HomeMy WebLinkAbout3.2_AgriculturalResources_FroomRanch_DEIR3.2 AGRICULTURAL RESOURCES
3.2 AGRICULTURAL RESOURCES
This section describes agricultural resources
and evaluates the potential impacts of the
Project on site-specific and regional agricultural
resources. Agricultural resources consist of any
farmland with potential for agricultural
productivity based on soil and farmland
characteristics. Prime soils are superior or
unique soils as identified by the U.S.
Department of Agriculture (USDA) Natural
Resources Conservation Service (NRCS). As
identified by the State of California, Important
Farmlands contain soils best suited for
producing food and forage, particularly for
producing high-yield crops as defined by the California Department of Conservation’s
Farmland Mapping and Monitoring Program (FMMP). The FMMP classifies Important
Farmland based on agricultural soil quality and current land use into four categories of
important farmlands: Prime Farmland, Farmland of Statewide Importance, Unique
Farmland, and Farmland of Local Importance.1
Other important agricultural land may be defined and protected by agricultural zoning or
Williamson Act contracts to prevent conversion to non-agricultural use. A Williamson Act
contract is an agreement between private landowners and the government to restrict
specific parcels of land to agricultural or related open space uses in return for reduced
property tax assessments (see also, Section 3.2.2, Regulatory Setting). Further, agricultural
resources can include non-irrigated grazing lands where the prevalence of steep slopes, less
fertile soils, and lack of irrigation source may limit their use for cultivation or other
agricultural product production.
3.2.1 Environmental Setting
3.2.1.1 Regional Setting
Agricultural activity in the region includes mainly rotational row crops, vineyards in level
or gently sloping areas, and livestock grazing in foothill areas. Agriculture is a major
1 The FMMP also assesses the location, quality, and quantity of agricultural lands and monitors the
conversion of these lands to non-agricultural uses.
The Project site contains a 7.1-acre open
space and agricultural conservation
easement and supports soils classified as
prime, if irrigated, by the Natural Resources
Conservation Service (NRCS). See page 3.2-
12 for further discussion.
Froom Ranch Specific Plan 3.2-1
Draft EIR
3.2 AGRICULTURAL RESOURCES
production industry in the County with a gross production value of $1.035 billion in 2018.
Top crops by value in 2018 included: wine grapes ($276 million), strawberries ($268
million), broccoli ($48 million), avocados ($46 million), cattle and calves ($43 million),
vegetable transplants ($35 million), cauliflower ($30 million), cut flowers ($26 million),
head lettuce ($25 million), and lemons ($24 million) (County of San Luis Obispo 2019).
Agricultural production generates both direct revenues and indirect value through job
creation and economic output in other sectors of the local economy, including tourism,
industrial, retail, and commercial services.
Agricultural areas within the City limits are primarily located northeast of the Project site,
within a large swath of cultivated land adjacent to U.S. 101 (commonly known as Dalidio
Ranch or San Luis Ranch); however, a Specific Plan and proposed development on this
site has been recently approved and is under construction. Following development of the
San Luis Ranch project, 52.7 acres of the existing 131-acre site would remain as
agricultural land (refer also to Section 3.2.3.4, Cumulative Impacts). Additional
agricultural lands in the Project vicinity are located to the southeast in unincorporated areas
of the County, adjacent to the City limit. Several unincorporated parcels southeast of the
City are also subject to Williamson Act contracts. These agricultural lands generally
support rotational row crops, oat fields, and vineyards (City of San Luis Obispo 2014).
There are no lands in active agricultural production or lands under a Williamson Act
contract immediately adjacent to the Project site.
3.2.1.2 Project Site
Farmland within the Project Site
The Specific Plan area is currently used for
grazing horses. Historically, the Specific Plan area
has been used for grazing operations associated
with the former Froom Ranch Dairy since at least
1844 (Appendix F). The proposed stormwater
detention basin area is undeveloped and there is no
record of agricultural operations on this portion of
the Project site.
According to the FMMP, the Project site contains
approximately 67.6 acres of Farmland of Local
Potential, which are lands having prime or
The Project site has historically been used
for grazing, currently for horses. Portions
of the site are also identified as Farmland
of Local Potential by the FMMP. While
the site formerly served as grazing for the
historic Froom Ranch Dairy, there is no
record of cultivation on the site.
