amount of waste diverted to the landfill. These
actions would reduce air quality emissions as well as GHG emissions. Thus, the CAP Update and GHG
Emissions Thresholds are consistent with the 2001 Clean Air Plan and would have no impact related
to a conflict with or obstruction of the applicable air quality plan.
3b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for
which the project region is non-attainment under an applicable federal or State ambient air
quality standard (including releasing emissions that exceed quantitative thresholds for ozone
precursors)?
The GHG Emissions Thresholds provide guidance during CEQA review and does not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not result in construction or operational impacts related to an increase of criteria
pollutants. The CAP Update would not involve land use or zoning changes. Rather the CAP Update
would promote infrastructure development and redevelopment that is already accounted for in the
General Plan and is assessed in the General Plan EIR. As a policy document, the CAP Update would
not result in impacts related to criteria pollutants. However, implementation of the following CAP
Update foundational actions and measures may promote infrastructure development and
redevelopment.
Action Buildings 2.1, which could include installation of on-site solar arrays within the city. Action
Connected 6.1 would require the installation of electric vehicle charging stations and supporting
infrastructure. Additionally, implementation of Actions Connected 2.1 through 2.3 may require the
installation of new bicycle or pedestrian facilities. Construction-related impacts to air quality are
generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy
27 CARB. 2016. State SIP Strategy. Available at: https://ww3.arb.ca.gov/planning/sip/2016sip/2016sip.htm
Environmental Checklist
Final Initial Study–Negative Declaration 29
construction vehicles and soil hauling trucks, in addition to ROG that would be released during the
drying phase upon application of architectural coatings. However, implementation of proposed
foundational actions would not include large-scale construction within San Luis Obispo. Therefore, it
would result in low-level criteria pollutant emissions and negligible impacts to air quality.
Discretionary development would be required to undergo CEQA review, including assessment and
mitigation incorporation, and compliance with SLOAPCD air quality regulations and other applicable
local, State, and Federal regulations once project details and locations are known. Thus, the
construction required for implementation of the CAP Update would result in a less-than-significant
impact related to net increase of criteria pollutants.
With respect to operational emissions, many CAP Update measures and foundational actions would
have the secondary benefit of reducing criteria pollutant emissions. Foundational actions and
supporting measures aim to increase building energy efficiency, promote carbon neutral energy,
promote electric vehicles, reduce on-road gasoline fuel use, reduce vehicle miles traveled and
promote travel via low- and zero-emissions modes, and improve soil sequestration through carbon
farming. Implementation of foundational actions and the supporting measures would be beneficial
by helping San Luis Obispo meet applicable air quality plan goals. In addition, future discretionary
development projects constructed within the City would undergo project-level CEQA review once
details and locations are known. Therefore, the CAP Update and GHG Emissions Thresholds would
result in a less-than-significant impact related to criteria pollutant emissions.
3c. Would the project expose sensitive receptors to substantial pollutant concentrations?
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not result in construction or operational impacts related to exposure of sensitive
receptors to substantial pollutant concentrations. Implementation of the following CAP Update
measures and foundational actions may promote infrastructure development and redevelopment.
Action Buildings 2.1 could include installation of on-site solar arrays within the city. Action
Connected 6.1 would require the installation of electric vehicle charging stations and supporting
infrastructure. Additionally, implementation of Actions Connected 2.1 through 2.3 may require the
installation of new bicycle or pedestrian facilities. Construction-related impacts to air quality are
generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy
construction vehicles and soil hauling trucks, in addition to ROG that would be released during the
drying phase upon application of architectural coatings. However, implementation of proposed CAP
Update foundational actions would not include large-scale construction within San Luis Obispo.
Therefore, it would result in low-level toxic air contaminant emissions. While the CAP Update could
result in construction-related impacts related to toxic air contaminants and exposure to sensitive
receptors, discretionary development would be required to undergo CEQA review, including
assessment and mitigation incorporation, and compliance with SLOAPCD air quality regulations and
other applicable local, State, and Federal regulations once project details and locations are known.
Thus, the construction associated with implementation of the CAP Update would not result in
substantial emissions of toxic air contaminants and exposure to sensitive receptors. No operational
toxic air contaminant emissions are anticipated with implementation of the CAP Update
foundational actions. Therefore, the CAP Update and GHG Emissions Thresholds would have a less-
than-significant impact related to exposure of sensitive receptors to toxic air contaminants.
3d. Would the project result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people?
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
30
The CARB 2005 Air Quality Land Use Handbook: A Community Health Perspective identifies land
uses associated with odor complaints which include: sewage treatment plants, landfills, recycling
facilities, waste transfer stations, petroleum refineries, biomass operations, auto body shops,
coating operations, fiberglass manufacturing, foundries, rendering plants, and livestock
operations.28 The GHG Emissions Thresholds provide guidance during CEQA review and do not
propose development or changes to land use and zoning. Thus, implementation of the GHG
Emissions Thresholds would not have construction or operational impacts related to odors. The CAP
Update includes Climate Actions Circular Economy 1.1 through 1.3, which would require organic
waste subscription for all residential and commercial customers, 20 percent increase in edible food
rescue, and development and implementation of a waste stream education program for
homeowner associations (HOA) and property managers. Additionally, Climate Action Natural
Solutions 1.1 proposes conducting a carbon farming study and pilot program at Johnson Ranch
Open Space and City Farm starting in the year 2020, with monitoring through to the year 2023.
Carbon Farming involves implementing practices that are known to improve the rate at which CO2 is
removed from the atmosphere and converted to plant material and/or soil organic matter. I f
determined feasible and cost-effective, compost would be applied to the first annual 100 acres by
the year 2023. Physical implementation of carbon farming could include compost application at
Johnson Ranch Open Space and City Farm (also known as “Calle Joaquin Agricultural Reserve”). As
such, the CAP Update could result in minor odors related to compost. However, carbon farming
locations are limited to rural portions of the community that are moderately distant from residential
development. Additionally, green waste collection bins and compost application are not identified
on the list of “Sources of Odor Complaints” (Table 1-4) as provided in the CARB Air Quality Land Use
Handbook and would not be anticipated to result in other emissions, such as those leading to odors,
adversely affecting a substantial number of people.29 Therefore, the CAP Update and GHG
Thresholds would not facilitate development that could create odors, and there would be a less-
than-significant impact related to odors exposure.
Cumulative Impacts
The City of San Luis Obispo General Plan buildout would not exceed applicable San Luis Obispo Air
Pollution Control District (SLOAPCD) thresholds and is consistent with the Clean Air Plan. As such,
implementation of the CAP Update and GHG Emissions Thresholds would have a less than significant
cumulative impact related to the air quality within the air basin and on sensitive receptors within
the City of San Luis Obispo. Implementation of the CAP Update would not result in adverse impacts
related to contribution of criteria pollutants to the air basin and exposure of sensitive receptors to
toxic air contaminants. Furthermore, as a guidance document, the GHG Emissions Thresholds would
not result in cumulative impacts. Therefore, implementation of the CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to air quality.
28 California Air Resources Control Board (CARB). 2005. Air Quality and Land Use Handbook: A Community Health Perspective. Avail able
at: https://ww3.arb.ca.gov/ch/handbook.pdf
29 CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. Available at:
https://ww3.arb.ca.gov/ch/handbook.pdf
Environmental Checklist
Final Initial Study–Negative Declaration 31
4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ □ ■ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ ■ □
c. Have a substantial adverse effect on state or
federally protected wetlands (including, but
not limited to, marsh, vernal pool, coastal,
etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ ■ □
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ ■ □
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ □ ■
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or State habitat
conservation plan? □ □ □ ■
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
32
4a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as candidate, sensitive, or special status in local or
regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the
U.S. Fish and Wildlife Service?
San Luis Obispo is a primarily urbanized community with neighborhood parks, community parks,
mini parks, recreational and open spaces incorporated throughout, and a greenbelt extending from
the urban fringes to the City limits.30 The City’s Municipal Code Section 12.22, General Plan
Conservation and Open Space Element as well as the Conservation Guidelines for Open Space Lands
of the City of San Luis Obispo (Conservation Guidelines) incorporate goals and policies to protect
biological resources in rural areas of the City.
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to habitat modification. The
CAP Update would not involve land use or zoning changes. Rather the CAP Update would address
infrastructure development and redevelopment that is already accounted f or in the General Plan
and is assessed in the General Plan EIR. As a policy document, the CAP Update would not directly
result in impacts related to wildlife species identified as candidate, sensitive, or special status.
However, implementation of the following CAP Update foundational actions and measures may
promote infrastructure development and redevelopment and may result in impacts to species
through habitat modification for purposes of infrastructure installation.
The CAP Update includes Action Natural Solutions 1.1, which facilitates carbon farming in the form
of compost application at Johnson Ranch Open Space and City Farm (also known as “Calle Joaquin
Agricultural Reserve”). As such, the CAP Update could result in minor habitat modifications due to
organic nitrogen to grassland habitats where sensitive status plant species may occur. However,
peer-reviewed research indicates that application of organic nitrogen-rich compost does not change
or adversely affect botanical species.31 Additionally, carbon farming implementation would
specifically be located to avoid serpentine soils. Thus, impacts related to carbon farming would be
less than significant.
The CAP Update also includes Action Buildings 2.1, which could include installation of on-site solar
arrays within the City. Action Connected 6.1 would require the installation of electric vehicle
charging stations and supporting infrastructure. Additionally, implementation of Actions Connected
2.1 through 2.3 may require the installation of new bicycle or pedestrian facilities. Additionally,
Measure Natural Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires
planting and maintaining 10,000 new trees by the year 2035. Future related projects would be
required to undergo CEQA review, including assessment and mitigation incorporation once project
details and locations are known. These CAP Update foundational actions would not conflict with the
Municipal Code or objectives and policies of the General Plan or Conservation Guidelines but would
rather be consistent with and promote those plans. The pillars, supporting measures, and
foundational actions included in the CAP Update would generally apply to the urbanized areas of
the City, with little application to parks, open spaces area, or other locations where sensitive habitat
and related species may be present. As such, the CAP Update itself would not have a substantial
30 San Luis Obispo, City of. Parks and Recreation Facilities in San Luis Obispo. Available at:
https://www.slocity.org/home/showdocument?id=2270
31 Whendee, Silver et al. Grassland Compost Amendments Increase Plant Production Without Changing Plant Communitie s. Available at:
https://www.marincarbonproject.org/file/2018 -documents/5_Grassland-compost-amendments-increase-plant-production-without-
changing-plant-communities.pdf
Environmental Checklist
Final Initial Study–Negative Declaration 33
adverse effect on special-status wildlife species either directly through individual take or indirectly
through species habitat modification. Therefore, the CAP Update and GHG Emissions Thresholds
would result in a less-than-significant impact related to special-status wildlife species.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
34
4b, 4c. Would the project have a substantial adverse effect on any riparian habitat or other sensitive
natural community (such as State or federally protected wetlands, including, but not limited
to, marsh, vernal pool, coastal, etc.) identified in local or regional plans, policies, or
regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildl ife
Service through direct removal, filling, hydrological interruption, or other means?
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to riparian or other special
habitats. The CAP Update would not involve land use or zoning changes. Rather the CAP Update
would address infrastructure development and redevelopment that is already accounted for in the
General Plan and is assessed in the General Plan EIR. As a policy document, the CAP Update could
result in impacts related to habitat whether riparian, wetland, or other sensitive natural community .
The pillars, supporting measures, and foundational actions included in the CAP Update would
generally apply to the urbanized areas of the City, with little application to parks, open spaces area,
or other locations where sensitive habitat and related species may be present. The CAP Update
includes Action Buildings 2.1, which could include installation of on-site solar arrays within the City.
Action Connected 6.1 would require the installation of electric vehicle charging stations and
supporting infrastructure. Additionally, implementation of Actions Connected 2.1 through 2.3 may
require the installation of new bicycle or pedestrian facilities. Additionally, Measure Natural
Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires planting and
maintaining 10,000 new trees by the year 2035. Future related projects would be required to
undergo CEQA review, including assessment and mitigation incorporation once project details and
locations are known. These CAP Update foundational actions would not conflict with the Municipal
Code or objectives and policies of the General Plan or Conservation Guidelines but would rather be
consistent with and promote those plans. The pillars, supporting measures, and foundational
actions included in the CAP Update would generally apply to the urbanized areas of the City, with
little application to parks, open spaces area, or other locations where sensitive habitat and related
species may be present. As such, the CAP Update would not have a substantial adverse effect on
riparian habitat or sensitive natural community, such as wetlands. Therefore, the CAP Update and
GHG Emissions Thresholds would have a less-than-significant impact related to sensitive natural
plant communities.
4d. Would the project interfere substantially with the movement of any native resident or migratory
fish or wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to interference with species
movement. The CAP Update would not involve land use or zoning changes. Rather the CAP Update
would promote infrastructure development and redevelopment that is already accounted for in the
General Plan and is assessed in the General Plan EIR. As a policy document, the CAP Update would
not result in impacts related to interference with species movement. However, implementation of
the following CAP Update foundational actions and measures may promote infrastructure
development and redevelopment.
The CAP Update includes actions (Connected 2.1 through 2.3, Connected 4.1 through 4.4) that
would support pedestrian and bicycle circulation and improved transportation alternatives, which
Environmental Checklist
Final Initial Study–Negative Declaration 35
would improve connectivity throughout the City. Actions Connected 2.1 and 2.4 aim to prioritize an
Active Transportation Plan and implement and develop quick-build strategies to streamline
implementation of priority bicycle and pedestrian infrastructure projects, which would in turn
increase the walkability of the City and decrease vehicle miles traveled. Action Connected 2.2
facilitates launching a micro-mobility program in the form of electric bikes, which would increase
active transportation and decrease the vehicle miles traveled. Future related projects would be
required to undergo CEQA review, including assessment and mitigation incorporation once project
details and locations are known. These CAP Update foundational actions would not conflict with the
Municipal Code or objectives and policies of the General Plan or Conservation Guidelines but would
rather be consistent with and promote those plans. The pillars, supporting measures, and
foundational actions included in the CAP Update would generally apply to the urbanized areas of
the City, with little application to parks, open spaces area, or other locations where wildlife
corridors or native wildlife nursery sites may be present. Therefore, the CAP Update and GHG
Emissions Thresholds would result in a less-than-significant impact related to interference with
species movement.
4e. Would the project conflict with any local policies or ordinances protecting biological resources,
such as a tree preservation policy or ordinance?
The City of San Luis Obispo’s Municipal Code Section 12.22 as well as the General Plan Conservation
and Open Space Element and the Conservation Guidelines incorporate goals and policies for
resource protection within the City limits and the City’s greenbelt32. Additionally, the City has
passed the Street Tree Ordinance which was established to preserve the trees and plantings on City
property and enhance the ecological benefit to the community by providing for the regulation of
planting, management, maintenance, preservation and, where necessary, removal of public trees.
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not have construction or operational impacts related to biological resources. The
CAP Update would not involve land use or zoning changes. Rather, the CAP Update would address
infrastructure development and redevelopment that is already accounted for in the General Plan
and is assessed in the General Plan EIR. The purpose and intended effect of the CAP Update is to
reduce GHG emissions generated in the city to help reduce the effects of climate change.
