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HomeMy WebLinkAboutItem 5a. 1320 Roundhouse Rd. LOSSAN Draft EIR for Central Coast Layover Facility PLANNING COMMISSION AGENDA REPORT SUBJECT: REVIEW OF THE DRAFT ENVIRONMENTAL IMPACT REPORT (DRAFT EIR) PREPARED FOR THE LOSSAN RAIL CORRIDOR AGENCY’S (LOSSAN) CENTRAL COAST LAYOVER FACILITY (CCLF). BY: Brian Leveille, Senior Planner FROM: Tyler Corey, Deputy Director Phone Number: 805-781-7166 Email: tcorey@slocity.org Email: bleveille@slocity.org RECOMMENDATION Receive public testimony and provide input to the LOSSAN Rail Corridor Agency and environmental consultants regarding any additional analysis or data needed to adequately evaluate environmental issue areas within the Draft EIR. 1.0 SUMMARY The Los Angeles – San Diego – San Luis Obispo (LOSSAN) Rail Corridor Agency is proposing an expansion and/or relocation of the existing layover facility adjacent to the San Luis Obispo Station. The LOSSAN Rail Corridor Agency is a joint powers authority that oversees the coastal rail line between San Diego, Los Angeles and San Luis Obispo. It is governed by a 11-member Board of Directors composed of elected officials representing rail owners, operators, and planning agencies along the rail corridor. The LOSSAN Agency is staffed by the Orange County Transportation Authorit y (OCTA)1. The Central Coast Layover Facility (CCLF) project is intended to increase overnight storage capacity to support the service goals and objectives for the Pacific Surfliner in the State Rail Plan and LOSSAN’s fiscal year Business Plan. The LOSSAN rail corridor is 351 miles in length and serves commuter trains, Amtrak intercity trains, and freight trains. The LOSSAN corridor is identified as the second most heavily traveled intercity passenger rail corridor in the nation. San Luis Obispo is at the northern terminus of the Amtrak Pacific Surfliner service. Currently, one Pacific Surfliner train overnights each day in San Luis Obispo for an early morning departure the following day. The proposed project will provide for maintenance of equipment at the northern terminus of the corridor and will allow for additional passenger trains to hold overnight and allow a second morning departure from San Luis Obispo. Additional storage and maintenance capacity will also allow for future further expansion of service. 1 LOSSAN Rail Corridor Agency website: https://www.octa.net/LOSSAN-Rail-Corridor-Agency/Overview/ Meeting Date: 12/8/2021 Item Number: 5a Time Estimate: 60 Minutes Page 11 of 28 Item 5a LOSSAN CCLF DEIR Planning Commission Report – December 8, 2021 The EIR examined all potential issue areas including, Aesthetics, Air Quality, Biological Resources, Cultural Resources, Energy, Geology/Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology/Water Quality, Land Use/Pla nning, Noise and Vibration, Public Services, Transportation, Tribal Cultural Resources, Utilities/Service Systems, and Wildfire. The Draft EIR can be found on the LOSSAN CCLF Project webpage: http://www.octa.net/LOSSAN-Rail-Corridor-Agency/Central-Coast-Layover- Facility/#!Resources 2.0 COMMISSION'S PURVIEW The purpose of this public hearing is to provide a forum for discussion of the Draft EIR during the public review period for the document. Both Commission and public testimony at this public meeting should be focused on the content of the Draft EIR, rather than the particular merits of the project itself. The City of San Luis Obispo has limited review authority over the project, and the Planning Commission will not be asked to make a recommendation or take action on the project as the LOSSAN Rail Corridor Agency will act on potential adoption and certification of the Final EIR and any associated CCLF project approvals. 3.0 PREVIOUS PLANNING COMMISSION COMMENTS On March 10, 2021, The Planning Commission held a scoping meeting for LOSSAN to receive public input regarding potentially significant impacts of the project, alternatives, and potential mitigation measures that should be addressed in more detail in the EIR (Attachment C, March 10, 2021, PC meeting minutes). 4.0 PROJECT INFORMATION 4.1 Site Information/Setting The project site is located on approximately 8.3 acres of mostly undeveloped land on the Roundhouse site located in the Railroad Historic District. The proposed project is located south of the existing San Luis Obispo Amtrak St ation and the project site extends from the existing San Luis Obispo Amtrak Station south to Francis Street, and between the Union Pacific Main Tracks and existing commercial and residential development to the west. The southern extent of the project site is located just west of McMillan Avenue. 