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HomeMy WebLinkAboutFroom Ranch - Advisory Body DEIR commentsFroom Ranch EIR Advisory Body Comments on Draft EIR Wanted clarification on whether historic resources are being considered as a district, individual resources, or as a multi-component resource. See emails from Eva Ulz 12/3/2019. Multi-component resource may be an even better classification than historic district. MM CR-8 should consider requiring native plantings, seeking guidance from consultation with tribal representatives, if possible. Monitoring is not mitigation, we need to be able to state how the City is working with Native Americans. MM CR-10 HABS Photographic Documentation. No HABS level is identified, as per NPS guidelines. In no case is photography alone sufficient to meet HABS guidelines. Suggest choosing an appropriate HABS level (I, II, or III) based on the significance of each resource to be documented and following the NPS recommendations at https://www.nps.gov/hdp/standards/standards_regs.pdf. Suggest treating the documentation as pertaining to the entire complex so that functional relationships between buildings can be documented as well. We should also consider using additional documentary tools beyond HABS, inclduing oral histories or LIDAR/photogrammetry via drone to create 3D documentation. MM CR-11 Interpretive Pamphlet. Pamphlets are an ancillary (and slightly outmoded in modern practice) vehicle for distributing an interpretive message, whose primary form should be semi-permanent and presented on site. It would be better to focus on the development of an interpretive plan for the Froom Ranch dairy complex and/or traditional tribal uses that encompasses a multi-disciplinary approach to interpretation, as well as the installation of signage (mentioned briefly in mitigtation description) as the main thrust of this mitigation, and mention the pamphlets at the end instead of the reverse. The key product should be the interpretive plan, not a pamphlet. If digital content will be available, consider reconfiguring it into mobile-friendly forms to accompany the physical signage so that readers with digital devices can access it in situ. It would be helpful to clarify in the EIR how the elevation changes at the quarry location. It would be helpful to overlay site plans over satellite/aerial imagery, so you can see where buildings would be relocated. Chair Haydu recommended having 3rd unrecorded site evaluated at same level as other two (Extended Phase I). Need evaluation for clear and accurate baseline, clear and accurate mitigation. Can't say with certainty that site will be avoided. Discuss the impacts of a modified Alternative 1 that keeps the public park at the applicant's preferred location. Does this belong in the Final EIR? PRC majority agreed that it was fair to give Villaggio some park acreage credit for providing the Froom Creek Trail. ATC commented that the EIR struggles with a lack of well laid out maps showing proposed features. FEIR needs more maps, show Collector A. FEIR should add a reference to Avila Ranch SP for Buckley/Vachell requirement. Costco/Target/LOVR/Froom Ranch Way - no crosswalks in all directions. Queue times is double that for cars, but is not addressed in mitigation. Location of bus stop 1/2 mile away will impact riderhood. Big red flag about why transit is not closer, particularly to Villaggio populations. DEIR is confusing re: who is responsible to pay for transportation improvements. Are there enough parties to pay for completion of identified mitigation? Healthy communities committee wants to see an increase in mode share. Is there an opportunity to increase (e.g., cycle tracks, walking easier than driving, more progressive /mm)? Need additional clarity that shows the features of the /mm, but stop, bike paths. Need additional maps. Clarify what is proposed re: protected bike lanes and pedestrian crossings as a priority. Move definition of Class I bike path up before first mention of Class I bike lane. Clarify whether wait times are for cars only? Should also include wait times for ped/bike. Construction management, EIR should include separate bike facility during construction. EIR section is hard to read. Concerns about fair share vs. actual implementation. Suggests creation of a fund with a formula that takes into account the Climate Action Plan and mode increases (developer money towards program/fund). Concern about the Villaggio park acreage calculation/requirement. It is an unfair burden on the project and project costs. City goal for carbon neutrality by 2035. Not sure EIR goes far enough to achieve this. This project could be precedent setting for GHG reductions. Los Verdes concerns include traffic circulation, air quality, creek impacts, noise, flooding, and road improvements. Want to be sure all environmental impacts are mitigated in a way thto benefit the community and surrounding neighborhoods. LOVR is already greatly impacted, and there was a recent fatality on LOVR. The right turn-lane on 101 is inadequate and backs up. LOVR/S. Higuera is congested and too narrow, needs mitigation, too heavily impacted. Trucks are tearing up the roads. Dust and dirt are not being sufficiently mitigated. The trees at San Luis Ranch were butchered. The City is pushing forward its Climate Action Plan, including planting trees, but it will take years and years to realize the benefit from this. CNPS commented that SLO is a unique location, surrounded by a series of serpentine hills that are not found elsewhere in the world, with multiple very rare plant species. We need to think about long-term implications; this is the last area in front of the Irish Hills that is not developed. Water flow is a big issue; wetlands/creek/steelhead are big issues. Need to consider whether we are making the right choices here for future generations to be able to enjoy. The creek leads to stormdrains, flood control is a concern. CNPS supports Alternative 1, asserts long-term responsibilities to protect these areas. Concerns with Appendix H Hydrology Report and conclusions that hydrology can be mitigated. The historic flow of the creek did not turn within the site until it was diverted in the 1940s. Current flow is 1 foot descent per every 100 feet. The creek, plus LOVR ditch, plus Irish Hills will carry flow into the jurisdictional wetlands. The existing stormwater basin would be removed from the site, which is bad for flash flow. Appendix H, page 156, shows that during a 2-year storm event, current flows into the wetland (253 cfs) would increase to 518 cfs, and over 1,000 cfs at higher storm events. There is no analysis of where all this water will go. The