Implementation of proposed foundational actions and supporting measures would be beneficial by
helping San Luis Obispo meet applicable local policies and ordinances for protecting biological
resources. The CAP Update would not conflict with or obstruct implementation of the applicable
policies for preserving biological resources and would not affect the City’s ability to attain goals and
policies that protect biological resources. Therefore, the CAP Update and GHG Emissions Thresholds
would result in no impact related to consistency with local biological resources protection policies.
4f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or State habitat conservation
plan?
The City’s Municipal Code, General Plan Conservation and Open Space Element, and the
Conservation Guidelines include mapping of land approved for habitat conservation as well as goals
and policies to protect biological resources in rural areas of the City. And specifically, there is the
32 San Luis Obispo, City of. 2006. General Plan Open Space and Conservation Element. Avai lable at:
https://www.slocity.org/home/showdocument?id=6651
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
36
adopted Johnson Ranch Conservation Plan located in the southern portion of the City and aimed at
preserving natural areas. The GHG Emissions Thresholds provide guidance during CEQA review and
do not propose development or changes to land use and zoning. Thus, implementation of the GHG
Emissions Thresholds would not have construction or operational impacts related to conflict with an
adopted Habitat Conservation Plan. The CAP Update includes Action Natural Solutions 1.1, which
requires conducting a carbon farming study and pilot program at Johnson Ranch Open Space and
City Farm starting in the year 2020, with monitoring through to the year 2023. Carbon Farming
involves implementing practices that are known to improve the rate at which CO2 is removed from
the atmosphere and converted to plant material and/or soil organic matter. If determined feasible
and cost-effective, compost would be applied to the first annual 100 acres by the year 2023.
Furthermore, all goals and policies included in the Johnson Ranch Conservation Plan would apply.
The CAP Update would not facilitate specific development projects, nor would it add or enable new
development that would conflict with the adopted Municipal Code, General Plan, the Conservation
Guidelines, or other approved local, regional, or State habitat conservation plan. Therefore, the CAP
Update and GHG Emissions Thresholds would have no impact related to consistency with an
adopted habitat or natural community conservation plan.
Cumulative Impacts
As described in the General Plan Land Use and Circulation Elements Update EIR, with incorporation
of required project-level mitigation measures to implement program-level mitigation and
compliance with applicable General Plan policies and applicable State and federal regulatory
requirements, cumulative impacts related to biological resources resulting from buildout of the City
under the General Plan, including buildout of the San Luis Ranch Specific Plan, would be significant
but mitigable. The CAP Update would promote infrastructure development and redevelopment that
is already accounted for in the General Plan and is assessed in the General Plan EIR. Implementation
of the CAP Update could result in impacts to biological resources during infrastructure development
construction. However, all infrastructure development or redevelopment resulting from
implementation of the CAP Update would be required to comply with applicable General Plan
policies and State and federal regulatory requirements regarding avoidance of special wildlife
species and habitat. Furthermore, as a guidance document, the GHG Emissions Thresholds would
not result in cumulative impacts. Therefore, implementation of the CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to biological
resources.
Environmental Checklist
Final Initial Study–Negative Declaration 37
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City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
38
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource pursuant
to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ □ ■ □
c. Disturb any human remains, including those
interred outside of formal cemeteries? □ □ ■ □
5a. Would the project cause a substantial adverse change in the significance of a historical resource
pursuant to §15064.5?
San Luis Obispo Municipal Code Chapter 14.01 Historic Preservation Ordinance requires designation
of historic resources and sites.33 According to the City’s General Plan Conservation and Open Space
Element there are five historic districts that include a multitude of master list historical properties.34
As many as a dozen potentially significant historic and prehistoric sites have been identified in the
downtown and old town historic districts alone. The City also provides a list of historic properties
under the Mills Act within the City limits.35
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not result in construction or operational impacts related to historical resources.
The CAP Update would not involve land use or zoning changes. Rather the CAP Update would
promote infrastructure development and redevelopment that is already accounted for in the
General Plan and is assessed in the General Plan EIR.
As a policy document, the CAP Update would not directly result in impacts related to historical
resources. Implementation of the CAP Update foundational actions and measures may promote
infrastructure development and redevelopment that could have impacts on these resources during
construction. Future related projects would be required to undergo CEQA review, including
assessment and mitigation incorporation once project details and locations are known. The CAP
Update would not conflict with or obstruct the City’s ability to comply with applicable historical
resources preservation policies. Therefore, the CAP Update and GHG Emissions Thresholds would
result in a less-than-significant impact related to historical resources.
33 San Luis Obispo, City of. Municipal Code. Available at: https://sanluisobispo.municipal.codes/Code/14.01.060
34 San Luis Obispo, City of. 2006. General Plan Open Space and Conservation Element. A vailable at:
https://www.slocity.org/home/showdocument?id=6651
35 San Luis Obispo, City of. 2010. City of San Luis Obispo List of Mills Act Properties. Available at:
https://www.slocity.org/home/showdocument?id=4160
Environmental Checklist
Final Initial Study–Negative Declaration 39
5b. Would the project cause a substantial adverse change in the significance of an archaeological
resource pursuant to §15064.5?
As many as a dozen potentially significant historic and prehistoric sites have been identified in the
downtown and old town historic districts alone. The GHG Emissions Thresholds provide guidance
during CEQA review and do not propose development or changes to land use and zoning. Thus,
implementation of the GHG Emissions Thresholds would not have construction or operational
impacts related to archaeological resources. The CAP Update would not involve land use or zoning
changes. Rather the CAP Update would promote infrastructure development and redevelopment
that is already accounted for in the General Plan and is assessed in the General Plan EIR.
As a policy document, the CAP Update would not directly result in impacts related to archaeological
resources. Implementation of the CAP Update foundational actions and measures may promote
infrastructure development and redevelopment that could result in an impact on these resources
during construction. Future related projects would be required to undergo CEQA review, including
assessment and mitigation incorporation once project details and locations are known. The CAP
Update would not conflict with or obstruction of the applicable policies for preserving archeological
resources and would not affect the City’s ability to attain goals and policies that protect
archeological resources. Therefore, the CAP Update and GHG Emissions Thresholds would result in a
less-than-significant impact related to archaeological resources.
5c. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
According to the City’s General Plan Conservation and Open Space Element there are burial points
and burial sensitivity areas in the City.36 The GHG Emissions Thresholds provide guidance during
CEQA review and do not propose development or changes to land use and zoning. Thus,
implementation of the GHG Emissions Thresholds would not have construction or operational
impacts related to human remains. The CAP Update would not involve land use or zoning changes.
Rather the CAP Update would promote infrastructure development and redevelopment that is
already accounted for in the General Plan and is assessed in the General Plan EIR.
As a policy document, the CAP Update would not directly result in impacts related to human
remains. Implementation of the CAP Update foundational actions and measures may promote
infrastructure development and redevelopment that could have an impact on these resources
during construction. However, future related projects would be required to comply with State
coroner requirements related to burial findings. Therefore, the CAP Update and GHG Emissions
Thresholds would result in a less-than-significant impact related to human remains.
36 San Luis Obispo, City of. 2006. General Plan Open Space and Conservation Element. Available at:
https://www.slocity.org/home/showdocument?id=6651
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
40
Cumulative Impacts
Planned buildout of the City of San Luis Obispo under the General Plan would cumulatively increase
the potential for adverse effects on historic and archaeological resources in the City. The CAP
Update could incrementally contribute to this cumulative effect. Impacts to historic and
archaeological resources are generally site-specific. Accordingly, as required under applicable laws
and regulations, potential impacts associated with cumulative developments woul d be addressed
on a case-by-case basis. Implementation of the CAP Update foundational actions may promote
infrastructure development and redevelopment that could have an impact on these resources
during construction. However, no known cultural resources would be removed, modified, or
otherwise affected by the implementation of the CAP Update. Furthermore, as a guidance
document, the GHG Emissions Thresholds would not result in cumulative impacts. Therefore,
implementation of the CAP Update and GHG Emissions Thresholds would result in an overall
less-than-significant cumulative impact related to cultural resources.
Environmental Checklist
Final Initial Study–Negative Declaration 41
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City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
42
6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ ■ □
6a. Would the project result in a potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, during pro ject construction or
operation?
California is one of the lowest per-capita energy users in the United States, ranked 48th in the
nation, due to its energy efficiency programs and mild climate.37 California consumed 292,039
gigawatt-hours of electricity and 2,110,829 million cubic feet of natural gas in 2017.38,39
The single largest end-use sector for energy consumption in California is transportation (39.8
percent), followed by industry (23.7 percent), commercial (18.9 percent), and residential (17.7
percent).40
Adopted in 2018, SB 100 accelerates the State’s Renewable Portfolio Standards Program, codified in
the Public Utilities Act, by requiring electricity providers to increase procurement from eligible
renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100
percent by 2045.
The City of San Luis Obispo has demonstrated its commitment to energy efficiency and renewable
energy through many efforts. The City has adopted the California Green Building Standards Code,
per San Luis Obispo Municipal Code Chapter 15.02, which requires efficiency measures to reduce
energy use, and provide energy reduction benefits. The City has also completed communitywide
GHG emissions inventories for years 2005 and 2016, which are summarized in Table 1. Table 1 also
provides estimated 1990 emissions levels for informational purposes. Communitywide GHG
emissions declined by approximately 12 percent between 2005 and 2016. The most notable changes
37 United States Energy Information Administration (EIA). 2018a. “California - Profile Overview.” Last modified: November 15, 2018.
Available at: https://www.eia.gov/state/?sid=CA
38 California Energy Commission (CEC). 2019. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in
California: A Review of the Literature.
39 United States Energy Information Administration (EIA). 2018. Natural Gas: Natural Gas Consumption by End Use. December 31, 2018.
Available at: https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm
40 United States Energy Information Administration (EIA). 2018. “California - Profile Overview.” Last modified: November 15, 2018.
Available at: https://www.eia.gov/state/?sid=CA
Environmental Checklist
Final Initial Study–Negative Declaration 43
occurred in the energy and solid waste sectors due to increasing decarbonization of the electricity
grid, investments in energy efficiency, and a decrease in the amount of solid waste generated.
The GHG Emissions Thresholds provide guidance during CEQA review and do not propose
development or changes to land use and zoning. Thus, implementation of the GHG Emissions
Thresholds would not result in construction or operational impacts related to wasteful consumption
of energy resources. The CAP Update is a policy document containing climate action measures and
foundational actions to reduce Citywide GHG emissions. The CAP Update would not involve land use
or zoning changes. Rather, the CAP Update would promote infrastructure development and
redevelopment that is already accounted for in the General Plan and assessed in the General Plan
EIR. Furthermore, the purpose and intended effect of the CAP is to reduce GHG emissions generated
in the City to help reduce the effects of climate change, including those emissions generated by
energy demand and supply. The CAP Update encourages energy efficiency and carbon neutral
electricity of existing building stock. Actions Leadership 1.1 through 1.3 aims to facilitate carbon
neutral energy for municipal buildings and programs. Actions Energy 1.1, 2.1, and 3.1 focus on
carbon neutral electricity throughout the City by launching Monterey Bay Community Power
(MBCP). Actions Buildings 1.1, 2.1, and 2.2 aim to facilitate all new residential and/or commercial
construction to be 100 percent electric within San Luis Obispo. As such, the CAP Update would not
result in the use of non-renewable resources in a wasteful or inefficient manner. Therefore, the CAP
Update and GHG Emissions Thresholds would result in a less-than-significant impact related to the
wasteful, inefficient, or unnecessary consumption of energy. Rather, the CAP Update would assist in
reducing use of non-renewable energy resources.
6b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy
efficiency?
The City of San Luis Obispo has adopted the California Green Building Standards Code per San Luis
Obispo Municipal Code Chapter 15.02. Therefore, construction and operation associated with
infrastructure projects stemming from the CAP Update would be designed to comply with the
energy source standards of the California Green Building Standard Code. Likewise, discretionary
development would be required to comply with the energy efficiency standards in the 2016
California Energy Code, Part 6 of the California Building Standards Code (Title 24). Thus, the CAP
Update would not conflict with adopted renewable energy or energy conservation plans. The GHG
Emissions Thresholds is a CEQA guidance document that does not propose development or changes
to land use and zoning. As such, the GHG Emissions Thresholds would not result in construction or
operational impacts related to consistency with a State or local renewable energy plan. Therefore,
the CAP Update and GHG Emissions Thresholds would result in a less-than-significant impact
related to consistency with State and local renewable energy and energy efficiency plans. Rather,
the CAP Update would be consistent with State and local plans for renewable energy and energy
efficiency.
Cumulative Impacts
The City of San Luis Obispo General Plan Update EIR did not provide a cumulative impact
assessment related to energy. The CAP Update would assist in reducing use of non-renewable
energy resources across the community in particular with remodels and new construction.
Additionally, construction of the General Plan assumed buildout could result in temporary energy
consumption impacts. Furthermore, as a guidance document, the GHG Emissions Thresholds would
not result in cumulative impacts. Thus, implementation of the CAP Update and GHG Emissions
Thresholds would result a less-than-significant cumulative impact related to energy.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
44
7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Expose people or structures to potentially
substantial adverse effects, including the
risk of loss, injury, or death involving:
1. Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault Zoning
Map issued by the State Geologist for
the area or based on other substantial
evidence of a known fault? □ □ □ ■
2. Strong seismic ground shaking? □ □ □ ■
3. Seismic-related ground failure,
including liquefaction? □ □ □ ■
4. Landslides? □ □ □ ■
b. Result in substantial soil erosion or the loss
of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction, or collapse? □ □ ■ □
d. Be located on expansive soil, as defined in
Table 1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life or property? □ □ ■ □
e. Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems where sewers
are not available for the disposal of
wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
Environmental Checklist
Final Initial Study–Negative Declaration 45
7a. Expose people or structures to potential substantial adverse effects, including the risk of loss,
injury, or death involving:
▪ Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other
substantial evidence of a known fault?
▪ Strong seismic ground shaking?
▪ Seismic-related ground failure, including liquefaction?
▪ Landslides?
San Luis Obispo is located in a seismically active region and is identified as Landslide Zone by
California Department of Conservation41. In 2006, the City adopted a Local Hazard Mitigation Plan
(LHMP) to assess hazards and reduce risks prior to a disaster event and fully cover the necessity to
address seismic and geological hazards42. And, all development projects are required to conform to
applicable provisions of the current California Building Code.
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to risk of loss, injury, or death involving rupture
of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure including
liquefaction, or landslides. The CAP Update is a policy document containing climate actions and
supporting measures to reduce GHG emissions, which is consistent with the City’s General Plan and
other regional regulations. The CAP Update does not propose habitable development that could
result in exposure of people or structures to potential substantial adverse effects, including the risk
of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground
shaking, seismic-related ground failure, including liquefaction, or landslides. Therefore, the CAP
Update and GHG Emissions Thresholds would result in no impact related to seismic- and landslide-
related hazards.
7b. Would the project result in substantial soil erosion or the loss of topsoil?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to substantial loss of topsoil. The CAP Update
would not involve land use or zoning changes. Rather, the CAP Update would promote
infrastructure development and redevelopment that is already accounted for in the General Plan
and is assessed in the General Plan EIR. As a policy document, the CAP Update would not di rectly
require ground disturbing activities. However, implementation of the following CAP Update
foundational actions and measures may promote infrastructure development and redevelopment.