4.2 Project Description The proposed project includes the construction of a new rail yard, storage and servicing tracks, operations and maintenance buildings, landscape improvements, pedestrian improvements, and safety and security features. Perimeter fencing would be installed around the facility for site security and public safety. Funding is currently not available to construct the entire facility at once. Instead, a phased construction approach is intended, constructing an initial portion of the facility which includes the most immediately needed elements, and adding the remaining components as the need arises and additional funding becomes available. The sections below will provide some details that are known at this stage in the project; the information is subject to change as design work proceeds. Page 12 of 28 Item 5a LOSSAN CCLF DEIR Planning Commission Report – December 8, 2021 Rail Yard and Tracks. The proposed project would construct a new rail yard with up to five new tracks.  Train Wash Track  Service & Inspection (S&I) Track  Storage Track (3) Trains would enter the site from the mainline switch at the north end of the site, passing through the Train Wash. Trains would travel south, passing the train wash building onto the tail track and then reverse direction into either the S&I Track or to one of the other storage tracks. Upon reaching the S&I position or a storage track, the trains would park for the night, connecting to ground power to allow for the electric functions of the train to continue and connecting to a yard air compressor to keep the brake system charged. These connections allow for continuity of these functions without the locomotive engine running, minimizing engine idling within the facility. From the S&I or storage positions, daily servicing and light maintena nce can occur. Trains stored on the S&I track would also undergo additional safety, operational and reliability inspections. Trains would exit the facility north toward the San Luis Obispo station at intervals based on the approved and published service sc hedules. Buildings. The proposed CCLF would consist of a series of single-story structures housing a variety of functions including office space, storage space, workshops, train wash, train S&I and wheel truing. Operations/Fleet Maintenance Building. The Operations Building would be an approximately 3,000 square feet (sf) one-story building, which would house administrative offices and restrooms for operations and maintenance staff. Page 13 of 28 Item 5a LOSSAN CCLF DEIR Planning Commission Report – December 8, 2021 Fleet Maintenance Shops Building. The Fleet Maintenance Shops Building would be a one-story building and approximately 2,900 sf and would house a welding/fabrication shop, brake and coupler shop, and toolbox storage. Parts Storeroom Building. The Parts Storeroom Building would be a one-story building, approximately 1,500 sf, located adjacent to the Fleet Maintenance Shops Building and Maintenance of Way Building. This building would store components and parts that are required on a frequent basis to support maintenance activities, and would include a dedicated secure area for shipping, receiving and storage. Maintenance of Way (MOW) Building. The MOW Building would be a one-story building, approximately 2,200 sf, located adjacent to the Par ts Storeroom Building. MOW is responsible for inspection and maintenance of track, roadbed, and buildings for the facility. MOW is also responsible for inspection and maintenance of non -revenue vehicles assigned to the CCLF. Wash Building. The Wash Building would be a 10,000 sf one-story building, located at the center of the project site, along the Train Wash Track. An automatic, drive -through train wash would be enclosed in the Wash Building. As described above, trains entering the maintenance facility would pass through the Train Wash Building for cleaning prior to being placed on one of the storage tracks or the S&I track. The train wash is anticipated to operate 7 days per week. Each train arriving at the facility at the end of its service day will enter through the wash, requiring it to run for about 5-10 minutes for each train. The timing of the train wash operation will depend on the approved and published service schedule and would likely be during the evening hours. Wheel Truing Building. The Wheel Truing Building would be a one-story building, approximately 1,900 sf in size and located at the north end of the project site adjacent to the San Luis Obispo Railroad Museum parking lot. The Wheel Truing Building would house an underfloor pit-mounted wheel truing