HomeMy WebLinkAbout8/12/2020 Item 2, Havlik
Wilbanks, Megan
From:Scott, Shawna
Sent:Wednesday, August 12, 2020 2:44 PM
To:CityClerk
Cc:Emily Creel
Subject:FW: Froom Ranch Specific Plan
Attachments:Froom PC letter2.doc
Good afternoon,
Please post the attached agenda correspondence.
Thank you,
Shawna Scott
Senior Planner
Community Development
919 Palm Street, San Luis Obispo, CA 93401-3218
E sscott@slocity.org
T 805.781.7176
slocity.org
From: neilhavlik@aol.
Sent: Wednesday, August 12, 2020 2:43 PM
To: Scott, Shawna <sscott@slocity.org>; Emily Creel <ecreel@swca.com>
Subject: Froom Ranch Specific Plan
Greetings ladies, please forward the attached to the Planning Commission for tonight's meeting if you would. Thanks!
Neil Havlik
1
TO: The Honorable City of San Luis Obispo Planning Commission
FROM: Neil Havlik, California Native Plant Society, San Luis Obispo Chapter (CNPS -SLO)
SUBJECT: FROOM RANCH SPECIFIC PLAN PROJECT PROPOSAL AGENDA ITEM,
August 12-13, 2020
Dear Commissioners:
At your meeting of August 12-13, 2020, you will be asked to provide recommendations to the
City Council regarding the Froom Ranch Specific Plan Project (the “Project”), located on Los
Osos Valley Road and Calle Joaquin. The California Native Plant Society, San Luis Obispo
County Chapter (CNPS-SLO) would like to address various issues associated with this project
for your consideration.
First, we wish to acknowledge, and express our appreciation for, the important changes that have
been made to the project as a result of the analysis and findings of the Draft Environmental
Impact Report (DEIR), review of comments on the DEIR, and resultant Final EIR (FEIR) for the
project. We appreciate that the project sponsors have made significant adjustments to the project
in an attempt to accommodate environmental issues raised in the DEIR.
We still have questions and concerns about some of the proposals in the project, specifically the
ultimate disposition of the open space lands of the project site, and the effects of the rerouting of
Froom Creek around the project site.
The 150 foot elevation line. Again we acknowledge the project sponsors for their decision to
relocate those portions of the Villaggio project above the 150 foot elevation line to below that
line. The DEIR clearly showed the lands above that elevation to have significant resource value
which would be very difficult to mitigate, and many impacts were unavoidable except by project
redesign. Furthermore that elevation line has been an important limit in the City’s General Plan
in the Irish Hills area for many years, and is at least partially responsible for the creation of Irish
Hills Natural Reserve, the City’s largest open space.
We also acknowledge the effort on the Madonna portion of the project to redesign it to relocate
the historic Froom Ranch dairy buildings into a rural setting as opposed to the busy, urban
setting originally envisioned. We have been persuaded by the project sponsors that they have
done all that they could to stay below the 150 foot elevation line at the storage or quarry area,
and we therefore withdraw our opposition to the minor amount of private development currently
proposed at that site, which will be at or above the 150 foot elevation line. We base this upon
several findings, which we recommend that your Commission adopt or reference in justifying the
General Plan amendment that is necessary to allow this aspect of the development, to wit:
1. The storage or former quarry area has been so used for many years, with numerous
changes in elevation and ground materials due to quarrying activities and use of the site
for equipment and materials storage;
2. This use over the years has resulted in the site having very limited habitat value;
3. Re-grading and proper soil compaction of the site, relocating the historic Froom
Ranch buildings, developing a trailhead park which also serves neighborhood needs,
addressing the need for significant landscaping and habitat enhancement, and other
efforts, creates a particular burden on this portion of the Froom Ranch Specific Plan.
For these reasons a special and minor adjustment of the 150 foot elevation limit line in this
environmentally degraded location only can be justified to permit development as currently
(August 2020) proposed in the Froom Ranch Specific Plan. It will also retain the 150 foot
elevation limit for other portions of the Irish Hills affected by that General Plan requirement.
Open Space Lot. The Vesting Tentative Map for the Froom Ranch Specific Plan identifies most
(perhaps all) of the land above the 150 foot elevation in the Villaggio portion of the project site
as an open space lot (Lot 1). This lot also includes the so-called “cove” area, which holds the
property’s small woodland site and several small streams which flow into it. Again, we
recognize and appreciate the changes made in this location by the project sponsors, which have
resulted in the inclusion of the cove into the open space lot.