3.2-2 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
statewide farmland characteristics, but that are not cultivated; 46.2 acres of grazing land;
and 2.3 acres of other and urban/built-up land (California Department of Conservation
2016; Figure 3.2-1 and Table 3.2-1). There is no Prime Farmland, Farmland of Statewide
Importance, Unique Farmland, or Farmland of Local Importance within the Project site.
The Project site is not under a Williamson Act contract.
Figure 3.2-1. Agricultural Resource within the Project Site
Table 3.2-1. Project Site FMMP Resources
FMMP Designation
Specific
Plan Area
(acres)
Proposed
Stormwater
Detention
Basin Area
(acres)
Project Site
(Total) Percentage1
Farmland of Local Potential 62.4 5.2 67.6 58.3%
Grazing 44.5 1.7 46.2 39.8%
Urban/Built-Up and Other 2.2 0.1 2.3 2.0%
1Totals do not add to 100 percent due to rounding.
Agricultural Soils within the Project Site
The NRCS assesses the potential agricultural productivity and limitations of different soils
by utilizing both the land capability classification (LCC) system (described in the National
Froom Ranch Specific Plan 3.2-3
Draft EIR
3.2 AGRICULTURAL RESOURCES
Soil Survey Handbook Part 622.02) and the Important Farmland Inventory (pursuant to
requirements of Code of Federal Regulations [CFR] Chapter 7 Part 657). The LCC
indicates the suitability of soils for most kinds of crops, where groupings are made
according to the limitations of the soils when used to grow crops, and the risk of damage
to soils when they are used in agriculture. Soils are rated from Class I to Class VIII, with
soils having the fewest limitations receiving the highest rating (Class I). The system is
subdivided into capability class and capability sub-class. LCC sub-classes are utilized to
further characterize soils within a specific class by designating the main hazard by which
a particular soil is limited by reference to a letter, including: erosion (e); water (w); shallow,
droughty, or stony (s); and very cold or very dry (c). Class I soils have no sub-classes
because soils of this type have few limitations (California Department of Conservation
1997). The NRCS identifies prime soils as those with an LCC of Class I or II. Many soils
are assigned Class I or II only when irrigated, but otherwise receive a lower rating without
irrigation.
Soils at the Project site consist of approximately 47.6 acres of prime agricultural soils if
irrigated, and approximately 67.2 acres of non-prime soils based on NRCS soil
classifications. The prime if irrigated agricultural soils consists of Cropley clay and Salinas
silty clay loam (NRCS 2018; see Tables 3.2-2 and 3.2-3, and Figure 3.2-2). Cropley clay
is a very deep, moderately well-drained, nearly level soil with slow permeability and slow
surface runoff. The hazard of water erosion is slight, and the shrink swell potential of this
soil is high. This soil is suited for vegetable crops, dryland farming, and pasture. If used
for urban development, foundations and footings should be designed to compensate for the
high shrink swell potential and low strength. Cropley clay constitutes approximately 43.9
acres of the Project site and is rated with an LCC of Class IIs with irrigation and Class IIIs
without irrigation. Salinas silty clay loam constitutes approximately 3.7 acres of the Project
within the proposed stormwater detention basin area and is rated with an LCC of Class I
with irrigation and Class IIIc without irrigation. Per NRCS designations, these soils are
considered Prime Farmland if irrigated.
3.2-4 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
Table 3.2-2. Specific Plan Area Soil Capabilities
Map
Symbol Soil Name Acreages in
Project Site
Class Important
Farmland
Designation1
Slope % Surface
Runoff IR NI
127 Cropley clay 43.8 (40.3%) IIs IIIs Prime (if
irrigated) 0 to 2 Medium
130 Diablo and Cibo
clays 16.0 (14.7%) IIIe IIIe Non-prime 9 to 15 Very high
131 Diablo and Cibo
clays 7.3 (6.7%) IVe IVe Non-prime 15 to 30 Very high
162 Los Osos – Diablo
complex 1.8 (1.6%) IIIe IIIe Non-prime 5 to 9 Very high
164 Los Osos – Diablo
complex 14.5 (13.3%) VIe VIe Non-prime 15 to 30 Very high
183 Obispo – Rock
outcrop complex 21.8 (20.0%) VIIe VIIe Non-prime 15 to 75 Very high
221
Xerets – Xerolls –
Urban land
complex
0.7 (0.6%) VIII VIII Non-prime 0 to 15 Very high
300 Corducci – Typic
Xerofluvents 2.9 (2.7%) N/A VIe Non-prime 0 to 5 Very low
Notes: IR = irrigated; NI = non-irrigated.