The CAP Update includes Action Natural Solutions 1.1, which facilitates carbon farming, in the form
of compost application at Johnson Ranch Open Space and City Farm (also known as “Calle Joaquin
Agricultural Reserve”). As such, the CAP Update could result in minor retention of topsoil, because
compost application improves the quality of topsoil. The CAP Update Action Connected 6.1 would
require the installation of electric vehicle charging stations and supporting infrastructure.
Additionally, implementation of Actions Connected 2.1 through 2.3 may require the installation of
41 California Department of Conservation (CDOC). 2015. CGS Information Seismic Hazards Programs
https://maps.conservation.ca.gov/cgs/DataViewer/
42 San Luis Obispo, City of. 2006. Local Hazard Mitigation Plan (LHMP). Available at: https://www.slocity.org/home/showdocument?id=60
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
46
new bicycle or pedestrian facilities. Additionally, Measure Natural Solutions 2 facilitates the
preparation of an Urban Forest Master Plan and requires planting and maintaining 10,000 new trees
by the year 2035. As such, the CAP Update could result in construction-related soil erosion and
topsoil loss impacts associated with such installations and plantings. However, discretionary
development would be required to conduct geotechnical studies and adhere to related geology and
soils recommendations prior to final siting and construction. Therefore, the CAP Update and GHG
Emissions Thresholds would result in a less-than-significant impact related to soil erosion, loss of
topsoil, and the presence of unstable soils.
7c. Would the project be located on a geologic unit or soil that is unstable as a result of the project,
and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or
collapse?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to project location on an unstable geologic unit
or soil. Additionally, the CAP Update is a policy document containing programs that are consistent
with the General Plan. Some of the proposed measures in the CAP Update would support small-
scale construction projects, such as electric vehicle charging station construction. However,
discretionary development would be required to conduct geotechnical studies and adhere to
related recommendations prior to final siting and construction. Therefore, the CAP Update and GHG
Emissions Thresholds would result in a less-than-significant impact related to risks associated with
location on unstable geologic unit or soil.
7d. Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building
Code, creating substantial risks to life or property?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to project location on expansive soil.
Additionally, The CAP Update is a policy document containing measures that are consistent with the
General Plan. Some of the proposed measures of CAP Update would support small-scale
construction projects, such as electric vehicle charging station construction. However, discretionary
development would be required to conduct geotechnical studies and adhere to related
recommendations prior to final siting and construction which would reduce impacts. Therefore, the
CAP Update and GHG Emissions Thresholds would result in a less-than-significant impact related to
risks associated with location on expansive soils.
7e. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
The CAP Update and GHG Emissions Thresholds would not involve the development of habitable
structures and, thus, no use of septic tanks or alternative wastewater disposal systems. Therefore,
no impact would occur related to soil capability support of alternative wastewater disposal systems.
Environmental Checklist
Final Initial Study–Negative Declaration 47
7f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique
geologic feature?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to paleontological resources. The CAP Update
would not involve land use or zoning changes. Rather the CAP Update would promote infrastructure
development and redevelopment that is already accounted for in the General Plan and is assessed
in the General Plan EIR. As a policy document, the CAP Update would not directly result in impacts
related to paleontological resources or unique geologic features. However, implementation of the
following CAP Update foundational actions and measures may promote infrastructure development
and redevelopment.
The CAP Update includes Action Buildings 2.1, which could include installation of on-site solar arrays
within the city. Action Connected 6.1 would require the installation of electric vehicle charging
stations and supporting infrastructure. Additionally, implementation of Actions Connected 2.1
through 2.3 may require the installation of new bicycle or pedestrian facilities. Additionally,
Measure Natural Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires
planting and maintaining 10,000 new trees by the year 2035. Planting new street trees and private
trees may expose paleontological resources during ground disturbing activities. However,
discretionary development would be required to conduct geotechnical and design guideline studies
and adhere to related recommendations prior to final siting and construction. Therefore, the CAP
Update and GHG Emissions Thresholds would result in a less-than-significant impact related to
paleontological resources or unique geologic features.
Cumulative Impacts
Planned, proposed, and approved projects assumed under General Plan buildout could expose
additional people and property to seismic and geologic hazards that are present in the region. The
magnitude of geologic hazards for individual projects would depend upon the location, type, and
size of development and the specific hazards associated with individual sites. Specific geologic
hazards associated with individual project sites would be limited to those sites without affecting
other areas. Similarly, potential impacts to paleontological resources associated with each individual
site would be limited to that site without affecting other areas, and impacts related to these
resources would be minimized on a case-by-case basis. Compliance with existing regulations,
including California Building Code requirements, City-issued permit requirements, and construction
general permit requirements, would minimize potential cumulative seismic and geologic impacts.
Seismic and geologic hazards would be addressed on a case-by-case basis and would not result in
cumulative impacts. Furthermore, as a guidance document, the GHG Emissions Thresholds would
not result in cumulative impacts. Therefore, implementation of the CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to geology
and soils.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
48
8 Greenhouse Gas Emissions
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment? □ □ ■ □
b. Conflict with any applicable plan, policy, or
regulation adopted to reduce the emissions
of greenhouse gases? □ □ ■ □
8a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
The greenhouse effect is a natural occurrence that helps regulate the temperature of the Earth. The
majority of radiation from the Sun hits Earth’s surface and warms it. The surface in turn radiates
heat back towards the atmosphere, known as infrared radiation. Gases and clouds in the
atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all
directions. This process is essential to support life on Earth, because it warms the planet by
approximately 60°F. Emissions from human activities since the beginning of the industrial revolution
(approximately 270 years ago) have been adding to the natural greenhouse effect by increasing the
gases in the atmosphere that trap heat and contribute to an average increase in Earth’s
temperature. Global warming is the observed increase in the average temperature of the Earth’s
surface, and climate change is the resultant change in wind patterns, precipitation, and storms over
an extended period.
GHGs produced by human activities include CO2, methane (CH4), nitrous oxide (N2O),
hydroflourocarcons (HFCs), perfluorinated compound (PFC), and sulfur hexafluoride (SF6) (see
Appendix B for more details related to these GHG gases).43 Combustion of fossil fuels (gasoline,
natural gas, and coal), deforestation, and decomposition of waste release carbon into the
atmosphere that had been locked underground and stored in oil, gas, and other hydrocarbon
deposits or in the biomass of surface vegetation. Since 1750, estimated concentrations of CO2, CH4,
and N2O in the atmosphere have increased by over 36 percent, 148 percent, and 18 percent
respectively, primarily due to human activity. Emissions of GHGs affect the atmosphere directly by
changing its chemical composition. Changes to the land surface also indirectly affect the
atmosphere by changing the way in which Earth absorbs gases from the atmosphere. Potential
43 The proposed CAP only considers emissions of CO2, CH4, and N2O because these are the GHGs most relevant to local government
policymaking. These gases comprise a large majority of GHG emissions at the community level. The remaining gases (HFCs, PFC, and
SF6) are emitted primarily in private sector manufacturing and electricity transmission and are the subject of regulation at the state
level. Therefore, these gases were omitted from the CAP.
Environmental Checklist
Final Initial Study–Negative Declaration 49
impacts in California due to climate change include sea level rise, more extreme-heat days and high-
ozone days, larger and more frequent forest fires, and more drought years.44
Although GHG emissions do not typically cause direct health impacts at a local level, GHG emissions
can result in indirect health impacts by contributing to climate change, which can have public health
implications. The primary public health impacts of climate change include the following:45
▪ Increased incidences of hospitalization and deaths due to increased incidences of extreme
heat events;
▪ Increased incidences of health impacts related to ground-level ozone pollution due to
increased average temperatures that facilitate ozone formation;
▪ Increased incidences of respiratory illnesses from wildfire smoke due to increased
incidences of wildfires;
▪ Increased vector-borne diseases due to the growing extent of warm climates; and
▪ Increased stress and mental trauma due to extreme events and disasters, economic
disruptions, and residential displacement.
The City of San Luis Obispo has completed communitywide GHG emissions inventories for years
2005 and 2016, which are summarized in Table 1. Table 1 also provides estimated 1990 emissions
levels for informational purposes. As shown therein, communitywide GHG emissions declined by
approximately 12 percent between 2005 and 2016. The most significant changes occurred in the
energy and solid waste sectors due to increasing decarbonization of the electricity grid, investments
in energy efficiency, and a decrease in the amount of solid waste generated.46
Figure 3 and Table 3 summarize the communitywide GHG emissions forecast under three scenarios:
1) business-as-usual, 2) implementation of State laws and programs, and 3) implementation of State
laws and programs and the CAP Update. As shown therein, under the business-as-usual scenario,
communitywide GHG emissions are forecasted to increase by approximately 21 percent between
1990 and 2035 based on anticipated economic and population growth. However, with
implementation of State laws and programs, communitywide GHG emissions would decline by
approximately 22 percent between 1990 and 2035. Furthermore, implementation of the CAP
Update alongside State laws and programs would reduce communitywide GHG emissions by 66
percent between 1990 and 2035.
The City has an aspirational goal of achieving carbon neutrality by 2035 and has proposed the CAP
Update as a pathway to make progress toward this goal. As shown in Table 3, implementation of the
CAP Update would achieve an approximately 43 percent reduction in communitywide GHG
emissions below 1990 levels by 2030 and an approximately 66 percent reduction in communitywide
GHG emissions below 1990 levels by 2035. Therefore, the City goal of carbon neutrality and the
associated CAP Update establish a trajectory that provides GHG emissions reductions greater than
those required by SB 32 for 2030. Because SB 32 is considered an interim target toward meeting the
2045 State goal of carbon neutrality, implementation of the CAP Update would be considered
substantial progress toward meeting the State’s long-term 2045 goal. Avoiding interference with,
and making substantial progress toward, these long-term State targets is important, because these
44 California Energy Commission (CEC). 2009. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in
California: A Review of the Literature. March 2009.
45 State of California. 2018. California’s Fourth Climate Change Assessment Statewide Summary Report. August 27, 2018.
http://www.climateassessment.ca.gov/state/ (accessed February 2020).
46 San Luis Obispo, City of. 2019. Community Greenhouse Gas Emissions Inventory and Forecast .
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
50
targets have been set at levels that achieve California’s fair share of international emissions
reduction targets that will stabilize global climate change effects and help avoid the associated
adverse environmental consequences.
The proposed CAP Update creates a GHG emission reduction strategy (consistent with Section
15183.5 of the CEQA Guidelines)47 for the City of San Luis Obispo. The inventory performed for 2016
demonstrated that the activities within the City emitted 339,290 metric tons (MT) of carbon dioxide
equivalent units (CO2e). The State has codified a goal of reducing emissions to 1990 levels by 2020
(via AB 32); 40 percent below 1990 emissions levels by 2030 (via SB 32); and carbon neutrality by
2045 (via Executive Order [EO] B-55-18 and pending AB 2832).
The CAP Update includes a series of pillars, measures, and foundational actions intended to reduce
communitywide GHG emissions by approximately 66 percent below 1990 levels by 2035, which
provides substantial progress toward meeting the City carbon neutrality goal while exceeding the
State goal. The CAP Update acknowledges that additional actions beyond those identified in the
plan will be necessary to achieve carbon neutrality and, thus, provides a mechanism for updating
and adopting a new climate action plan every other financial plan cycle in order to incorporate new
measures and technologies that will further the City toward meeting its goal of carbon neutrality.48
As such, the CAP Update would result in the reduction of communitywide operational GHG
emissions, with only generating temporary GHG emissions during construction of infrastructure
development and redevelopment such as electric vehicle charging stations, bicycle paths, transit,
etc. The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning and, thus, would not result in construction or operational impacts
related to GHG emissions. The GHG Emissions Thresholds would establish GHG emissions targets
and analysis methodologies that are enforced during CEQA review with the intention of reducing
GHG emissions associated with construction and operation of future projects and plans in the City.
Additionally, the CAP Update would serve as a pathway to reduce GHG emissions and introduce
other beneficial environmental and sustainability effects. These benefits include reduction in
building energy consumption and vehicle miles traveled (and thus air pollution), water consumption,
and solid waste generation. Therefore, the CAP Update and GHG Emissions Thresholds would result
in a less-than-significant impact related to generation of GHG emissions.
8b. Would the project conflict with any applicable plan, policy, or regulation adopted for the purpose
of reducing the emissions of greenhouse gases?
The CAP Update and GHG Emissions Thresholds are policy-level documents that set strategies to
reduce GHG emissions within the City in an effort to also comply with State regulations. As discussed
under 8a above, the CAP Update includes GHG emissions reduction measures and supporting
foundational actions to reduce City GHG emissions from forecasted business-as-usual levels by
approximately 299,730 MT of CO2e by 2035. The purpose of the CAP Update is to meet San Luis
Obispo’s proportionate fair share of the Statewide GHG emissions reduction target set by AB 32 and
SB 32 and work toward the State’s longer-term target identified in Executive Order S-3-05 and
47 Per the CEQA Statutes and Guidelines Section 15183.5(b)(1), a qualified GHG reduction plan should: quantify greenhouse gas
emissions, both existing and projected over a specified time period, resulting from activities wi thin a defined geographic area; establish
a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by t he plan
would not be cumulatively considerable; identify and analyze the greenhouse gas e missions resulting from specific actions or
categories of actions anticipated within the geographic area; specify measures or a group of measures, including performance
standards, that substantial evidence demonstrates, if implemented on a project -by-project basis, would collectively achieve the
specified emissions level; establish a mechanism to monitor the plan’s progress toward achieving the level and to require ame ndment
if the plan is not achieving specified levels; and be adopted in a public process f ollowing environmental review.
48 San Luis Obispo, City of. 2019. Carbon Neutrality Vision and Three-Year Strategic Plan Technical Report. November 2019.
Environmental Checklist
Final Initial Study–Negative Declaration 51
Executive Order B-30-15. The CAP Update would not conflict with an applicable GHG reduction plans,
including the California Climate Change Scoping Plan and the California Climate Change Scoping Plan
Updates. The CAP Update identifies how the City would achieve consistency with the Statewide GHG
emissions limit.
The GHG Emissions Thresholds would establish GHG emissions targets and analysis methodologies
that are enforced during CEQA review with the intention of reducing GHG emissions associated with
construction and operation of future projects and plans in the City. Additionally, the CAP Update
would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and
sustainability effects. These benefits include reduction in building energy consumption and vehicle
miles traveled (and thus air pollution), water consumption, and solid waste generation. Therefore,
the CAP Update and GHG Emissions Thresholds would result in a less-than-significant impact related
to consistency with applicable GHG emissions reduction plans, policies, and regulations.