machine. Use of this facility is anticipated to be infrequent and not part of the daily operation. S&I Shelter. One of the tracks would function as a storage track with an S&I position. The S&I track would be covered by a 24’ high shelter. To provide access to the underside of a train for inspection and maintenance, a lower-level work area or gauge pit would be installed. Cleaning Shelters. Two cleaning shelters would be provided south of the Wash Building and storage tracks. Parking. The proposed project would provide a total of 54 on -site parking spaces for employees and visitors. Most of the parking spaces would be located on the west end of the central yard in between the Roundhouse Site and Operations building. The other parking spaces would be located adjacent to the MOW Shops building. Page 14 of 28 Item 5a LOSSAN CCLF DEIR Planning Commission Report – December 8, 2021 Access. Primary employee and visitor access to the site would be from Roundhouse Avenue. Additional emergency access to the site would be available from the train museum parking lot (north end of site), from the parking lot off Alphonso Street (center of site), and from Francis Avenue (south end of site). 5.0 CEQA PROCESS AND DRAFT EIR CONCLUSIONS 5.1 CEQA Process Under CEQA, a 45-day public review period of the Draft EIR is required. A Draft EIR was prepared and released to the public on November 5, 2021. This started a 45-day public review period that will end on December 20, 2021. LOSSAN is not required to but has requested the City Planning Commission to serve as a venue to hold a public meeting on the Draft EIR, which allows LOSSAN to hear directly from the Commission and public separate from their consideration of project approval and provides an opportunity for members of the public to learn of the concerns of other people testifying about the project’s environmental impact analysis. Both Commission and public testimony at this public meeting should be focused on the content of the Draft EIR, rather than the particular merits of the project itself. The public meeting represents an opportunity to: 1. Obtain additional information needed to properly evaluate identified issue areas; 2. Identify issue areas that may not be covered in the draft environmental document; and 3. Provide an opportunity for the public to express environmental concerns. 5.2 Draft EIR Contents and Conclusions The Draft EIR concludes that the project will result in no impacts or less than significant impacts in all issue areas and no Class 1 Significant Unavoidable Impacts are identified in the EIR. The Draft EIR finds that mitigation measures are required to reduce impacts to less than significant impacts in the following issue areas:  Air Quality  Biological Resources  Cultural Resources  Geology and Soils  Hazards and Hazardous Materials  Noise  Tribal Cultural Resources Page 15 of 28 Item 5a LOSSAN CCLF DEIR Planning Commission Report – December 8, 2021 6.0 NEXT STEPS LOSSAN and their consultant team will be recording comments of the Commission and public for response in the Final Environmental Impact Report (FEIR ). In addition to the comments of the Commission and public at this public meeting, staff continues to review the DEIR for adequacy, and it is anticipated a detailed City comment letter will be provided prior to the close of public comment on December 20, 2021. The Final EIR will be a compilation of the Draft EIR and responses to comments received regarding the Draft EIR from reviewing agencies, organizations, and individuals. Responses to comments are a written evaluation of comments on the environmental issues received from persons who reviewed the Draft EIR, including comments made at this public workshop. The responses to comments will be prepared by LOSSAN staff and their consultants. LOSSAN will have to certify the Final EIR, which must occur before an action to approve the project can be made. 7.0 ATTACHMENTS A. The Draft EIR is available for review online at the following location: http://www.octa.net/LOSSAN-Rail-Corridor-Agency/Central-Coast-Layover- Facility/#!Resources *Hardcopies are also available for review at the San Luis Obispo Council of Governments Office, 1114 Marsh St., San Luis Obispo. Please call (805) 781-4219 prior to visiting the San Luis Obispo Council of Governments Office. B. Conceptual Project Plans C. Planning Commission Minutes of March 10, 2021 Page 16 of 28 Parking Summary Non-Revenue EmployeeNisitor Accessible Parking Motorcycle Parking 2 44 2 2 Visitor Parking 2 Clean Air/Electric Vehicle Parking 2 Department Legend perations leet Maintenance leet Maintenance Shop & Bay Areas ard and