1 NRCS criteria for prime soils is the same as that used for the Farmland Protection Policy Act, which is dependent on
site-specific irrigation and drainage; however, it is noted that prime soils under Williamson Act criteria only considers
soils with Class I or II capabilities as prime (NCRS 2016).
Source: NRCS 2018.
Table 3.2-3. Proposed Stormwater Detention Basin Area Soil Capabilities
Map
Symbol Soil Name
Acreages
in Project
Site
Class Important
Farmland
Designation1
Slope % Surface
Runoff
Irrigation
Limitation IR NI
127 Cropley clay 0.1 (1.8%) IIs IIIs Prime (if
irrigated) 0 to 2 Medium Water
availability
197 Salinas silty
clay loam
3.7
(62.2%) I IIIc Prime (if
irrigated) 0 to 2 Negligible Water
availability
221
Xerets –
Xerolls –
Urban land
complex
2.2
(36.0%) VIII VIII Non-prime 0 to 15 Very high
Water
availability /
well drained
Notes: IR = irrigated; NI = non-irrigated.
1 NRCS criteria for prime soils is the same as that used for the Farmland Protection Policy Act, which is dependent on
site-specific irrigation and drainage; however, it is noted that prime soils under Williamson Act criteria only considers
soils with Class I or II capabilities as prime (NCRS 2016).
Source: NRCS 2018.
Froom Ranch Specific Plan 3.2-5
Draft EIR
3.2 AGRICULTURAL RESOURCES
The Cropley clay soils in the Specific Plan area and proposed stormwater detention basin
area, in addition to the Salinas silty clay loam soils of the proposed stormwater detention
basin area, are not currently nor historically irrigated, nor have they been historically
utilized for crop cultivation. However, an agricultural well exists at the Project site, which
could provide a reliable source of water for irrigating these soils. As such, the Cropley clay
and Salinas silty clay loam soils are conservatively considered to be prime soils.
Figure 3.2-2. Agricultural Soils within the Project Site
3.2.2 Regulatory Setting
Agricultural resources are governed primarily by local jurisdictions, consistent with state
law. Regulations that are directly relevant to the Project are summarized below.
3.2.2.1 State
Department of Conservation Farmland Mapping and Monitoring Program (FMMP)
The California Department of Conservation established the FMMP in 1982 to assess the
location, quality, and quantity of agricultural lands and analyze the conversion of these
lands throughout California. Public Resources Code (PRC) Section 21060.1 defines
agricultural land for the purposes of assessing environmental impacts under the FMMP.
3.2-6 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
The list below provides a description of all categories mapped by the California
Department of Conservation (California Department of Conservation 2016):
• Prime Farmland. Farmland that has the best combination of physical and chemical
features and is able to sustain long-term agricultural production. This land has the
soil quality, growing season, and moisture supply needed to sustain high yields.
Land must have been used for irrigated agricultural production at some time during
the four years prior to the mapping date.
• Farmland of Statewide Importance. Farmland similar to Prime Farmland but
with minor shortcomings, such as greater slopes or less ability to store soil moisture.
Land must have been used for irrigated agricultural production at some time during
the four years prior to the mapping date.
• Farmland of Local Importance and Local Potential. Farmland of importance to
the local agricultural economy as determined by each county’s board of supervisors
and a local advisory committee. Farmland of Local Importance is either currently
producing crops, has the capability of production, or is used for the production of
confined livestock. Farmland of Local Importance is land other than Prime
Farmland, Farmland of Statewide Importance or Unique Farmland. In the County,
the local advisory committee has elected to additionally define areas of Local
Potential, which include soils that qualify for Prime Farmland or Farmland of
Statewide Importance, but generally are not cultivated or irrigated. For FMMP
reporting purposes, Local Potential and Farmland of Local Importance are
combined in the acreage tables, but are shown separately on the Important Farmland
Map.