Cumulative Impacts
Analyses of GHG emissions and climate change are cumulative in nature, as they affect the
accumulation of GHG emissions in the atmosphere. Cumulative projects under San Luis Obispo
General Plan buildout that exceed the thresholds discussed above would have a significant impact
related to GHG emissions and climate change, both individually and cumulatively. The CAP Update
creates a GHG emissions reduction strategy (consistent with Section 15183.5 of the CEQA
Guidelines) for the City of San Luis Obispo. The CAP Update includes a series of pillars, measures,
and foundational actions that are intended to reduce communitywide GHG emissions by
approximately 66 percent below 1990 levels by 2035, which provides substantial progress toward
meeting the City carbon neutrality goal while exceeding State goals. The CAP Update acknowledges
that additional actions beyond those identified in the plan will be necessary to achieve carbon
neutrality and, therefore, provides a mechanism for updating and adopting a new climate action
plan every other financial plan cycle in order to incorporate new measures and technologies that
will further the City toward meeting its goal of carbon neutrality. As such, the CAP Update would
result in the reduction of GHG emissions rather than generating GHG emissions. Furthermore, as a
guidance document, the GHG Emissions Thresholds would not result in cumulative impacts. Rather,
the GHG Emissions Thresholds would establish GHG emissions targets and analysis methodologies
that are enforced during CEQA review with the intention of reducing GHG emissions associated with
construction and operation of cumulative buildout. Therefore, implementation of the CAP Update
and GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact
related to GHG emissions.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
52
9 Hazards and Hazardous Materials
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an
existing or proposed school? □ □ ■ □
d. Be located on a site that is included on a list
of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment? □ □ ■ □
e. For a project located in an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project result in a safety hazard or
excessive noise for people residing or
working in the project area? □ □ □ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan? □ □ □ ■
g. Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury,
or death involving wildland fires? □ □ □ ■
Environmental Checklist
Final Initial Study–Negative Declaration 53
9a, 9b. Would the project create a significant hazard to the public or the environment through :
▪ The routine transport, use, or disposal of hazardous materials?
▪ Reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to creating a significant hazard. The CAP
Update is a policy document containing actions and supporting measures to reduce GHG emissions.
The proposed CAP Update does not involve identified site-specific development, nor would it
facilitate new development. Implementation of the CAP Update measures and foundational actions
would not involve the routine transport, use, or disposal of hazardous materials and would not
create reasonably foreseeable upset and/or accidental conditions involving the release of hazardous
materials into the environment.
Implementation of some of the CAP Update measures and foundational actions, such as the
installation of bicycle facilities, energy retrofits, and electric vehicle charging stations, may involve
the use and transport of fuels, lubricating fluids, and solvents, among other activities. These types of
materials are not considered acutely hazardous, and all storage, handling, and disposal of these
materials are regulated by the California Department of Toxic Substances Control (CDTSC), United
States Environmental Protection Agency (USEPA), Occupational Safety & Health Administration
(OSHA), and San Luis Obispo County Environmental Health Division. Additionally, future
discretionary development would be subject to review by the City for compliance with the General
Plan and Municipal Code and would also be required to comply with applicable local, State, and
Federal regulations. Therefore, the CAP Update and GHG Emissions Thresholds would result in a
less-than-significant impact related to creating a significant hazard.
9c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an existing or proposed school?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to handling hazardous materials. The CAP
Update is a policy document containing pillars, supporting measures, and foundational actions to
reduce GHG emissions. The proposed CAP Update does not include site-specific proposals and
development, nor would it emit or handle hazardous materials. Implementing some GHG measures
may require future development or improvements, such as bike paths, solar panels, or building
improvements for efficiency. However, discretionary development would be subject to review by
the City for compliance with the General Plan and Municipal Code and would be required to comply
with all applicable local, State, and Federal regulations. Therefore, the CAP Update and GHG
Thresholds would result in a less-than-significant impact related to handling of hazardous materials.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
54
9d. Would the project be located on a site included on a list of hazardous material sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a significant
hazard to the public or the environment?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to project site location on a site listed on a
hazardous material site. The CAP Update is a policy document containing actions and supporting
measures to reduce GHG emissions. The proposed CAP Update does not include site-specific
proposals and development, but CAP measures and foundation actions could result in projects that
could be located on listed hazardous materials site. However, discretionary development would be
subject to review by the City for compliance with the General Plan and Municipal Code and would
be required to comply with applicable local, State, and Federal regulations. Therefore, the CAP
Update and GHG Thresholds would result in a less-than-significant impact related to location on a
listed hazardous materials site.
9e. For a project located in an airport land use plan or, where such a plan has not been adopted,
within two miles of a public airport or public use airport, would the project result in a safety
hazard or excessive noise for people residing or working in the project area?
The San Luis Obispo County Regional Airport is the only airport located in San Luis Obispo. The
airport and adjoining Airport Safety zone are located in the southern portion of the city limits, at
975 Airport Drive. The location as well as goals and policies associated with the airport area are
depicted in the City’s General Plan Land Use Element. The CAP Update and GHG Emissions
Thresholds are policy documents and implementation of which would not increase airport activity
or otherwise increase potential exposure to aircraft-related hazards. Additionally, discretionary
development projects associated with the CAP Update would undergo project-level CEQA review.
Therefore, the CAP Update and GHG Emissions Thresholds would result in no impact related to risks
associated with location proximate to a public airport.
9f. Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
The CAP Update and GHG Emissions Thresholds are policy documents intended to reduce GHG
emissions. The proposed CAP Update and GHG Emissions Thresholds do not involve site-specific
development, nor would it facilitate new development that would interfere with adopted
emergency plans. Therefore, the CAP Update and GHG Emissions Thresholds would result in
no impact related to impairment or interference with implementation of an emergency response or
evacuation plan.
Environmental Checklist
Final Initial Study–Negative Declaration 55
9g. Would the project expose people or structures, either directly or indirectly, to a significant risk of
loss, injury, or death involving wildland fires?
According to California Department of Forestry and Fire Protection (CalFIRE), San Luis Obispo is not
located in designated California Fire Hazard Severity Zones,49 or in State Responsibility Areas. No
impact associated with wildland fires would occur. According to the City’s General Plan Safety
Element, the urban reserve consists of low to moderate fire hazard rates.50 High and extreme fire
hazard rates closely surround the San Luis Obispo urban reserve. However, according to CalFIRE,
there are five areas categorized as very high fire hazard severity zones within the local responsibility
area (LRA).51 However, these areas are located on the outer fringes of the city boundaries and the
CAP Update and GHG Emissions Thresholds do not propose specific development or other physical
changes to the environment through would be put at risk in the case of a wildland fire. Therefore,
the Update and GHG Emissions Thresholds would result in no impact related to risks associated with
exposure to wildland fires.
Cumulative Impacts
As described in the General Plan Update EIR, adherence to applicable General Plan policies and
applicable State and Federal regulatory requirements would reduce cumulative hazards and
hazardous materials impacts resulting from buildout of the City under the General Plan to a less-
than-significant level. Furthermore, as a guidance document, the GHG Emissions Thresholds would
not result in cumulative impacts. Thus, implementation of the CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to hazards and
hazardous materials.
49 California Department of Forestry and Fire Protection (CalFIRE). Local Responsibility Area. Available at:
https://osfm.fire.ca.gov/media/5980/san_luis_obispo.pdf
50 San Luis Obispo, City of. City of San Luis Obispo Safety Element Wildland Fire Hazard. Available at:
https://www.slocity.org/home/showdocument?id=2274
51 CalFIRE. Very High Fire Hazard Severity Zones in LRA As Recommended by
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
56
10 Hydrology and Water Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Violate any water quality standards or
waste discharge requirements or otherwise
substantially degrade surface or
groundwater quality? □ □ □ ■
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin? □ □ □ ■
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would: □ □ ■ □
(i) Result in substantial erosion or siltation
on- or off-site; □ □ ■ □
(ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site; □ □ □ ■
(iii) Create or contribute runoff water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted runoff; or □ □ □ ■
(iv) Impede or redirect flood flows? □ □ ■ □
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation? □ □ ■ □
e. Conflict with or obstruct implementation of
a water quality control plan or sustainable
groundwater management plan? □ □ □ ■
Environmental Checklist
Final Initial Study–Negative Declaration 57
10a.Would the project violate any water quality standards or waste discharge requirements or
otherwise substantially degrade surface or groundwater quality ?
The GHG Emissions Thresholds is a guidance document as does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to water quality standards. The CAP Update is a
policy document containing measures and foundational actions intended to reduce GHG emissions
in the City. Discretionary development would be required to undergo CEQA review, including
assessment and mitigation incorporation, including the implementation of stormwater pollution
prevention plans (SWPP) and compliance with applicable local, State, and Federal regulations once
project details and locations are known. As such, the CAP Update’s related infrastructure changes
and discretionary development would not utilize or alter water supply or result in new or different
wastewater discharge. Additionally, discretionary development would be small in scale and not
result in substantial, adverse impacts related to surface or groundwater quality. Therefore, the CAP
Update and GHG Emissions Thresholds would result in no impact related to surface or groundwater
water quality in San Luis Obispo.
10b.Would the project substantially decrease groundwater supplies or interfere substantially with
groundwater recharge such that the project may impede sustainable groundwater management
of the basin?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to groundwater supplies. The CAP Update is a
policy document containing programs that are consistent with the City’s General Plan. In addition,
implementation of the CAP Update actions related to infrastructure development and
redevelopment would not substantially degrade groundwater quality or groundwater recharge. As a
result, no adverse impacts related to groundwater water quality or resources would occur.
The CAP Update includes Natural Solutions 2, which facilitates the preparation of an Urban Forest
Master Plan and requires planting and maintaining 10,000 new trees by the year 2035.
Encouragement of tree planting and thus provision of pervious areas in the City would increase
groundwater recharge. As such, implementing the CAP Update would have a beneficial effect
related to local groundwater recharge as well as support groundwater management in San Luis
Obispo. Therefore, the CAP Update and GHG Emissions Thresholds would result in no impact related
to impedance of sustainable groundwater management in the San Luis Obispo Valley Groundwater
Basin.
10c. Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would:
▪ Result in substantial erosion or siltation on - or off-site?
▪ Substantially increase the rate or amount of surface runoff in a manner which would result
in flooding on- or off-site?
▪ Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted runoff?
▪ Impede or redirect flood flows?
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
58
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to alterations in polluted runoff.
Implementation of the following CAP Update foundational actions and measures may promote
infrastructure development and redevelopment. Action Buildings 2.1 could include installation of
on-site solar arrays within the city. Action Connected 6.1 would require the installation of electric
vehicle charging stations and supporting infrastructure. Additionally, implementation of Actions
Connected 2.1 through 2.3 may require the installation of new bicycle or pedestrian facilities.
Construction of infrastructure development and redevelopment could result in erosion and
potential redirect of flood flows or drainage patterns; however, implementation of proposed actions
would not include large-scale construction within San Luis Obispo. Additionally, discretionary
development would be required to undergo CEQA review, including assessment and mitigation
incorporation, including the implementation of a SWPP and compliance with applicable local, State,
and Federal regulations once project details and locations are known. And given the associated
small footprints, the CAP Update-related infrastructure changes would not result in substantial
additional erosion or runoff. Therefore, the CAP Update and GHG Emissions Thresholds would result
in a less-than-significant impact related to polluted runoff.
10d. Would the project result in flood hazard, tsunami, or seiche zones, risk release of
pollutants due to project inundation ?
The City is not located within designated seiche or tsunami zones. Portions of the City are within the
100- and 500-year flood zones defined by Federal Emergency Management Agency (FEMA).52 In San
Luis Obispo, new construction, including infrastructure projects associated with implementation of
the CAP Update, in flood-prone areas must comply with Chapter 17.78 (Flood Damage Prevention)
of Title 7 of the San Luis Obispo Municipal Code. The City of San Luis Obispo identified flood
preparation areas, but no major flood improvement projects are included in recent City planning
documents.53 In addition, the San Luis Obispo County Flood Control and Water Conservation District
established a guide to implementing flood control projects, which includes strategies for San Luis
Obispo Creek FC Zone 9 that would decrease the flood risk in San Luis Obispo.54 Therefore, the CAP
Update and GHG Emissions Thresholds would result in a less-than-significant impact related to
flooding and inundation resulting in release of pollutants.
52 Federal Emergency Management Agency (FEMA). FEMA Flood Map Service Center. Available at:
https://msc.fema.gov/portal/search?AddressQuery=turlock%2C%20ca#searchresultsanchor
53 San Luis Obispo, City of. San Luis Obispo City Flood Prep Map. Available at:
https://www.arcgis.com/apps/webappviewer/index.html?id=97ed3e37de014973a2d36f71ae468975
54 San Luis Obispo, County of. San Luis Obispo County Flood Control and Water Conservation District. Guide to Implementing Flood
Control Projects. 2009. Available at: https://www.slocounty.ca.gov/Departments/Public -Works/Forms-Documents/Water-
Resources/Drainage-Studies/Guide-to-SLO-Flood-Managemenit-Report.aspx
Environmental Checklist
Final Initial Study–Negative Declaration 59
10e. Would the project conflict with or obstruct implementation of a water quality control plan or
sustainable groundwater management plan?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to obstruction of a water quality control plan.
The CAP Update foundational actions would not include direct extraction of groundwater and
encourages water savings through conservation. The CAP Update would not interfere with or
obstruct implementation of water quality standards or waste discharge requirements or otherwise
substantially degrade surface or ground water quality. Therefore, the CAP Update and GHG
Emissions Thresholds would result in no impact related to consistency with a water quality control
plan or sustainable groundwater management plan.
Cumulative Impacts
As described in the General Plan Update EIR, adherence to applicable General Plan policies and
applicable State and Federal regulatory requirements would reduce cumulative hydrology and water
quality impacts resulting from buildout of the City under the General Plan to a less-than-significant
level. Implementation of the CAP Update would not contribute to an increase in development but
could result in infrastructure development or redevelopment projects, including renewable energy
facilities and alternative transportation thoroughfares. As such, implementation of the CAP Update
and other cumulative projects could have incremental impacts related to hydrology and water
quality, with potential minor alterations to existing drainage patterns in the City. However,
cumulative projects would comply with applicable local, State, and Federal regulations related to
hydrology and water quality. Furthermore, as a guidance document, the GHG Emissions Thresholds
would not result in cumulative impacts. Therefore, implementation of the CAP Update would result
in an overall less-than-significant cumulative impact related to hydrology and water quality.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
60
11 Land Use and Planning
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Physically divide an established
community? □ □ □ ■
b. Cause a significant environmental impact
due to a conflict with any land use plan,
policy, or regulation adopted for the
purpose of avoiding or mitigating an
environmental effect? □ □ □ ■
11a.Would the project physically divide an established community?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to division of an established community. The
CAP Update is a policy document containing programs that are consistent with San Luis Obispo’s
General Plan and does not include foundational actions or specific development projects that would
divide an established community.
The CAP Update includes actions (Connected 2.1 through 2.3, Connected 4.1 through 4.4) that
would support pedestrian and bicycle circulation and improved transportation alternati ves, which
would improve connectivity throughout the City. Action Connected 2.1 and 2.4 aims to prioritize an
Active Transportation Plan and implementation and develop quick build strategies to streamline
implementation of priority bicycle and pedestrian infrastructure projects, which would increase the
walkability of the City and decrease the vehicle miles traveled. Actions Connected 2.2 facilitates
launching a micro-mobility program in the form of electric bikes, which would increase active
transportation and decrease the vehicle miles traveled. Actions Connected 5.1 through 5.2
encourages flexible zoning in Downtown as well as updates to the Housing Element of the General
Plan to complete the housing Major City Goal. Actions Connected 4.1 through 4.4 proposes
improvements to the transit system including but not limited to developing a transit electrification
strategic plan and implementation, accelerated implementation of the existing Short-Range Transit
Plan, in order to increase ridership and increase sustainable practices within the transit system.