analysis does not include an assessment of the exit drainage (offsite); there is a large amount of water flowing into the wetland with no description of where it will go. There is a new wall on the 101 on-ramp that will block flows. The Taco Temple location may be jeopardized. Concerns regarding unacceptable environmental impacts imposed on the community, some of which lead to bad precedent (change in 150-foot development limit). Applauds applicant's intent to move forward with project that avoids development in the Upper Terrace; thinks all areas above 150 feet should be preserved. The realignment of Froom Creek is inconsistent with the Creek Setback Ordinance. There is a potential legal issue with adjusting the boundaries of the existing conservation easement on the property, and it sets a very bad precedent. See written comments. Need to consider balancing of environmental impacts and the needs of seniors; the facility will be dynamic to community needs. Add a trail map, so you can see how close you are to the open space trails. Add a provision to delay LOVR veg removal as much as possible to screen construction activities. Wants to see additional language about robust riparian planting to achieve screening along creek. Disagrees with Class I visual impact. If retained, EIR should include landscaping along sections visible from trail (shrubs/trees/native) to help soften impacts. Add reference to using muted, earthtone colors, use brown roofs to recede into background, etc., especially for development above 150-feet. Is it appropriate to require visual treatment for retaining walls at a certain height? Also fencing? White is very bright, at what height should treatments/use of darker colors/muted earthtone colors be considered? If Class I impact to AQ/GHG, is it appropriate to include requirements for solar or other measures to reduce emissions? e.g., solar on sun-facing roofs, additional solar to help offset impacts? Add bio /mm for worker environmental awareness training. Add bio /mm for good housekeeping (e.g., to prevent nesting in construction equipment). Rethink use of 'containers' and instead refer to something more generic. Not all plants come in 'containers' (e.g. willow tubes). Identify how much of the creek would be armored. What would riparian vegetation look like in armored sections? What quality of riparian vegetation can establish in armored sections (e.g., rip-rap)? Thinks this is potentially a very significant cultural site. We should better understand cultural resources now, rather than later. We should do full subsurface investigations of these sites. Replicate CR-11 /mm (develop interpretive project that documents cultural and architectural heritage) for Chumash history? The development of more information as /mm should be built into the project (e.g., ethnobotanical garden, public art, interpretational signage informing public, incorporated into historic site, etc.). The project should stress the Chumash use of the site. Confirm (in GEO /mm or PD) that no habitable structures are proposed within the fault setbacks. Include reference to City regulations prohibiting this. Is the EIR the appropriate place to discuss things like cement roofs or other features in buildings that would help protect them from wildfire? 4-story buildings w/ elevators and senior/assisted living populations. If power loss, perhaps mitigate with requirement for backup power? The site needs more than one way in and out. Supports any effort to include a full access to Calle Joaquin to increase evacuation alternatives. Number of hydro issues were raised in Neil Havlick's comment letter. Would like to see those addressed. EIR includes a discussion about a fair amount of fill. Was a study done to evaluate the elimination of the flood zone and any impacts downstream? Want to make sure this is adequately addressed. Could the 174 units in Madonna Froom Ranch be considered for senior housing as well? Different from Villaggio but age restricted as well? Would be good to include that as a sub-alternative. Noise study should not be deferred. Why not do it now in the interest of full disclosure? Project creates need for 1 new fire, 1 new police… funding for these is "soft" impact, but since outside of applicant's control, should it be Class 1 significant and unavoidable or discussed further? Project would be adding 300-400 new dogs, look into dog park area at Mountainbrook Church? Retention basins are common areas for dog park uses. EIR should explain the rationale for Villaggio being responsible for full parks acreage requirements. Why no credit for onsite facilities being provided? Traffic on LOVR is bad and going to get worse. The /mm idenfitied in the EIR actually needs to get built. Agrees with /mm and encourages the City/applicant to complete them as quickly as possible. Agree with restricted turn at Buckley & Vachell, but this will worsen traffic on the 227, as people use it as a short-cut. Agree with requirement for traffic calming within the site, but don't use speed humps, they are bad on emergency vehicles. Looks like the transportation analysis is from 2016/2017, worried about age of data (e.g., LOVR overpass was just constructed and it is immediately full to the brim). It's getting worse every day; goal of LOS D may be optimistic. Project goals are worth the extra traffic, but concerned with age of data. Concerned with projections based on what is seen on the ground today, not based on the project itself. Caltrans stated they have no capacity within their right of way to handle water, so if not accommodated onsite, flooding could be an issue (flooding on the highway). Add clarifying language to each /mm referenced in EIR (key descriptor words) so you don't have to flip back and forth to figure out what measure is being referred to. Commenter CHC Ulz CHC Ulz CHC Ulz CHC Ulz CHC Ulz CHC Papp CHC Matteson CHC Haydu CHC PRC ATC ATC ATC ATC ATC ATC ATC ATC ATC ATC ATC PC public comments PC public comments PC public comments (Los Verdes) PC public comments (CNPS) PC public comments (Chipping) PC public comments (Havlick) PC public comments PC McKenzie PC McKenzie PC McKenzie/Wulkan PC McKenzie PC McKenzie PC McKenzie PC McKenzie PC McKenzie PC McKenzie PC McKenzie PC Stevenson PC McKenzie PC Jorgensen PC Jorgensen PC McKenzie PC Jorgensen PC McKenzie PC Stevenson PC Wulkan PC McKenzie PC McKenzie PC Wulkan PC Kohn PC Kohn PC Kohn PC Jorgensen/Stevenson PC Stevenson PC McKenzie Date 11/18/2019 11/18/2019 11/18/2019 11/18/2019 11/18/2019 11/18/2019 11/18/2019 11/18/2019 11/18/2019 12/4/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/10/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019 12/11/2019