• Grazing Land. Land on which the existing vegetation is suited to the grazing of
livestock. It also does not include heavily brushed, timbered, excessively steep, or
rocky lands that restrict the access and movement of livestock, rural residential
land, or publicly owned lands for which there is an adopted policy preventing
agricultural use.
• Urban and Built-up Land. Land occupied by structures with a building density of
at least 1 unit to 1.5 acres, or about six structures to a 10-acre parcel. This land is
used for residential, industrial, commercial, institutional, and public administrative
purposes; railroad and other transportation yards; cemeteries; airports; golf courses;
sanitary landfills; sewage treatment facilities; water control structures; and other
developed purposes.
• Other Land. Land not included in any other mapping category. Common examples
include low-density rural developments; brush, timber, wetland, and riparian areas
not suitable for livestock grazing; confined livestock, poultry, or aquaculture
facilities; strip mines and borrow pits; and water bodies smaller than 40 acres.
Vacant and non-agricultural land surrounded on all sides by urban development and
greater than 40 acres is mapped as Other Land.
Froom Ranch Specific Plan 3.2-7
Draft EIR
3.2 AGRICULTURAL RESOURCES
California Land Conservation Act of 1965 (Williamson Act)
The California Land Conservation Act of 1965, commonly referred to as the Williamson
Act, is located in California Government Code Section 51200-51297.4. The Williamson
Act enables local governments to enter into contracts with private landowners for the
purpose of restricting specific parcels of land to agricultural or related open space uses in
return for reduced property tax assessments. Specifically, this legislation enables
landowners who voluntarily agree to participate in the Williamson Act program, to receive
assessed property taxes per the income-producing value of their property in agricultural
use, rather than on the property’s assessed market value. Section 51238.1 allows a board
or council to deem compatible any use, without conditions or mitigation that would
otherwise be considered incompatible. However, this may occur only if that use meets the
following conditions:
• The use will not significantly compromise the long-term productive agricultural
capability of the subject contracted parcel or parcels on other contracted lands in
agricultural preserves.
• The use will not significantly displace or impair current or reasonably foreseeable
agricultural operations on the subject contracted parcel or parcels on other
contracted lands in agricultural preserves. Uses that significantly displace
agricultural operations on the subject contracted parcel or parcels may be deemed
compatible if they relate directly to the production of commercial agricultural
products on the subject contracted parcel or parcels or neighboring lands, including
activities such as harvesting, processing, or shipping.
• The use will not result in the significant removal of adjacent contracted land from
agricultural or open space use.
3.2.2.2 Local
City of San Luis Obispo General Plan
Land Use Element (LUE)
The City’s adopted General Plan LUE outlines multiple policies designed to protect
agricultural resources and prime agricultural land. The City’s General Plan sets forth
specific requirements for the Project vicinity and Project site, as well as overall
requirements for protection of agricultural land and required mitigation standards for loss
of agricultural land. Policies relevant to the Project are listed below:
3.2-8 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
Policy 1.7.3 Interim Uses. Expansion areas should be kept in agriculture, compatible with
agricultural support services, or open space uses until urban development occurs, unless a
City-approved specific plan provides for other interim uses.
Policy 1.8.1 Open Space Protection. Within the City's planning area and outside the urban
reserve line, undeveloped land should be kept open. Prime agricultural land, productive
agricultural land, and potentially productive agricultural land shall be protected for
farming. Scenic lands, sensitive wildlife habitat, and undeveloped prime agricultural land
shall be permanently protected as open space.
Policy 1.9.2 Prime Agricultural Land. The City may allow development on prime
agricultural land if the development contributes to the protection of agricultural land in the
urban reserve or greenbelt by one or more of the following methods, or an equally effective
method: acting as a receiver site for transfer of development credit from prime agricultural
land of equal quantity; securing for the City or for a suitable land conservation organization
open space or agricultural easements or fee ownership with deed restrictions; helping to
directly fund the acquisition of fee ownership or open space easements by the City or a
suitable land conservation organization. Development of small parcels which are
essentially surrounded by urbanization need not contribute to agricultural land protection.