Therefore, the CAP Update and GHG Emissions Thresholds would result in no impact related to
division of an established community.
Environmental Checklist
Final Initial Study–Negative Declaration 61
11b. Would the project cause a significant environmental impact due to a conflict with any land use
plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in impacts related to conflict with a land use plan. The CAP Update is a policy document
containing programs that are consistent with the City’s General Plan. Nonetheless, implementing
the CAP Update would require some modification of existing policies, including developing and
implementing new programs, and projects, or modifying existing ones. For example, Action
Leadership 1.1 proposes to present a municipal carbon neutrality plan. Action Leadership 3.1 would
include carbon neutrality considerations and a focus on developing the green local economy in the
updated Economic Development Strategic Plan. Action Buildings 1.1 would adopt and implement
local amendments to the 2019 California Energy Code incentivizing all electric development (Clean
Energy Choice Program) and review opportunities for improvement in the 2022 code cycle. Action
Buildings 2.2 proposes adopting a building energy score program or benchmark ordinance and begin
implementing a retrofit program. In order to implement these measures, the City Municipal Code,
General Plan, and other applicable documents may need to be amended to reflect new or modified
requirements.
The CAP Update is designed to reduce adverse environmental impacts associated with climate
change. Where modifications of existing policies are needed, such as updates to policies related to
transit, active transportation, and parking garages, the CAP Update foundational actions would
result in greater avoidance or reduction of environmental effects. Therefore, the CAP Update and
GHG Emissions Thresholds would result in no impact related to consistency with current land use
plans or policies.
Cumulative Impacts
The CAP Update and GHG Emissions Thresholds are policy documents containing programs that are
consistent with the City’s General Plan. Nonetheless, implementing the CAP Update would require
some modification of existing policies, including developing and implementing new programs, and
projects, or modifying existing ones. The proposed policy changes are consistent with the intent of
the goals and policies established within the City General Plan and Zoning Regulations and would
not cumulatively contribute to the loss of open space or agricultural land beyond that already
anticipated in the City General Plan Land Use and Circulation Elements Update and EIR. Cumulative
projects would be required to adhere to City development regulations and General Plan policies to
retain land use character and minimize environmental impacts. And discretionary development
would be reviewed for consistency with the General Plan and other applicable regulatory land use
actions prior to approval. Furthermore, as a guidance document, the GHG Emissions Thresholds
would not result in cumulative impacts. Therefore, implementation of the CAP Update and GHG
Emissions Thresholds would result in an overall less-than-significant cumulative impact related to
land use.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
62
12 Mineral Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Result in the loss of availability of a known
mineral resource that would be of value to
the region and the residents of the state? □ □ □ ■
b. Result in the loss of availability of a locally
important mineral resource recovery site
delineated on a local general plan, specific
plan, or other land use plan? □ □ □ ■
12a, 12b. Would the project result in the loss of availability of a:
▪ Known mineral resource that would be of value to the region and the residents of the
State?
▪ Locally important mineral resource recovery site delineated on a local general plan,
specific plan, or other land use plan?
The City of San Luis Obispo General Plan does not identify any mineral resources or mineral
resources recovery sites within the City of San Luis Obispo.55 The CAP Update and GHG Emissions
Thresholds would not facilitate infrastructure development projects within the City that could result
in the loss of availability of known mineral resources. Therefore, the CAP Update and GHG Emissions
Thresholds would result in no impact related to mineral resource.
Cumulative Impacts
The City of San Luis Obispo General Plan Update EIR did not provide a cumulative impact
assessment related to mineral resources, since the General Plan Update does not identify mineral
resources in the City of San Luis Obispo. As such, no cumulative impact related to mineral resources
is assumed as a result of General Plan buildout. Furthermore, as a guidance document, the GHG
Emissions Thresholds would not result in cumulative impacts. Thus, implementation of the CAP
Update and GHG Emissions Thresholds would result in no cumulative impact related to mineral
resources.
55 2006. General Plan Open Space and Conservation Element. Available at: https://www.slocity.org/home/showdocument?id=6651
Environmental Checklist
Final Initial Study–Negative Declaration 63
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City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
64
13 Noise
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project result in:
a. Generation of a substantial temporary or
permanent increase in ambient noise levels
in the vicinity of the project in excess of
standards established in the local general
plan or noise ordinance, or applicable
standards of other agencies? □ □ ■ □
b. Generation of excessive groundborne
vibration or groundborne noise levels? □ □ ■ □
c. For a project located within the vicinity of a
private airstrip or an airport land use plan
or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or working
in the project area to excessive noise
levels? □ □ □ ■
13a. Would the project result in exposure of persons to or generation of noise levels in excess of
standards established in the local general plan or noise ordinance, or applicable standards of
other agencies?
Noise is unwanted sound that disturbs human activity. Environmental noise levels typically fluctuate
over time, and different types of noise descriptors are used to account for this variability. Noise
level measurements include intensity, frequency, and duration, as well as time of occurrence. Noise
level (or volume) is generally measured in decibels (dB) using the A -weighted sound pressure level
(dBA). Because of the way the human ear works, a sound must be about 10 dBA greater than the
reference sound to be judged as twice as loud. In general, a 3 dBA change in community noise levels
is noticeable, while 1-2 dBA changes generally are not perceived. Quiet suburban areas typically
have noise levels in the range of 40-50 dBA, while arterial streets are in the 50-60+ dBA range.
Normal conversational levels are in the 60-65 dBA range, and ambient noise levels greater than 65
dBA can interrupt conversations.
Noise levels typically attenuate (or drop off) at a rate of 6 dBA per doubling of distance from point
sources (such as construction equipment). Noise from lightly traveled roads typically attenuates at a
rate of about 4.5 dBA per doubling of distance. Noise from heavily traveled roads typically
attenuates at about 3 dBA per doubling of distance; while noise from a point source typically
attenuates at about 6 dBA per doubling of distance. Noise levels may also be reduced by the
introduction of intervening structures. For example, a single row of buildings between the receptor
Environmental Checklist
Final Initial Study–Negative Declaration 65
and the noise source reduces the noise level by about 5 dBA, while a solid wall or berm that breaks
the line-of-sight reduces noise levels by 5 to 10 dBA.
The Noise Element of the San Luis Obispo General Plan aims to ensure appropriate noise levels
considered compatible for community noise environments. The City’s normally acceptable exterior
noise exposure standard is 60 dBA community noise equivalent level (CNEL) or less for residential,
schools and hotels and 70 dBA CNEL. A detailed noise exposure threshold is shown below in
Table 4.56
Table 4 Land Use Compatibility for Community Noise Exposure
Normally
Acceptable
Conditionally
Acceptable Unacceptable
Residences, Theatres, Auditoriums, Music Halls 60 dB or less 61-70 dB Over 70 dB
Motels and hotels 60 dB or less 61-75 dB Over 75 dB
Schools, Libraries, Museums, Hospitals, Nursing
Homes, Meeting Halls, Churches, Mortuaries
60 dB or less 61-75 dB Over 85 dB
Playgrounds 70 dB or less 70-75 dB Over 75 dB
Office Buildings 60 dB or less 60-75 dB Over 75 dB
Neighborhood Parks 65 dB or less 65-75 dB Over 75 dB
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to excessive noise levels. The CAP Update is a
policy document containing programs that are consistent with the General Plan. Some of the
proposed measures of CAP Update would support small scale construction projects, such as EV
charging station construction, which may result in a temporary increase in noise levels. However,
discretionary development would be subject to review by the City for compliance with the General
Plan and Municipal Code, and would be required to comply with applicable local, State, and Federal
regulations.
The City’s General Plan indicates that traffic is the major source of noise in San Luis Obispo57. The
CAP Update encompasses a suite of GHG-reduction opportunities that affect the transportation
sector. For example, the CAP Update includes actions (Connected 2.1 through 2.3, Connected 4.1
through 4.4) that would support pedestrian and bicycle circulation and improved transportation
alternatives, which would improve connectivity throughout the City. Action Connected 2.1 and 2.4
aims to prioritize an Active Transportation Plan and implementation and develop quick build
strategies to streamline implementation of priority bicycle and pedestrian infrastructure projects,
which would increase the walkability of the City and decrease the vehicle miles traveled. Actions
Connected 2.2 facilitates launching a micro-mobility program in the form of electric bikes, which
would increase active transportation and decrease the vehicle miles traveled. These measures
would reduce vehicle miles traveled and further reduce traffic-related noise in San Luis Obispo.
Therefore, the CAP Update and GHG Emissions Thresholds would not generate excessive noise
levels; thus, there would be a less-than-significant impact related to noise exposure.
56 San Luis Obispo, City of. 1996. General Plan Noise Element. Available at: https://www.slocity.org/home/showdocument?id=664 3
57 San Luis Obispo, City of. 1996. General Plan Noise Element. Available at: https://www.slocity.org/home/showdocument?id=6643
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
66
13b. Would the project result in exposure of persons to or generation of excessive groundborne
vibration or groundborne noise levels?
While people have varying sensitivities to vibrations at different frequencies, in general they are
most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction
activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building
components can also take the form of an audible low-frequency rumbling noise, referred to as
groundborne noise.58 Although groundborne vibration is sometimes noticeable in outdoor
environments, it is almost never annoying to people who are outdoors. The primary concern from
vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land
uses.
Vibration amplitudes are usually expressed in peak particle velocity (PPV) or Root Mean Square
(RMS) vibration velocity. The PPV and RMS velocity are normally described in inches per second
(in/sec). PPV is defined as the maximum instantaneous positive or negative peak of a vibration
signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that
are experienced by buildings.59
Vibration significance ranges from approximately 50 vibration decibels (VdB), which is the typical
background vibration-velocity level, to 100 VdB, the general threshold where minor damage can
occur in fragile buildings.60 The general human response to different levels of groundborne vibration
velocity levels is described in Table 5.
Table 5 Human Response to Different Levels of Groundborne Vibration
Vibration Velocity Level Human Reaction
65 VdB Approximate threshold of perception for many people
75 VdB Approximate dividing line between barely perceptible and distinctly perceptible. Many
people find that transportation-related vibration at this level is unacceptable.
85 VdB Vibration acceptable only if there are an infrequent number of events per day
VdB = vibration decibels
Source: Federal Transit Administration. Transit Noise and Vibration Impact Assessment Manual. 2018.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-
manual-fta-report-no-0123_0.pdf 61
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to groundborne vibration. The CAP Update is a
policy document containing programs that are consistent with the General Plan. Some of the
proposed measures of CAP Update would support small-scale construction projects, such as electric
58 California Department of Transportation (Caltrans). 2013. Transportation and Construction Vibration Guidance Manual (CT -HWANP-
RT-13-069.25.3). http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf
59 Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook. (FHWAHEP -06-015; DOT-VNTSC-FHWA-
06-02). http://www.fhwa.dot.gov/environment/construction_noise/handbook
60 Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-
manual-fta-report-no-0123_0.pdf
61 Federal Transit Administration. Transit Noise and Vibration Impact Assessment Manual. 2018.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-innovation/118131/transit-noise-and-vibration-impact-assessment-
manual-fta-report-no-0123_0.pdf
Environmental Checklist
Final Initial Study–Negative Declaration 67
vehicle charging station construction that may result in a temporary increase in groundborne
vibration. However, discretionary development would be subject to review by the City for
compliance with the General Plan and Municipal Code and would be required to comply with
applicable local, State, and Federal regulations. Thus, the CAP Update and GHG Emissions
Thresholds would result in a less-than-significant impact related to groundbourne vibration.
13c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where
such a plan has not been adopted, within two miles of a public airport or public use airport,
would the project expose people residing or working in the project area to excessive noise levels ?
The San Luis Obispo County Regional Airport is the only public airport or airstrip located in San Luis
Obispo. The airport and adjoining Airport Safety zone are located in the southern portion of the City
limits, at 975 Airport Drive. The GHG Emissions Thresholds is a guidance document and does not
propose development or changes to land use and zoning. Thus, implementation of the GHG
Emissions Thresholds would not result in noise exposure impacts related to airports, airstrips, or
helicopters. The CAP Update does not propose land use or zoning changes related to airports,
airstrips, or heliports, nor does it include development that would increase exposure to excessive
noise levels associated with operation of airports, airstrips, or heliports. Therefore, the CAP Update
and GHG Emissions Thresholds would result in no impact related to aviation-related noise exposure.
Cumulative Impacts
The CAP Update is a policy document containing programs that are consistent with the City of San
Luis Obispo General Plan. Some of the proposed measures of CAP Update would support small scale
construction projects, such as electric vehicle charging station construction, which may result in a
temporary increase in groundborne vibration or noise levels. However, discretionary development
would be subject to review by the City for compliance with the General Plan and Municipal Code,
and would be required to comply with applicable local, State, and Federal regulations. Additionally,
the CAP Update encompasses a suite of GHG-reduction opportunities that would decrease traffic
and traffic-related noise. As such, implementation of the CAP Update would not generate excessive
groundborne vibration or noise levels. Furthermore, as a guidance document, the GHG Emissions
Thresholds would not result in cumulative impacts. Therefore, the CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to noise.
City of San Luis Obispo
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68
14 Population and Housing
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Induce substantial unplanned population
growth in an area, either directly (for
example, by proposing new homes and
businesses) or indirectly (for example,
through extension of roads or other
infrastructure)? □ □ □ ■
b. Displace substantial numbers of existing
people or housing, necessitating the
construction of replacement housing
elsewhere? □ □ □ ■
14a, 14b. Would the project induce substantial unplanned population growth in an area, either
directly (for example, by proposing new homes and businesses) or indirectly (for example,
through extension of roads or other infrastructure)? Would the project displace substantial
numbers of existing people or housing, necessitating the construction of replacement
housing elsewhere?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to substantial unplanned population growth.
The CAP Update is a policy document containing programs that are consistent with the City’s
General Plan. Nonetheless, implementing the CAP Update would require some modification of
existing policies, including developing and implementing new programs, and projects, or modifying
existing ones. For example, Action Connected 5.1 proposes developing flexible zoning requirements
for Downtown. Additionally, Action Connected 5.2 proposes updating the Housing Element of the
General Plan and complete the Housing-Major City Goal. In order to implement these measures, the
City Municipal Code, General Plan, and other applicable documents may need to be amended to
reflect new or modified requirements.
The CAP Update is designed to reduce adverse environmental impacts associated with climate
change. Where modifications of existing policies are needed the CAP Update actions would not
result in increases in population or induce additional population growth and would not displace
people or housing. Therefore, the CAP Update and GHG Emissions Thresholds would result in
no impact related to population and housing.
Environmental Checklist
Final Initial Study–Negative Declaration 69
Cumulative Impacts
Buildout of development assumed under the San Luis Obispo General Plan would not displace
people or housing nor induce substantial unplanned population growth in the City. And the CAP
Update would not contribute to person or housing displacement in the City of San Luis Obispo nor
result in population growth beyond that already assumed and planned for in the General Plan.