SeNice Bay Page 17 of 28 Page 18 of 28 City ofSan Luis Obispo, Council Agenda, City Hall, 990 Palm Street, San Luis Obispo Minutes - Draft Planning Commission Minutes Planning Commission Regular Meeting Wednesday, March 10, 2021 CALL TO ORDER A Regular Meeting of the San Luis Obispo Planning Commission was called to order on Wednesday, March 10, 2021 at 6:04 p.m., via teleconference, by Chair Hemalata Dandekar. ROLL CALL Present: Commissioners Michael Hopkins, Steve Kahn, Nicholas Quincey, Michelle Shoresman, Mike Wulkan, Vice-Chair Robert Jorgensen, and Chair Hemalata Dandekar Absent: None Staff: Community Development Director Michael Codron, Deputy Community Development Director Tyler Corey, Assistant City Attorney Markie Jorgensen, and Deputy City Clerk Kevin Christian PUBLIC COMMENTS ON ITEMS NOT ON THE AGENDA None 1. CONSENT AGENDA – CONSIDERATION OF MINUTES ACTION: MOTION BY COMMISSIONER QUINCEY, SECOND BY COMMISSIONER WULKAN, CARRIED 7-0-0 to approve the Planning Commission Minutes of February 24, 2021. Page 19 of 28 Planning Commission Meeting Minutes March 10, 2021 Page 2 of 5 PUBLIC HEARING 2. Public scoping meeting to discuss the scope of the Environmental Impact Report (EIR) being prepared for the Los Angeles – San Diego - San Luis Obispo (LOSSAN) Rail Corridor Agency, Central Coast Layover Facility (CCLF). The project site is located on approximately 8.3 acres of mostly vacant land area between the area west of the Union Pacific (UP) Main Tracks and areas east of the Roundhouse St. terminus (Roundhouse site). The southern extent of the project area is east of Francis Avenue and terminates in the area north of McMillan Avenue west of the UP tracks. The project consists of the construction of a new rail yard, storage and servicing tracks, operations and maintenance buildings, landscape improvements, and pedestrian improvements. Address: 1320 Roundhouse Street; Zoning: Service- Commercial with Special Considerations and Historic Overlay (C-S-S-H); LEAD AGENCY: LOSSAN Rail Corridor Agency. Senior Planner Brian Leveille presented the staff report and Active Transportation Manager, Adam Fukushima, reviewed active transportation facilities that exist or are planned for in the general project area. LOSSAN representatives, James Campbell, Manager of Programs / Project Manager, Dan Phu, Environmental Program Manager, Scott Gaastra, Design Project Manager, and Tim Gnibus, EIR Project Manager, presented an overview of the project and provided responses to questions raised by the Commission. Chair Dandekar opened the public hearing. Public Comment: Jackie Mansoor, APCD, noted concerns of diesel particulate matter effects on nearby residents. Noted is was important to understand management and policies of engine idling and welding operations. Polluting sources should be located as far away as possible from residents. Elizabeth Aloe, resident at Roundhouse Place Apartments had questions on phasing of project, concerns of noise throughout construction, and after with trains idling; concerns of crime, traffic impacts, loss of on street parking on Roundhouse, lighting impacts on residential apartments in the area and projects under construction. Daniel Kallal, noted that although the project is in the Railroad District Plan, there are also nearby properties in the Broad Street corridor plan and aesthetics should be evaluated. Also, noted safety concerns should be evaluated and the Railroad Safety Trail between the facility and apartments will likely enhance safety over the current situation. Pete Rodgers, Director of SLOCOG emphasized support for the project and discussed rail operations as a part of the City’s past and this sites past. Stated the facility will allow ability to implement State Rail Plan and expand operations north and south and rail is consistent with efforts to reduce GHG’ Page 20 of 28 Planning Commission Meeting Minutes March 10, 2021 Page 3 of 5 Jonathan Roberts, Chair of Active Transportation Committee, noted concerns over negative effect the project may have for GHG reduction goals and indicated support for completion of the Railroad Safety trail on the west side of the tracks. Armen Grewal, noted past fires on the property and noted need to consider bridge crossings and had a question on the proper contact for LOSSAN. Glenn Matteson, San Luis Obispo Railroad Museum, noted appreciation for info provided by LOSSAN and HDR staff. He noted security fencing may cause access issues for museum staff which is needed for maintenance of display track and rail cars. He noted the project would reestablish operations at a lower level than had already been there historically for a