Conservation and Open Space Element (COSE)
The City’s adopted General Plan COSE also contains policies designed to protect
agricultural resources and prime agricultural land, as well as offset the development of
agricultural areas. Policies relevant to the Project are listed below:
Policy 8.6.3 Required Mitigation. Loss or harm shall be mitigated to the maximum extent
feasible. Mitigation must at least comply with federal and state requirements. Mitigation
shall be implemented and monitored in compliance with state and federal requirements, by
qualified professionals, and shall be funded by the project applicant.
C. For a widespread habitat type or for farmland, mitigation shall consist of
permanently protecting an equal area of equal quality, which does not already have
permanent protection, within the San Luis Obispo Planning Area.
G. Any development that is allowed on a site designated as Open Space or Agriculture,
or containing open space resources, shall be designed to minimize its impacts on
open space values on the site and on neighboring land.
Froom Ranch Specific Plan 3.2-9
Draft EIR
3.2 AGRICULTURAL RESOURCES
1. Hillside development shall comply with the standards of the Land Use
Element, including minimization of grading for structures and access, and
use of building forms, colors, and landscaping that are not visually intrusive.
2. Creek corridors, wetlands, grassland communities, other valuable habitat
areas, archaeological resources, agricultural land, and necessary buffers
should be within their own parcel, rather than divided among newly created
parcels. Where creation of a separate parcel is not practical, the resources
shall be within an easement. The easement must clearly establish allowed
uses and maintenance responsibilities in furtherance of resource protection.
3. The City will encourage the County not to create new parcels within the
greenbelt, with the exception of those permitted under the County’s
agriculture cluster incentive. Outside of cluster districts, allowed parcel
sizes within the greenbelt should be no smaller, and the number of dwellings
allowed on a parcel should be no greater than as designated in the September
2002 San Luis Obispo Area Plan and related County codes.
4. The City will encourage the County to adopt and implement a mandatory
cluster district for appropriate areas of the greenbelt under County
jurisdiction to preserve open space qualities, consistent with the
Conservation and Open Space Element. The City will encourage other
agencies to follow these policies.
County of San Luis Obispo General Plan
The County’s General Plan guides land use and planning in unincorporated areas and the
Agriculture Element of the County’s General Plan addresses agricultural resources
specifically. As the Project site is currently unincorporated, the County’s General Plan
currently applies and may be relevant when considering onsite, adjacent, or nearby
agricultural resources.
Agriculture Element
Goal AG-2 – Conserve agricultural resources.
a. Maintain the agricultural land base of the county by clearly defining and identifying
productive agricultural lands for long-term protection.
b. Conserve the soil and water that are the vital components necessary for a successful
agricultural industry in this county.
3.2-10 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
c. Establish land-use policies in this element that support the needs of agriculture
without impeding its long-term viability.
Goal AG-3 – Protect agricultural lands.
a. Establish criteria in this element for agricultural land divisions that will promote
the long-term viability of agriculture.
b. Maintain and protect agricultural lands from inappropriate conversion to non-
agricultural uses. Establish criteria in this element and corresponding changes in
the Land Use Element and Land Use Ordinance for when it is appropriate to convert
land from agricultural to non-agricultural designations.
c. Maintain and strengthen the county’s agricultural preserve program (Williamson
Act) as an effective means for long-term agricultural land preservation.
d. Provide incentives for landowners to maintain land in productive agricultural uses.
Policy AGP17: Agricultural Buffers – Protect land designated Agriculture and other lands
in production agriculture by using natural or man-made buffers where adjacent to non-
agricultural land uses.
San Luis Obispo County Local Agency Formation Commission (LAFCO)
The San Luis Obispo County Local Agency Formation Commission (LAFCO) considers
annexations to cities and special districts, and, as such, would review the Project’s
proposed annexation to the City. LAFCO considers the impact that a proposal may have
on existing agricultural lands with focus on protecting prime agricultural lands. LAFCO
has adopted specific policies regarding the preservation of agricultural resources.