Our concern is the ultimate fate of Lot 1. There is no clear indication that the lot will be added to
Irish Hills Natural Reserve—which seems to us to be the most appropriate thing to do—and
discussion of this matter is vague. The EIR clearly identified the occurrence of numerous
conditions of high resource value on the site: a Federally recognized rare plant species; several
rare plant species of concern to the State of California, a rare habitat (serpentine grassland),
wetlands, and other features. City open space policies and programs clearly state that op en space
lands with conditions such as those above requiring special attention should be protected in City
ownership (See General Plan Open Space Element, Appendix B, Paragraphs 3A, B, E, and G;
4B, C, and D; and 5D). To provide further protection, a conservation easement held by a
qualified organization other than the City, which restricts permissible uses to those supportive of
open space and wildlife habitat (such as is already the case on the adjacent Irish Hills Natural
Reserve) should also be placed on this lot. We are hopeful that the project sponsors will make
such an offer or pledge voluntarily, but if it is not forthcoming we request that your Commission
include discussion of this matter in your recommendations to the City Council, as being in
keeping with existing City policies.
Changing the Agricultural Conservation Easement. We believe that the above offer or
pledge would be an important component of justifying the changes in the agricultural
conservation easement which have also been proposed. It means that the public will be gaining a
significant open space and ecological resource in exchange for the loss of a portion (1.6 acres) of
the existing 7.1 acre agricultural conservation easement. We acknowledge that other nearby
areas will be added to that easement thus actually enlarging it to 7.8 acres, but the additional 1.8
acres is not of equivalent value to the 1.6 acres being lost, so we believe that great care is needed
to avoid setting a precedent that the City could come to regret. In effect, in this “package”, the
project sponsors will be offering a number of public open space benefits—the open space lot, the
historic and trailhead park, a modified but enlarged agricultural conservation easement area, and
a reestablished Froom Creek—as compensation for the adjustment of the easement, and approval
of the project. We recommend that findings to that effect be included in your ultimate
recommendations to the City Council.
Rerouting of Froom Creek and Stormflow Issues. Our other major concern involves the
results of the rerouting of Froom Creek. Perhaps a finding that the opportunity presented by the
life plan community rises to the level of an overriding consideration justifying the exception to
the City’s creek setback ordinance is appropriate. We do recognize that the project sponsors
have made additional changes to the design of the Froom Creek rerouting to accommodate
concerns raised in the DEIR; we especially note the apparent elimination of the “outside curve”
levee. This levee had an opening in it which rendered it basically meaningless, and served
only as a slightly elevated landform inviting to weeds and other non-native and non-riparian
species. It is not clear from the submitted plans whether this elimination is complete or n ot, but
we would recommend its elimination from the point where the rerouted creek begins to parallel
the identified wetland boundary to the southerly end of the property. We appreciate the concept
of the larger area serving as a flood basin, but we remain concerned that the existing wetland
may get drowned with too much water over an extended period of time, and that the area may
not be able to hold all the water in a major storm event, placing at risk the existing developments
along Calle Joaquin in that area. Finally, we still have been unable to see the vision that the
project sponsors have for the rerouted creek, what its fully revegetated state might look like, and
how it would function ecologically. This rerouting and revegetation is a huge undert aking, will
take years to successfully complete, and has many potential pitfalls and points of failure.
Therefore we urge that your Commission recommend to the City Council that a highly detailed
restoration plan be required in submittal to the State and Federal regulatory agencies overseeing
such matters, and that this submittal demonstrate that (1) the rerouting will not adversely affect
the existing wetlands at Calle Joaquin, either by extensive flooding or by intercepting the
groundwater flow there, (2) that stormflows can safely and adequately exit the area (including
the so-called “cut-off” wetland) in safe and timely fashion, (3) that the proposed revegetation
palette will be diverse, healthy, and ecologically functional within a reasonable timeframe, and
(4) that the relocated detention basin will function ecologically at least as well as the current
basins which are proposed for removal.
We appreciate the opportunity to comment on this project with so much significance for the City
of San Luis Obispo. Thank you.
Neil Havlik, PhD,
City of San Luis Obispo Natural Resources Manager (retired)
California Native Plant Society, San Luis Obispo Chapter (CNPS -SLO)
August 12, 2020