Furthermore, as a guidance document, the GHG Emissions Thresholds would not result in
cumulative impacts. Therefore, the CAP Update and GHG Emissions Thresholds would result in
no cumulative impact related to population and housing.
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15 Public Services
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
a. Would the project result in substantial
adverse physical impacts associated with
the provision of new or physically altered
governmental facilities, or the need for
new or physically altered governmental
facilities, the construction of which could
cause significant environmental impacts, in
order to maintain acceptable service ratios,
response times or other performance
objectives for any of the public services:
1. Fire protection? □ □ □ ■
2. Police protection? □ □ □ ■
3. Schools? □ □ □ ■
4. Parks? □ □ □ ■
5. Other public facilities? □ □ □ ■
15a. Would the project result in substantial adverse physical impacts associated with the provision of
new or physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance
objectives for any of the public services:
▪ Fire protection?
▪ Police protection?
▪ Schools?
▪ Parks?
▪ Other public facilities?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to public services. The CAP Update is a policy
document containing programs that are consistent with the San Luis Obispo General Plan. New
development facilitated by the General Plan would increase public service needs in San Luis Obispo
by adding population and housing. However, implementation of the CAP Update and the proposed
foundational actions would not result in increases in population and induce additional population
growth. As such, the CAP Update would not require the construction of new or physically altered
governmental facilities to serve additional population, the construction of which could cause
Environmental Checklist
Final Initial Study–Negative Declaration 71
significant environmental impacts. Furthermore, future site-specific discretionary projects would be
subject to subsequent environmental review wherein site-specific public service impacts would be
addressed accordingly.
Nonetheless, implementing the CAP Update would require some modification of existing policies,
including developing and implementing new programs, and projects, or modifying existing ones. The
CAP Update is designed to reduce adverse environmental impacts associated with climate change.
Where modifications of existing policies are needed the CAP Update actions would not result in
increases in population or induce additional population growth and would not displace people or
housing. Therefore, the CAP Update and GHG Emissions Thresholds would result in no impact
related to public services in terms of need for the construction of new or altered governmental
facilities.
Cumulative Impacts
Implementation of cumulative projects, including the CAP Update, would not result in increases in
population or induce additional population growth beyond that assumed under the San Luis Obispo
General Plan. Per the General Plan EIR, the cumulative need for construction of new fire, police,
school, park, or other public facilities would be reduced to a less-than-significant level. The CAP
Update and GHG Emissions Thresholds would not result in substantial population growth or direct
land use change. Therefore, implementation of the CAP Update would not result in substantial
cumulative need to expand public services facilities. Furthermore, as a guidance document, the GHG
Emissions Thresholds would not result in cumulative impacts. Thus, CAP Update and GHG Emissions
Thresholds would result in an overall less-than-significant cumulative impact related to public
services.
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16 Recreation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Increase the use of existing neighborhood
and regional parks or other recreational
facilities such that substantial physical
deterioration of the facility would occur or
be accelerated? □ □ □ ■
b. Include recreational facilities or require the
construction or expansion of recreational
facilities which might have an adverse
physical effect on the environment? □ □ □ ■
16a, 16b. Would the project increase the use of existing neighborhood and regional parks or oth er
recreational facilities such that substantial physical deterioration of the facility would
occur or be accelerated? Would the project include recreational facilities or require the
construction or expansion of recreational facilities which might have an adverse physical
effect on the environment?
San Luis Obispo is a primarily urbanized community with neighborhood parks, community parks,
mini parks, recreational and open spaces incorporated throughout, and a greenbelt extending from
the urban fringes62. The City’s General Plan Parks and Recreation Element identifies goals, policies,
and programs to manage the local parks and recreational facilities that were available for the
current and future population of San Luis Obispo63. The GHG Emissions Thresholds is a guidance
document and does not propose development or changes to land use and zoning. Thus,
implementation of the GHG Emissions Thresholds would not result in construction or operational
impacts related to neighborhood or regional parks. The CAP Update is a policy document containing
programs that are consistent with San Luis Obispo’s General Plan. Additionally, the CAP Update
would not result in substantial population growth or direct land use change. As such,
implementation of the CAP Update would not result in a substantial physical deterioration of parks
or other recreational facilities or result in the need to expand recreational facilities. Therefore, the
CAP Update and GHG Emissions Thresholds would result in no impact related to the need for
construction of new or altered recreational facilities.
62 San Luis Obispo, City of. Parks and Recreation Facilities in San Luis Obispo. Available at:
https://www.slocity.org/home/showdocument?id=2270
63 San Luis Obispo, City of. General Plan Parks and Recreation Element. Available at:
https://www.slocity.org/home/showdocument?id=6647
Environmental Checklist
Final Initial Study–Negative Declaration 73
Cumulative Impacts
Implementation of cumulative projects, including the CAP Update, would not result in increases in
population or induce additional population growth beyond that assumed under the General Plan.
Per the General Plan EIR, the cumulative need for construction of new recreational facilities would
be reduced to a less than significant level. The CAP Update and GHG Emissions Thresholds would
not result in substantial population growth or direct land use change. Therefore, implementation of
the CAP Update would not result in substantial cumulative physical deterioration of parks or other
recreational facilities or result in the cumulative need to expand recreational facilities. Furthermore,
as a guidance document, the GHG Emissions Thresholds would not result in cumulative impacts.
Therefore, implementation of the CAP Update and GHG Emissions Thresholds would result in
no cumulative impact related to recreation.
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17 Transportation
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Conflict with a program, plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities? □ □ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3, subdivision
(b)? □ □ □ ■
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm equipment)? □ □ ■ □
d. Result in inadequate emergency access? □ □ ■ □
17a, 17b. Would the project conflict with a program, plan, ordinance or policy addressing the
circulation system, including transit, roadway, bicycle and pedestrian facilities ? Would the
project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
The City adopted the City of San Luis Obispo Bicycle Transportation Plan in 2013 and amended it in
2017. The updated Bicycle Transportation Plan contains goals and policies for development and
implementation of a bicycle and pedestrian network that provides a viable transportation
alternative to the automobile, improves safety for bicyclists and pedestrians, and provides residents
with access and good connections to parks, open space, trails and other recreational opportunities.
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to conflict with a program, plan, ordinance, or
policy addressing the transportation circulation system. The CAP Update is a policy document
containing measures and supporting foundational actions that are consistent with the City General
Plan with many that are aimed at facilitating the implementation of the local transportation
regulations. For example, the CAP Update includes foundational actions (Connected 2.1 through 2.3,
Connected 4.1 through 4.4) that would support pedestrian and bicycle circulation and improved
transportation alternatives, which would improve connectivity throughout the City. Action
Connected 2.1 and 2.4 aims to prioritize an Active Transportation Plan and implement quick -build
strategies to streamline implementation of priority bicycle and pedestrian infrastructure projects,
which would increase the walkability of the City and decrease the vehicle miles traveled (VMT).
Actions Connected 2.2 facilitates launching a micro-mobility program in the form of electric bikes,
which would increase active transportation and decrease VMT. Actions Connected 5.1 through 5.2
encourages flexible zoning in Downtown as well as updates to the Housing Element of the General
Environmental Checklist
Final Initial Study–Negative Declaration 75
Plan. Actions Connected 4.1 through 4.4 proposes improvements to the transit system including but
not limited to developing a transit electrification strategic plan and implementing the existing Short-
Range Transit Plan, in order to increase ridership and increase sustainable practices withi n the
transit system. These CAP Update foundational actions would be consistent with and promote the
General Plan or Bicycle Transportation Plan. Implementation of some of the measures and
foundational actions may require future infrastructure development or improvements, such as bike
paths, solar panels, or building energy efficiency retrofits. However, discretionary development
would be subject to review by the City for compliance with the General Plan and Municipal Code
and be required to comply with applicable local, State, and Federal regulations. Therefore, the CAP
Update and GHG Emissions Thresholds would result in no impact related to consistency with plans
addressing the transportation circulation system.
17c, 17d. Would the project substantially increase hazards due to a design feature (e.g., sharp curves
or dangerous intersections) or incompatible use (e.g., farm equipment) or result in
inadequate emergency access?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to risk associated with transportation design or
features. The CAP Update is a policy document containing programs that are consistent with the
City General Plan and would not facilitate development beyond that allowed under the General
Plan. As such, it would not directly create transportation hazards or result in inadequate emergency
access. However, the proposed CAP Update measures and supporting foundational action included
in the CAP Update promotes alternative modes of transportation and reduction in the amount of
vehicle miles traveled throughout City. For example, the CAP Update promotes the Bicycle
Transportation Plan implementation to enhance bicycle, pedestrian, and transit connectivity, which
would reduce potential transportation hazards and would provide adequate emergency access. The
CAP does not include measures that would substantially increase transportation hazards due to a
design feature or incompatible land uses. Furthermore, future site-specific discretionary projects
would be subject to subsequent CEQA review wherein site-specific impacts related to hazards or
emergency access would be addressed accordingly. Thus, the CAP Update and GHG Emissions
Thresholds would result in a less-than-significant impact related to transportation hazards and
emergency access.
Cumulative Impacts
The goals, policies, objectives, measures, and actions included in the San Luis Obispo General Plan
Update and CAP Update promote alternative modes of transportation and reduction of the amount
of vehicle miles traveled throughout the City. The CAP Update foundational actions would not
conflict with the objectives and policies of the General Plan Update or Bicycle Transportation Plan
but would rather be consistent with and promote those plans. The CAP Update is a policy document
containing programs that are consistent with the City’s General Plan and does not propose new
development beyond that anticipated under the General Plan and assessed in the General Plan EIR.
Furthermore, as a guidance document, the GHG Emissions Thresholds would not result in
cumulative impacts. Therefore, the CAP Update and GHG Emissions Thresholds would result in an
overall less-than-significant cumulative impact related to transportation.
City of San Luis Obispo
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76
18 Tribal Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of the size and scope of the landscape, sacred
place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the California
Register of Historical Resources, or in a
local register of historical resources as
defined in Public Resources Code section
5020.1(k), or □ □ ■ □
b. A resource determined by the lead agency,
in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in subdivision
(c) of Public Resources Code Section
2024.1. In applying the criteria set forth in
subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall
consider the significant of the resource to a
California Native American tribe? □ □ ■ □
18a, 18b. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in a Public Resources Code section 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the
landscape, sacred place, or object with cultural value to a California Native American tribe
and that is:
▪ Listed or eligible for listing in the California Register of Historical Resources, or in a local
register of historical resources as defined in Public Resources Code § 5020.1 (k)?
▪ A resource determined by the lead agency, in its discretion and supported by
substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of
Public Resources Code § 5024.1.
In applying the criteria set forth in subdivision (c) of Public Resources Code § 5024.1, the
lead agency shall consider the significance of the resource to a California Native American
Tribe.
On February 13, 2020, local Native American tribal groups were formally notified that the City
initiated environmental review of the Climate Action Plan (CAP) and CEQA Greenhouse Gas (GHG)
Emissions Threshold(s) of Significance and were invited to provide consultation. No formal
consultation was requested. On April 25, 2020, Fred Collins with the Northern Chumash Tribal
Environmental Checklist
Final Initial Study–Negative Declaration 77
Council requested to be kept informed regarding the Climate Action Plan, indicating support of the
Plan.
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to tribal cultural resources. The CAP Update
would not involve land use or zoning changes. Rather the CAP Update would promote infrastructure
development and redevelopment that is already accounted for in the General Plan and is assessed
in the General Plan EIR. As a policy document, the CAP Update would not directly require ground
disturbing activities. However, implementation of the following CAP Update foundational actions
and measures may promote infrastructure development and redevelopment.
The CAP Update includes Action Connected 6.1 would require the installation of electric vehicle
charging stations and supporting infrastructure. Additionally, implementation of Actions Connected
2.1 through 2.3 may require the installation of new bicycle or pedestrian facilities. Additionally,
Measure Natural Solutions 2 facilitates the preparation of an Urban Forest Master Plan and requires
planting and maintaining 10,000 new trees by the year 2035. Implementation of the CAP Update
measures and foundational actions would result in infrastructure development and redevelopment
that could impact unknown tribal cultural resources during construction, but such resources would
be protected upon discovery and, thus, impacts would be reduced to a minimal level . Furthermore,
the CAP Update would not conflict with or obstruction of the applicable policies for preserving tribal
cultural resources and would not affect the City’s ability to attain goals and policies that protect
tribal cultural resources. Therefore, the CAP Update and GHG Emissions Thresholds would result in a
less-than-significant impact related to tribal cultural resources.
Cumulative Impacts
Planned buildout within the City of San Luis Obispo under the General Plan would cumulatively
increase the potential for adverse effects to unknown tribal cultural resources in the City. Impacts to
tribal cultural resources are site-specific; accordingly, as required under applicable laws and
regulations, potential impacts associated with cumulative developments would be addressed on a
case-by-case basis as cumulative project details and locations become known. The CAP Update
would not conflict with or result in the obstruction of applicable policies for preserving tribal
cultural resources and, thus, would not affect the City’s ability to attain goals and policies that
protect tribal cultural resources. Therefore, the CAP Update and GHG Emissions Thresholds would
result in a less-than-significant cumulative impact related to tribal cultural resources.
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19 Utilities and Service Systems
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects? □ □ ■ □
b. Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years? □ □ □ ■
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments? □ □ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals? □ □ □ ■
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste? □ □ □ ■
19a. Would the project require or result in the relocation or construction of new or expanded water,
wastewater treatment or storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause significant
environmental effects?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
have direct construction or operational impacts related to utilities and service systems. The CAP
Update is a policy document aimed at reducing water and energy consumption and related GHG
emissions throughout the City of San Luis Obispo and does not include site-specific infrastructure
designs or project proposals. Implementing the CAP Update would not result in an increase in
Environmental Checklist
Final Initial Study–Negative Declaration 79
population and housing nor would it facilitate growth beyond that anticipated by the General Plan
Update and assessed by the General Plan Update EIR. As such, implementing the CAP Update would
not create new demand related to water, wastewater, stormwater drainage, electric power, natural
gas power, or telecommunications utilities. However, projects resulting from CAP Update
implementation could include redevelopment and/or restructuring of electricity and natural gas
power facilities and infrastructure.
Water Supply Facilities/Infrastructure
The City of San Luis Obispo provides potable and recycled water to the community and is
responsible for water supply, treatment, distribution, and resource planning. The City is the sole
water provider within the City limits and most of the City’s water is supplied from multiple surface
water sources. Groundwater is also used to supplement surface water supplies and recycled water is
used to supplement irrigation demand. The Water and Wastewater Element of the General Plan,
first adopted in 1987 and most recently updated in 2018, specifies that the City shall utilize multiple
water resources, including the Salinas Reservoir, Nacimiento Reservoir, and recycled water from the
City’s Water Resource Recovery Facility (WRRF), to meet water needs.64 The CAP Update and GHG
Emissions Thresholds would not result in new land uses that would contribute to an increase in
water use compared to existing conditions or require relocation or construction of new water
infrastructure. Therefore, no impact related to need for construction or expansion of water supply
facilities and infrastructure would occur.