2.9.12 Agricultural Policies. The Commission may approve annexations of prime
agricultural land only if mitigation that equates to a substitution ratio of at least 1:1 for the
prime land to be converted from agricultural use is agreed to by the applicant (landowner),
the jurisdiction with land use authority. The 1:1 substitution ratio may be met by
implementing various measures:
a. Acquisition and dedication of farmland, development rights, and/or agricultural
conservation easements to permanently protect farmlands within the annexation
area or lands with similar characteristics within the County Planning Area.
Froom Ranch Specific Plan 3.2-11
Draft EIR
3.2 AGRICULTURAL RESOURCES
b. Payment of in-lieu fees to an established, qualified, mitigation/conservation
program or organization sufficient to fully fund the acquisition and dedication
activities stated above in 12a.
c. Other measures agreed to by the applicant and the land use jurisdiction that meet
the intent of replacing prime agricultural land at a 1:1 ratio.
2010 Open Space and Agricultural Conservation Easement Agreement
In 2010, as part of the annexation and development of the Prefumo Creek Commons project
located across LOVR from the Project site, an open space and agricultural conservation
easement was established over a 7.1-acre portion of the Project site to satisfy LAFCO
Policy 2.9.12, Agricultural Policies (refer to Figure 2-2). The land within the easement was
found suitable to meet the LAFCO criteria for dedication for the Prefumo Creek Commons
project impacts, as it contains the same type of soils; however, the area was never
cultivated, and now overlays a delineated wetland area, as described in Section 3.4,
Biological Resources. The open space and agricultural conservation easement is intended
to allow the continuation of prior historical agricultural activities on the property, including
grazing and agricultural production, and otherwise restricts the use of the land from
development that would not support agricultural production. Additionally, the easement
agreement states that the area may be used for wetland and biological resource mitigation
banking (e.g., the restoration, creation, enhancement, and/or preservation of wetlands
and/or biological resources) for the purpose of providing compensation mitigation as a
result of impacts to similar resources. The easement is managed by the City and may be
amended with written consent of both Irish Hills Plaza, LLC and the City; LAFCO would
review any proposed amendment to confirm it is in conformance with the conditions of the
easement agreement.
3.2.3 Environmental Impact Analysis
3.2.3.1 Thresholds of Significance
With respect to agricultural resources, applicable sections of Appendix G of the CEQA
Guidelines state that a project would normally have a significant impact on the environment
if it would:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance
(Farmland), as shown on the maps prepared pursuant to the FMMP of the California
Resources Agency, to non-agricultural use;
3.2-12 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
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
PRC Section 12220(g)), timberland (as defined by PRC 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 individually or cumulatively result in the conversion of farmland to
non-agricultural use.
Non-Applicable Thresholds
• Threshold (c) (Zoning for Forest Land, Timberland, or Timberland Production):
The Project site does not contain zoning for forest land, timberland, or timberland
zoned Timberland Production, nor does it propose the rezoning of any of these
areas. As such, there would be no potentially significant adverse impacts related to
forest- and timberland-related resources and this issue will not be analyzed further
in this EIR.
• Threshold (d) (Forest Land Conversion): The Project site does not contain any
forest land. As such, there would be no potentially significant adverse impacts
related to the loss or conversion of forest land with implementation of the Project
and this issue will not be analyzed further in this EIR.
3.2.3.2 Impact Assessment Methodology
Data for this analysis was derived from the review of the City’s General Plan LUCE Update
EIR (2014); General Plan COSE (2006); NRCS soil maps; and the FMMP San Luis Obispo
Important Farmland Map (2016). Potential impacts to agricultural resources are associated
with the conversion of open space lands used for grazing to urban development, including
39.1 acres of residential and 3.1 acres of retail commercial land uses, as further described
below. Though the Project site is currently unincorporated land under the jurisdiction of
the County, the City’s LUCE Update EIR and General Plan have planned for the
annexation of the site. The potential for impacts to agricultural resources are therefore
evaluated in the context of City resources and agricultural conservation policies. The
LUCE Update EIR analyzed the potential for planned development of the Specific Plan
area to convert agricultural resources to developed urban uses, and concluded that impacts
would be less than significant with the incorporation of program-level mitigation measures
and application of LUCE policies, which require conservation of comparable agricultural
Froom Ranch Specific Plan 3.2-13
Draft EIR
3.2 AGRICULTURAL RESOURCES
resources within the San Luis Obispo Planning Area. Such policies include the dedication
of offsite agricultural lands or payment of in-lieu fees to ensure that such land is conserved.