long period of time. Chair Dandekar closed the public hearing. ACTION: By consensus, the Commission requested staff to agendize an item on a future meeting for the Commission to provide comments on the Draft Environmental Impact Report DEIR) for the project, and requested the LOSSAN Rail Corridor Agency consider comments raised by the public and Commission comments as summarized below in preparation of the Draft EIR: Fencing impact to the Railroad Museum operations Night noise and lighting due to facility operation Pedestrian and bicycling connections through and adjacent to the project, including planned grade separated crossings both south and north of the project Visual impact of building design, height, etc., on neighborhood Railroad District design vernacular Air pollution impacts from train idling and facility operations (welding, etc.) Safety and crime impact to local residents Preservation of historic roundhouse remnants and visibility/use by citizens Project description should be more specific to adequately perform the EIR. o Hours of operation for activities o Building placement and use o Design of buildings included in project description o Phasing of building Evaluate consistency with existing City plans, guidelines, laws: o Railroad Historic Area Plan o Historic Preservation ordinance o Circulation element, specifically the grade separated crossing at Roundhouse Ave. o Broad Street Corridor Plan Security fencing impact to the current informal access to the area How engine idling will be managed – diesel particulate matter impact to local residents Neighborhood noise and traffic during construction and increased ongoing operational traffic The Commission recessed at 7:55 and resumed with all Commissioners present at 8:05. Page 21 of 28 Planning Commission Meeting Minutes March 10, 2021 Page 4 of 5 3. Review of a mixed-use project consisting of 9 residential units and approximately 10,400 square feet of commercial space, as a part of the Jones Subdivision Tract No. 3066. The project includes a request for a 40 percent parking reduction for the commercial use. The project is consistent with the previously adopted Mitigated Negative Declaration for SBDV-0067-2014 Tract No. 3066), City Council Resolution No. 10620 (2015 Series); Project address: 3806 Ranch House; Case #: ARCH-0256-2020; Zone: C-C-MU; Travis Fuentez, owner/applicant. Commissioner Hopkins recused himself and left prior to staff presentation of the item. Associate Planner Kyle Bell presented the staff report and responded to Commission inquiries. Applicant representative, Scott Martin, Principal Architect, RRM Design Group, provided an overview of the project. Chair Dandekar opened the public hearing. Public Comment: None Chair Dandekar closed the public hearing. ACTION: MOTION BY COMMISSIONER KAHN, SECOND BY VICE CHAIR JORGENSEN, CARRIED 6-0-1 (COMMISSIONER HOPKINS RECUSED) to adopt a Resolution entitled, A RESOLUTION OF THE SAN LUIS OBISPO PLANNING COMMISSION APPROVING THE DEVELOPMENT OF A MIXED-USE PROJECT WITHIN THE JONES SUBDIVISION TRACT NO. 3066, CONSISTING OF NINE (9) MODERATE- INCOME AFFORDABLE RESIDENTIAL UNITS, APPROXIMATELY 10,400 SQUARE FEET OF COMMERCIAL SPACE, WITH A 40 PERCENT PARKING REDUCTION FOR THE COMMERCIAL USES, AND A FINDING OF CONSISTENCY WITH PREVIOUSLY ADOPTED MITIGATED NEGATIVE DECLARATION ER137-11, CITY COUNCIL RESOLUTION NO 10620 (2015 SERIES), AS REPRESENTED IN THE STAFF REPORT AND ATTACHMENTS DATED MARCH 10, 2021 (3806 RANCH HOUSE ROAD, ARCH-0256-2020) with the following modification to Condition #9: inverted “U” rack designs shall not be permitted). Long term bicycle parking spaces shall provide charging capability for ebikes and shall provide a variety of floor and wall mounted racks to accommodate bicycles that vary in size, shape and weight. Sufficient detail shall be provided about placement and design...” Page 22 of 28 Planning Commission Meeting Minutes March 10, 2021 Page 5 of 5 Commissioner Hopkins returned to the meeting following recusal for this item. 4. Presentation of the General Plan Annual Report; Project Address: Citywide. Assistant Planner Graham Bultema presented the staff report and responded to Commission inquiries, with input from Deputy Community Development Director Tyler Corey and Community Development Director Michael Codron. Chair Dandekar opened the public hearing. Public Comment: None Chair Dandekar closed the public hearing. ACTION: By consensus, the Commission agreed to receive and file the General Plan Annual Report for 2020, with the following comments to be forwarded to City Council: Prioritize inclusionary housing Residential growth management table – add footnote to clarify unit counts include exclusions (ADUs; affordable units; downtown units) Make a few minor corrections regarding the Orcutt Area Specific Plan section COMMENT AND DISCUSSION 5. Agenda Forecast – Deputy Community Development Director Tyler Corey provided an update of upcoming projects. ADJOURNMENT The meeting was adjourned at 9:54 p.m. The next Regular Meeting of the Planning Commission meeting is scheduled for Wednesday, March 24, 2021, at 6:00 p.m., via teleconference. APPROVED BY THE PLANNING COMMISSION: 03/24/2021 Page 23 of 28 Page 24 of 28 LOSSAN Representative presentation  12/08/2021 1 Central Coast Layover Facility Project Public Workshop for a Draft Environmental Impact Report December 8, 2021 Purpose of the Public Workshop 1 2 LOSSAN Representative presentation  12/08/2021 2 Public Workshop Agenda Project Overview Overview of the Draft EIR The EIR Process Draft EIR Issues and Conclusions Public Comments on the Draft EIR Next Steps Project Site and Location 3 4 LOSSAN Representative presentation  12/08/2021 3 Project Overview & Components Wheel Truing Roundhouse Protected Zone Tanks/Pumps Backup Generator Wash Building Maint./Ops Buildings Cleaning Shelters Non-Railroad Features / Future Elements Bike / Ped Path Fence Protection between Bike Path and Project Site Possible Future Bike / Ped Bridge Locations Francis St5 6 LOSSAN Representative presentation  12/08/2021 4 Initial Phase Built-out Phase PRIMARY ACCESS Project Phasing MAINLINE TRACKS CEQA / EIR Overview The California Environmental Quality Act (CEQA) is the State’s primary environmental protection law CEQA requires public agencies to disclose environmental impacts of projects that have a physical effect on the environment An EIR is an informational document that: Discloses project effects on environment Identifies mitigation measures Describes feasible project alternatives An EIR must be certified prior to project approval 7 8 LOSSAN Representative presentation  12/08/2021 5 Notice of Preparation Draft EIR Issue Notice of Completio n/ Public Notice of Availability Public Review Period/ Public Meeting (45 days) Final EIR and Response to Comments Decision on Project File Notice of Determ- inationThe EIR Process Current Phase Opportunity for Public Input Issues Analyzed in the Draft EIR Air Quality Biological Resources Cultural Resources Geology and Soils Hazards and Hazardous Materials Noise Tribal Cultural Resources Aesthetics Energy Greenhouse Gas Emissions Hydrology and Water Quality Land Use and Planning Transportation Utilities and Service Systems Less than Significant WITH MITIGATION Less than Significant (No Mitigation) NOTE: No Significant or unavoidable impacts were identified in the Draft EIR 9 10 LOSSAN Representative presentation  12/08/2021 6 Key Mitigations Air Quality Mitigation Impact 3.3-3: Valley Fever and Asbestos Construction Valley Fever Plan Naturally Occurring Asbestos Air Toxics Control Measure Compliance Noise Mitigation Impact 3.12-1: Generation of Ambient Noise Noise Reducing Measures During Construction Community Notification Plan for Construction Operational Restrictions Key Mitigations Hazards and Hazardous Materials Mitigation Impact 3.9-3: Emissions in Proximity to Schools Cultural Resources Mitigation Impact 3.5-1: Historical Resources Public Outreach and Educational Display 11 12 LOSSAN Representative presentation  12/08/2021 7 Project Alternatives CEQA requires a “reasonable range” of alternatives Intended to address impacts identified in the EIR Must generally meet project objectives Intended primarily to show conceptual ways to address possible impacts -- not for consideration as possible options for project approval Alternatives to Proposed Project addressed in the Draft EIR Alternative 1: No Project/No Development Alternative Alternative 2: Expand Existing Facility Alternative 3: Islay Hill Site Alternative 4: California State Polytechnic University San Luis Obispo Site Next Steps 45-day public comment period on Draft EIR ends December 20, 2021 The Final EIR will be prepared and respond to public comments The LOSSAN Board of Directors will consider Final EIR contents as they consider project approval 13 14 LOSSAN Representative presentation  12/08/2021 8 How to Submit Your Comments on the Draft EIR Submit Comments by 5 PM on December 20, 2021 How to Submit Comments: Write a letter and address it to: Attn: James Campbell, Operations Officer LOSSAN Rail Corridor Agency 600 South Main Street Orange, CA 92863 Via email to: capitalprojects@lossan.org. Please include “Central Coast Layover Facility” or “(CCLF)” in the email subject line Questions & Comments 15 16