Wastewater Treatment Facilities/Infrastructure
The City of San Luis Obispo WRRF collects and processes wastewater from land uses in the City, Cal
Poly, and the airport. The WRRF treats approximately 4.5 million gallons per day (mgd) of
wastewater, prior to discharge to San Luis Obispo Creek.65 The CAP Update and GHG Emissions
Thresholds would not result in new land uses that would generate sanitary wastewater or otherwise
contribute to an increase in wastewater treatment requirements. The amount or characteristics of
wastewater treated at the WRRF would not change compared to existing conditions with
implementation of the proposed plan. The CAP Update and GHG Emissions Thresholds would not
require relocation or construction of new wastewater collection or treatment infrastructure.
Therefore, no impact related to need for construction or expansion of wastewater treatment
facilities and infrastructure would occur.
Stormwater Drainage Facilities/Infrastructure
As discussed in Section 10, Hydrology and Water Quality, the GHG Emissions Thresholds provide
guidance during CEQA review, and does not propose development or changes to land use and
zoning. Thus, implementation of the GHG Emissions Thresholds would not have direct construction
or operational impacts related to alterations in polluted runoff. However, implementation of the
following CAP Update foundational actions and measures may promote infrastructure development
and redevelopment. Action Buildings 2.1 could include installation of on-site solar arrays within the
city. Action Connected 6.1 would require the installation of electric vehicle charging stations and
supporting infrastructure. Additionally, implementation of Actions Connected 2.1 through 2.3 may
64 San Luis Obispo, City of. 1987. General Plan Water and Wastewater Element. Last revised May 15, 2018. Available at:
https://www.slocity.org/home/showdocument?id=19965
65 San Luis Obispo, City of. 2019d. https://www.slocity.org/government/department -directory/utilities-
department/wastewater/wastewater-treatment
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80
require the installation of new bicycle or pedestrian facilities. Construction of infrastructure
development and redevelopment could result in erosion and potential redirect of flood flows or
drainage patterns. However, implementation of proposed actions would not include large scale
construction within San Luis Obispo and the CAP Update-related infrastructure changes would not
result in additional sources of polluted runoff. As a result, no negative impacts related to polluted
runoff would occur. Therefore, implementing the CAP Update would have no effect on polluted
runoff. As such, implementation of the CAP Update would not require a Stormwater Pollution
Prevention Plan (SWPPP). Therefore, no impact related to need for construction or expansion of
stormwater drainage facilities and infrastructure would occur.
Electric Power Facilities/Infrastructure
The CAP Update includes foundational actions, such as Actions Energy 1.1, 2.1, and 3.1 that focus on
carbon neutral electricity throughout the City by launching MBCP. In addition, new electric vehicle
charging station installation would involve the construction of new electric power facilities and
infrastructure and could also involve the relocation of existing electric power infrastructure and
transmission lines. The CAP Update and GHG Emissions Thresholds would serve as a pathway to
reduce GHG emissions and other beneficial environmental and sustainability effects. These benefits
include reduction in energy consumption. Therefore, the CAP Update and GHG Emissions
Thresholds would result in a less-than-significant impact related to construction, expansion, or
relocation of electric power facilities and infrastructure.
Natural Gas Power Facilities/Infrastructure
The CAP Update would not involve new land uses that require new or additional natural gas service.
However, implementation of the CAP could involve the relocation or removal of existing natural gas
facilities and infrastructure. The CAP Update would serve as a pathway to reduce GHG emissions
and other beneficial environmental and sustainability effects. These benefits include reduction in
energy consumption. Therefore, the CAP Update and GHG Emissions Thresholds would result in a
less-than-significant impact related to construction, removal, or relocation of natural gas power
facilities and infrastructure.
Telecommunications Facilities/Infrastructure
The proposal plan would not involve new land uses that would require telecommunications
infrastructure and is not anticipated to involve the relocation of existing telecommunications
facilities. Therefore, the CAP Update and GHG Emissions Thresholds would result in no impact
related to need for construction or expansion of telecommunication facilities and infrastructure.
19b, 19c. Would the project have sufficient water supplies available to serve the project and
reasonably foreseeable future development during normal, dry and multiple dry years?
Would the project result in a determination by the wastewater treatment provider which
serves or may serve the project that it has adequate capacity to serve the project’s
projected demand in addition to the provider’s existing commitments?
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to water supplies. The CAP Update is a policy-
level document that does not include site-specific infrastructure designs or project proposals, nor
does it grant entitlements for development that would have the potential to increase demand for
Environmental Checklist
Final Initial Study–Negative Declaration 81
water supply or other utility services. Implementing the CAP Update would include no new
residential construction and would have no effect on water demand and wastewater treatment
demand. Thus, the CAP Update and GHG Emissions Thresholds would result in no impact related to
water supply and wastewater treatment.
19d, 19e. Would the project generate solid waste in excess of State or local standards, or in excess
of the capacity of local infrastructure, or otherwise impair the attainment of solid waste
reduction goals? Would the project comply with federal, State, and local management
and reduction statutes and regulations related to solid waste?
The City of San Luis Obispo Utilities Department is responsible for administering an exclusive
franchise agreement with San Luis Garbage Company to collect and dispose solid waste generated
by residential, commercial, and industrial customers in San Luis Obispo. There are three solid waste
disposal facilities within San Luis Obispo County, including Cold Canyon Landfill located in San Luis
Obispo, Chicago Grade Landfill located in Atascadero, and Paso Robles Landfill located in Paso
Robles.66
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to solid waste. The CAP Update includes Pillar
5: Circular Economy, which is intended to divert 75 percent of landfilled organic waste by 2025 and
90 percent by 2035. Specifically, foundational actions Circular Economy 1.1 through 1.3 would
require organic waste subscription for all residential and commercial customers, 20 percent increase
in edible food rescue, and development and implementation of a waste stream education program
for HOAs and property managers. Additionally, Climate Action Natural Solutions 1.1 proposes
conducting a carbon farming study and pilot program at Johnson Ranch Open Space and City Farm
starting in the year 2020, with monitoring through to the year 2023. Carbon Farming involves
implementing practices that are known to improve the rate at which CO2 is removed from the
atmosphere and converted to plant material and/or soil organic matter. If determined feasible and
cost-effective, compost would be applied to the first annual 100 acres by the year 2023. The CAP
Update would not facilitate habitable development and, thus, would not affect solid waste
collection and disposal demand. Additionally, because the CAP Update is a policy document that
would not facilitate growth beyond that anticipated by the General Plan, it would not generate solid
waste in excess of State or local standards. Therefore, the CAP Update and GHG Emissions
Thresholds would result in no impact related to solid waste.
Cumulative Impacts
Implementing the CAP Update and GHG Emissions Thresholds would not result in increases in
population or induce additional population growth that would require additional use of existing City
utilities or service systems. However, implementation of new or replacement energy or
transportation infrastructure could result in less-than-significant cumulative construction impacts.
Furthermore, as a guidance document, the GHG Emissions Thresholds would not result in
cumulative impacts. Thus, implementation of the CAP Update GHG Emissions Thresholds would
result in an overall less-than-significant cumulative impact related to utilities and service systems.
66 San Luis Obispo, City of. 2014. Land Use and Circulation Update Draft Program EIR. Available at:
https://www.slocity.org/home/showdocument?id=6723
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
82
20 Wildfire
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan? □ □ □ ■
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire? □ □ □ ■
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment? □ □ □ ■
d. Expose people or structures to significant
risks, including downslopes or
downstream flooding or landslides, as a
result of runoff, post-fire slope instability,
or drainage changes? □ □ □ ■
20a-20d. If located in or near State responsibility areas or lands classified as very high fire hazard
severity zones, would the project:
▪ Substantially impair an adopted emergency response pla n or emergency evacuation
plan?
▪ Due to slope, prevailing winds, and other factors, exacerbate wildfire risks and thereby
expose project occupants to pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire?
▪ Require the installation or maintenance of associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines or other utilities) that may exacerbate
fire risk or that may result in temporary or ongoing impacts to the environment?
▪ Expose people or structures to significant risks, including downslopes or downstream
flooding or landslides, as a result of runoff, post-fire slope instability, or drainage
changes?
Environmental Checklist
Final Initial Study–Negative Declaration 83
According to California Department of Forestry and Fire Protection (CalFIRE), the City of San Luis
Obispo is not located in a designated California Fire Hazard Severity Zones67 or in a State
Responsibility Area. According to the City’s General Plan Safety Element, the urban reserve consists
of low to moderate fire hazard risk rates.68 High and extreme fire hazard rates closely surround the
San Luis Obispo urban reserve. And according to CalFIRE, there are five areas categorized as very
high fire hazard severity zones within the local responsibility area (LRA).69 However, these areas are
located just outside the City boundaries.
The GHG Emissions Thresholds is a guidance document and does not propose development or
changes to land use and zoning. Thus, implementation of the GHG Emissions Thresholds would not
result in construction or operational impacts related to wildfire. Additionally, the CAP Update is a
policy-level document that does not propose new habitable development that could be at risk from
wildfire, nor does it grant entitlements for development that would have the potential to directly
cause wildfire. Rather, the CAP Update would aim to reduce natural gas infrastructure that poses
wildfire risk if damaged during seismic events and to underground new or restructured electric
power lines that pose wildfire risk if damaged during high-wind events. Thus, the CAP Update and
GHG Emissions Thresholds would result in no impact related to wildfire.
Cumulative Impacts
The City of San Luis Obispo General Plan Update EIR did not provide a cumulative impact
assessment related to wildfires. And the CAP Update and GHG Emissions Thresholds do not include
new habitable development that could be at risk from wildfire, nor does it grant entitlements for
development that would have the potential to cause wildfire. Furthermore, as a guidance
document, the GHG Emissions Thresholds would not result in cumulative impacts. Thus, the CAP
Update and the GHG Emissions Thresholds would result in no cumulative impact related to wildfire.
67 California Department of Forestry and Fire Protection (CalFIRE). Local Responsibility Area. Available at:
https://osfm.fire.ca.gov/media/5980/san_luis_obispo.pdf
68 San Luis Obispo, City of. City of San Luis Obispo Safety Element Wildland Fire Hazard. Available at:
https://www.slocity.org/home/showdocument?id=2274
69 CalFIRE. Very High Fire Hazard Severity Zones in LRA As Recommended by
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
84
21 Mandatory Findings of Significance
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Does the project:
a. Have the potential to substantially degrade
the quality of the environment,
substantially reduce the habitat of a fish or
wildlife species, cause a fish or wildlife
population to drop below self-sustaining
levels, threaten to eliminate a plant or
animal community, substantially reduce
the number or restrict the range of a rare
or endangered plant or animal or eliminate
important examples of the major periods
of California history or prehistory? □ □ ■ □
b. Have impacts that are individually limited,
but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the effects
of other current projects, and the effects of
probable future projects)? □ □ ■ □
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or indirectly? □ □ ■ □
21a. Does the project have the potential to substantially degrade the quality of the environment,
substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to
drop below self-sustaining levels, threaten to eliminate a plant or animal community,
substantially reduce the number or restrict the range of a rare or endangered plant or animal or
eliminate important examples of the major periods of California history or prehistory ?
The intent of the 2020 CAP Update is to reduce GHG emissions from San Luis Obispo community
operations through implementation of measures and supporting foundational actions. The CAP
Update foundational actions are consistent with the San Luis Obispo General Plan and encourage
residents, businesses, and the City to reduce energy, fuel use, water use, VMT, and solid waste
generation and the associated GHG emissions. The CAP Update would not facilitate development
that would eliminate or threaten wildlife habitats or eliminate important examples of the major
periods of California history or prehistory. Furthermore, as a guidance document, the GHG
Emissions Thresholds would not result in significant biological and cultural resources impacts.
Therefore, as discussed in more detail in Sections 4, Biological Resources, and 5, Cultural Resources,
Environmental Checklist
Final Initial Study–Negative Declaration 85
the CAP Update and GHG Emissions Thresholds would result in a less-than-significant impact
related to biological and cultural resources.
21b. Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are considerable
when viewed in connection with the effects of past projects, the effects of other current
projects, and the effects of probable future projects)?
Implementation of the 2020 CAP Update would result in a cumulatively beneficial reduction of GHG
emissions across the City. In addition, as discussed throughout the respective cumulative impacts
discussions within this document, the CAP Update and GHG Emissions Thresholds would not result
in significant cumulative impacts. Rather, implementation of the CAP Update would be consistent
with General Plan policies aimed at reducing emissions of GHGs and air pollutants, reducing VMT,
reducing energy and water supply demands on utilities, and decreasing solid waste generation.
Furthermore, as a guidance document, the GHG Emissions Thresholds would not result in
cumulative impacts. Therefore, the CAP Update and GHG Emissions Thresholds would result in an
overall less-than-significant cumulative impact related to all CEQA topics addressed within this
document.
21c. Does the project have environmental effects which will cause substantial adverse effects on
human beings, either directly or indirectly?
The 2020 CAP Update would not result in adverse effects on human beings. Rather, as discussed
throughout this document, the CAP Update would serve as a pathway to reduce GHG emissions and
other positive environmental and sustainability effects. These benefits include reduction in building
energy consumption and VMT (and thus air pollution), in transportation related GHG emissions,
energy and water consumption, and solid waste generation. However, as discussed in more detail in
Sections 3, Air Quality, 13, Noise, and 17, Transportation, the CAP Update could cause temporary
construction impacts related to transportation, air quality, and noise that could, in turn, affect
human beings but would not result in a substantial adverse environmental effect. Furthermore, as a
guidance document, the GHG Emissions Thresholds would not result in significant air quality, noise,
and transportation impacts. Therefore, the CAP Update and GHG Emissions Thresholds would result
in a less-than-significant impact related to potential for adverse effects on human beings.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
86
References
List of Citations
Best Places. Climate in San Luis Obispo, California. Available at:
https://www.bestplaces.net/climate/city/california/san_luis_obispo
California Air Resources Board (CARB).
_____. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. Available at:
https://www.arb.ca.gov/ch/handbook.pdf
_____. 2016. State SIP Strategy. Available at:
https://ww3.arb.ca.gov/planning/sip/2016sip/2016sip.htm
_____. 2017. AB 32 Scoping Plan. Available at:
https://ww3.arb.ca.gov/cc/scopingplan/scopingplan.htm
_____. 2019. Area Designations Maps/State and National. Available at:
https://ww3.arb.ca.gov/desig/adm/adm.htm
California Department of Conservation (DOC). 2015. CGS Information Seismic Hazards Programs
https://maps.conservation.ca.gov/cgs/DataViewer/
California Department of Fish and Wildlife. California Forests and Timberlands in the California
Department of Fish and Wildlife Regions. Available at:
https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=109919&inline
California Department of Forestry and Fire Protection (CalFIRE).
_____. Local Responsibility Area. Available at:
https://osfm.fire.ca.gov/media/5980/san_luis_obispo.pdf
_____. Very High Fire Hazard Severity Zones in LRA As Recommended by
California Department of Transportation (Caltrans). 2013. Transportation and Construction Vibration
Guidance Manual (CT-HWANP-RT-13-069.25.3).
http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf
California Energy Commission. Environmental Health and Equity Impacts from Climate Change and
Mitigation Policies in California: A Review of the Literature. March 2009.
California Environmental Protection Agency (CalEPA), March 2006. Climate Action Team Report to
Governor Schwarzenegger and the Legislature.
Federal Emergency Management Agency (FEMA). FEMA Flood Map Service Center. Available at:
https://msc.fema.gov/portal/search?AddressQuery=turlock%2C%20ca#searchresultsanchor
Federal Highway Administration (FHWA). 2006. FHWA Highway Construction Noise Handbook.
(FHWAHEP-06-015; DOT-VNTSC-FHWA-06-02).
http://www.fhwa.dot.gov/environment/construction_noise/handbook
References
Final Initial Study–Negative Declaration 87
Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment Manual.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-
innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no-
0123_0.pdf
Regional Transit Authority. SoCoTransit. Available at: https://www.slorta.org/schedules-fares/
San Luis Obispo, City of.
_____. 1987. General Plan Water and Wastewater Element. Last revised May 15, 2018. Available at:
https://www.slocity.org/home/showdocument?id=19965
_____. 1996. General Plan Noise Element. Available at:
https://www.slocity.org/home/showdocument?id=6643
_____. General Plan Parks and Recreation Element. Available at:
https://www.slocity.org/home/showdocument?id=6647
_____. 2006. General Plan Open Space and Conservation Element. Available at:
https://www.slocity.org/home/showdocument?id=6651
_____. 2006. Local Hazard Mitigation Plan (LHMP). Available at:
https://www.slocity.org/home/showdocument?id=60
_____. 2010. City of San Luis Obispo List of Mills Act Properties. Available at:
https://www.slocity.org/home/showdocument?id=4160
_____. 2012. Economic Development Strategic Plan. Last Revised March 17, 2015. Available at:
https://www.slocity.org/home/showdocument?id=4901
_____. 2012. City of San Luis Obispo Climate Action Plan. Available at:
https://www.slocity.org/home/showdocument?id=2398
_____. 2014. General Plan Land Use Element. Available at:
slocity.org/home/showdocument?id=6635
_____. 2014. General Plan Circulation Element. Last amended in 2017. Available at:
https://www.slocity.org/home/showdocument?id=20412
_____. 2014. Land Use and Circulation Update Draft Program EIR. Available at:
https://www.slocity.org/home/showdocument?id=6723
_____. 2019. Carbon Neutrality and Three-Year Strategic Plan Technical Report.
_____. 2019. Community Greenhouse Gas Emissions Inventory and Forecast.
_____. 2019. SLO TRANSIT. Available at: https://www.slocity.org/government/department-
directory/public-works/slo-transit
_____. City of San Luis Obispo Safety Element Wildland Fire Hazard. Available at:
https://www.slocity.org/home/showdocument?id=2274
_____. Municipal Code. Available at: https://sanluisobispo.municipal.codes/Code/17.12
_____. San Luis Obispo, City of. Parks and Recreation Facilities in San Luis Obispo. Available at:
https://www.slocity.org/home/showdocument?id=2270
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
88
_____. San Luis Obispo City Flood Prep Map. Available at:
https://www.arcgis.com/apps/webappviewer/index.html?id=97ed3e37de014973a2d36f71a
e468975
_____. Zoning Map. Available at: https://www.slocity.org/home/showdocument?id=5857
San Luis Obispo Council of Governments (SLOCOG). 2019. 2019 Regional Transportation Plan:
Connecting Communities. Available at: https://slocog.org/2019RTP (accessed January 2020).
San Luis Obispo, County of.
_____. San Luis Obispo County Flood Control and Water Conservation District. Guide to
Implementing Flood Control Projects. 2009. Available at:
https://www.slocounty.ca.gov/Departments/Public-Works/Forms-Documents/Water-
Resources/Drainage-Studies/Guide-to-SLO-Flood-Management-Report.aspx
See California. Mission San Luis Obispo. Available at: http://www.seecalifornia.com/missions/san-
luis-obispo-mission.html
United States Energy Information Administration (EIA).
____. 2018. “California - Profile Overview.” Last modified: November 15, 2018. Available at:
https://www.eia.gov/state/?sid=CA
____. 2018. Natural Gas: Natural Gas Consumption by End Use. December 31, 2018. Available at:
https://www.eia.gov/dnav/ng/ng_cons_sum_dcu_SCA_a.htm
Whendee, Silver et al. Grassland Compost Amendments Increase Plant Production Without
Changing Plant Communities. Available at: https://www.marincarbonproject.org/file/2018-
documents/5_Grassland-compost-amendments-increase-plant-production-without-
changing-plant-communities.pdf
List of Document Preparers
Rincon prepared this CAP Update and GHG Emissions Thresholds Initial Study-Negative Declaration
under contract to the City of San Luis Obispo. Persons involved in data gathering, environmental
impact analysis, quality review, graphics preparation, and document formatting include the
following.
RINCON CONSULTANTS, INC .
Matthew Maddox, Principal
Kelsey Bennett, Environmental/Sustainability Senior Program Manager
Sarah Howland, Environmental Planner
Annaliese Miller, Environmental Planner
Debra Jane, Document Formatting Specialist
Audrey Brown, Graphics Specialist
Appendix A
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants
Appendix A
Final Initial Study–Negative Declaration A-1
Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants
Pollutant Sources Health Effects Typical Controls
Ozone (O3) Formed when reactive organic
gases (ROG) and nitrogen
oxides react in the presence of
sunlight. ROG sources include
any source that burns fuels
(e.g., gasoline, natural gas,
wood, oil); solvents;
petroleum processing and
storage.
Breathing difficulties, lung
tissue damage, vegetation
damage, damage to rubber
and some plastics.
Reduce motor vehicle reactive
organic gas (ROG) and
nitrogen oxide (NOX) emissions
through emission standards,
reformulated fuels,
inspections programs, and
reduced vehicle use. Limit
ROG emissions from
commercial operations,
gasoline refueling facilities,
and consumer products. Limit
ROG and NOX emissions from
industrial sources such as
power plants and
manufacturing facilities.
Carbon monoxide
(CO)
Any source that burns fuel
such as automobiles, trucks,
heavy construction and
farming equipment, residential
heating.
Chest pain in heart patients,
headaches, reduced mental
alertness.
Control motor vehicle and
industrial emissions. Use
oxygenated gasoline during
winter months. Conserve
energy
Nitrogen dioxide
(NO2)
See Carbon Monoxide. Lung irritation and damage.
Reacts in the atmosphere to
form ozone and acid rain.
Control motor vehicle and
industrial combustion
emissions. Conserve energy.
Sulfur dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.
Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.
Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.
Respirable
particulate matter
(PM10)
Road dust, windblown dust,
agriculture and construction,
fireplaces. Also formed from
other pollutants (NOX, SOX,
organics).
Increased respiratory disease,
lung damage, cancer,
premature death, reduced
visibility, surface soiling.
Control dust sources,
industrial particulate
emissions, woodburning
stoves and fireplaces. Reduce
secondary pollutants which
react to form PM10. Conserve
energy.
Fine particulate
matter (PM2.5)
Fuel combustion in motor
vehicles, equipment, and
industrial sources; residential
and agricultural burning. Also
formed from reaction of other
pollutants (NOX, SOX, organics,
and NH3).
Increases respiratory disease,
lung damage, cancer, and
premature death, reduced
visibility, surface soiling.
Particles can aggravate heart
diseases such as congestive
heart failure and coronary
artery disease.
Reduce combustion emissions
from motor vehicles,
equipment, industries, and
agricultural and residential
burning. Precursor controls,
like those for ozone, reduce
fine particle formation in the
atmosphere.
Lead Metal smelters, resource
recovery, leaded gasoline,
deterioration of lead paint.
Learning disabilities, brain and
kidney damage. Control metal
smelters.
No lead in gasoline or paint.
Sulfur Dioxide
(SO2)
Coal or oil burning power
plants and industries,
refineries, diesel engines.
Increases lung disease and
breathing problems for
asthmatics. Reacts in the
atmosphere to form acid rain.
Reduce use of high sulfur fuels
(e.g., use low sulfur
reformulated diesel or natural
gas). Conserve energy.
Sulfates Produced by reaction in the air
of SO2, (see SO2 sources), a
component of acid rain.
Breathing difficulties,
aggravates asthma, reduced
visibility.
See SO2
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
A-2
Pollutant Sources Health Effects Typical Controls
Hydrogen Sulfide Geothermal power plants,
petroleum production and
refining, sewer gas.
Nuisance odor (rotten egg
smell), headache and
breathing difficulties (higher
concentrations).
Control emissions from
geothermal power plants,
petroleum production and
refining, sewers, and sewage
treatment plants.
Visibility Reducing
Particulates
See PM2.5 Reduced visibility (e.g.,
obscures mountains and other
scenery), reduced airport
safety.
See PM2.5
Vinyl Chloride Exhaust gases from factories
that manufacture or process
vinyl chloride (construction,
packaging, and transportation
industries).
Central nervous system effects
(e.g., dizziness, drowsiness,
headaches), kidney irritation,
liver damage, liver cancer.
Control emissions from plants
that manufacture or process
vinyl chloride, installation of
monitoring systems.
Toxic Air
Contaminant
(TAC)
Combustion engines
(stationary and mobile), diesel
combustion, storage and use
of TAC-containing substances
(i.e., gasoline, lead smelting,
etc.)
Depends on TAC, but may
include cancer, mutagenic
and/or teratogenic effects,
other acute or chronic health
effects.
Toxic Best Available Control
Technologies (T-BACT), limit
emissions from known
sources.
Source: Compiled by Rincon Consultants, Inc. in March 2020
Appendix B
Description of Greenhouse Gases of California Concern
Appendix B
Final Initial Study–Negative Declaration B-1
Description of Greenhouse Gases of California Concern
Greenhouse Gas
Physical Description and
Properties
Global Warming
Potential
(100 years)
Atmospheric
Residence
Lifetime
(years) Sources
Carbon dioxide
(CO2)
Odorless, colorless, natural gas. 1 50–200 Burning coal, oil, natural gas,
and wood; decomposition of
dead organic matter;
respiration of bacteria, plants,
animals, and fungus; oceanic
evaporation; volcanic
outgassing; cement
production; land use changes
Methane
(CH4)
Flammable gas and is the main
component of natural gas.
2870 12 Geological deposits (natural
gas fields) extraction; landfills;
fermentation of manure; and
decay of organic matter
Nitrous oxide
(N2O)
Nitrous oxide (laughing gas) is a
colorless GHG.
298 114 Microbial processes in soil and
water; fuel combustion;
industrial processes
Chloro-fluoro-
carbons
(CFCs)
Nontoxic, nonflammable,
insoluble, and chemically
unreactive in the troposphere
(level of air at the Earth’s
surface); formed synthetically by
replacing all hydrogen atoms in
methane or ethane with
chlorine and/or fluorine atoms.
3,800–8,100 45–640 Refrigerants aerosol
propellants; cleaning solvents.
Hydro-fluoro-
carbons
(HFCs)
Synthetic human-made
chemicals used as a substitute
for CFCs and contain carbon,
chlorine, and at least one
hydrogen atom.
140 to 11,700 1–50,000 Automobile air conditioners;
refrigerants
Per-fluoro-
carbons (PFCs)
Stable molecular structures and
only break down by ultraviolet
rays about 60 kilometers above
Earth’s surface.
6,500 to 9,200 10,000–50,000 Primary aluminum production;
semiconductor manufacturing
Sulfur
hexafluoride
(SF6)
Human-made, inorganic,
odorless, colorless, and
nontoxic, nonflammable gas.
22,800 3,200 Electrical power transmission
equipment insulation;
magnesium industry,
semiconductor manufacturing;
a tracer gas
70 The City of San Luis Obispo used a 20-year Global Warning Potential for methane.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
B-2
Greenhouse Gas
Physical Description and
Properties
Global Warming
Potential
(100 years)
Atmospheric
Residence
Lifetime
(years) Sources
Nitrogen
trifluoride
(NF3)
Inorganic, is used as a
replacement for PFCs, and is a
powerful oxidizing agent.
17,200 740 Electronics manufacture for
semiconductors and liquid
crystal displays.
Source: Compiled by Rincon Consultants, Inc. in March 2020
Appendix C
Public Comments Received on Draft Initial Study -Negative Declaration
and Responses to Comments
Appendix C
Final Initial Study–Negative Declaration C-1
Responses to Comments Received on the SLO CAP/GHG Thresholds Draft IS-ND
Comment
#
Response to Comment
Sara Sanders, Transportation Planner, San Luis Obispo Council of Governments
(SLOCOG)
letter received July 20, 2020
1 Recognition by the San Luis Obispo Council of Governments regarding that fact that
the City of San Luis Obispo 2020 Climate Action Plan (CAP) is in alignment with the
2019 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) is
noted. As this comment does not address the content or adequacy of the CEQA
analysis, no changes to the IS-ND were made as a result.
2 Comment noted. The City looks forward to coordinating with information-based
services as suggested. As this comment does not address the content or adequacy of
the CEQA analysis, no changes to the IS-ND were made as a result.
3 Comment noted. This level of detail will be evaluated when the City conducts the
2018 GHG emissions inventory update, which will be completed in a collaborative
partnership with Monterey Community Power (MBCP) and San Luis Obispo Air
Pollution Control District (SLOACPD). As this comment does not address the content
or adequacy of the CEQA analysis, no changes to the IS-ND were made as a result.
4 The 2018 GHG emissions inventory that will be initiated in the final quarter of 2020
with support from MBCP and SLOAPCD will be updated utilizing EMFAC2017. As this
comment does not address the content or adequacy of the CEQA analysis, no
changes to the IS-ND were made as a result.
Jenna Schudson, Development Review Coordinator, Caltrans District 5
(Caltrans Dist. 5)
letter received July 22, 2020
1 Comment noted. As this comment does not address the content or adequacy of the
CEQA analysis, no changes to the IS-ND were made as a result.
2 The Caltrans reminder regarding employment of the Vehicle Miles Traveled (VMT)
metric for transportation impact assessment is noted. As a matter of information, on
June 16, 2020 the City adopted a resolution to replace Level of Service (LOS) with
VMT as the City’s performance measure for CEQA analysis of transportation impacts
and approve revisions to the City’s Multimodal Transportation Impact Study
Guidelines. As this comment does not address the content or adequacy of the CEQA
analysis, no changes to the IS-ND were made as a result.
Jacqueline Mansoor, Air Quality Specialist, SLO County Air Pollution Control District
(SLO Co. APCD)
email received July 14, 2020
1 No menu of CEQA mitigation measures currently exists nor is included in the City’s
CEQA GHG Thresholds Guidance Document. For future plans and projects that are
not able to demonstrate consistency with the City’s 2020 CAP, a quantitative GHG
emissions analysis will be required and evaluated using the numeric thresholds
established in the City’s CEQA GHG Thresholds Guidance Document, and respective
project/plan-specific mitigation measures will need to be prepared and implemented
as necessary in order to reduce GHG emissions impacts to the maximum extent
feasible. As this comment does not address the content or adequacy of the CEQA
analysis, no changes to the IS-ND were made as a result.
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
C-2
Appendix C
Final Initial Study–Negative Declaration C-3
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
C-4
Appendix C
Final Initial Study–Negative Declaration C-5
City of San Luis Obispo
Climate Action Plan Update and CEQA GHG Emissions Thresholds
C-6