In addition, the analysis below also considers the physical loss of agricultural resources
and prime if irrigated soils.
The analysis for agricultural resources uses Land Evaluation and Site Assessment (LESA)
methodology to determine the potential for significance of impacts, which are assessed in
this section below. LESA Model estimates for the Project site are contained within
Appendix L of this EIR. The following methods were also used to determine the extent
and/or significance of the Project’s impact on agricultural resources:
a) Identify any onsite land classified by the FMMP with an Important Farmland
designation that would be directly converted as a result of the Project.
b) Identify any onsite prime soils that would be impacted based on the NRCS
designation of prime agricultural soils. The NRCS defines prime agricultural soils
as land with the best combination of physical and chemical features able to sustain
long-term production of agricultural crops.
c) Identify onsite and offsite areas with a County agriculture land use designation that
would be directly converted or would be affected by other changes in the
environment that would indirectly contribute to the conversion of agricultural land
as a result of the Project.
3.2.3.3 Project Impacts and Mitigation Measures
Implementation of the Project has the potential to result in direct impacts to onsite
agricultural resources, including grazing land and prime soils. The Project also has the
potential to result in impacts to agricultural resources based upon consistency with goals
and policies within the LUE and COSE of the City’s General Plan (refer also to Section
3.9, Land Use and Planning), and the 2010 Open Space and Agricultural Conservation
Easement agreement. These impacts are further discussed below and summarized in Table
3.2-4.
3.2-14 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
Table 3.2-4. Summary of Project Impacts
Agricultural Resource Impacts Mitigation Measures Residual
Significance
AG-1. The Project would convert onsite Farmland of
Local Potential and prime soils if irrigated to non-
agricultural uses.
None Required Less than
Significant
AG-2. Implementation of the Project would create
potential conflicts with existing agricultural zoning.
None Required Less than
Significant
AG-3. The Project would adjust the boundary of an
existing open space and agricultural conservation
easement to a location that would reduce the viability
of agricultural operations within the recorded
easement.
None Required Less than
Significant
Impact AG-1 The Project would convert onsite Farmland of Local Potential and
prime soils if irrigated to non-agricultural uses. (Less than Significant).
The Project site does not contain Prime Farmland, Unique Farmland, or Farmland of
Statewide Importance (Important Farmland), as shown on the maps prepared pursuant to
the FMMP of the California Resources Agency (see also, Figure 3.2-1 and City General
Plan COSE, Figure 10). Per the City General Plan COSE Figure 10, Prime Agricultural
Soils, the Project site contains areas mapped as Farmland of Local Potential. Therefore,
the Project would not convert FMMP-designated Important Farmland. The Project site
contains 46.2 acres of FMMP-designated Grazing Land, which has vegetation suited to
grazing livestock, and 67.6 acres of FMMP-designated Farmland of Local Potential, which
are potentially suitable for farmland but are not currently, and have not historically been,
cultivated or irrigated. Implementation of the Project would result in the conversion of
approximately 15.1 acres of Grazing Land (primarily within the Upper Terrace of the
Project site) and 47.0 acres of Farmland of Local Potential (primarily within Lower Area
and Madonna Froom Ranch) to developed urban uses. The loss of Grazing Land and
Farmland of Local Potential is not considered a significant impact under CEQA, nor under
the City’s General Plan LUE.
The Project site contains approximately 43.9 acres of Cropley clay and 3.7 acres of Salinas
silty clay loam soils (total 47.6 acres), which are considered to be prime soils if irrigated.
Though not currently irrigated, available water supplies exist to support irrigation of these
soils, including an existing well onsite. As such, these soils could be considered prime
under NRCS classifications and prime agricultural land under the City’s General Plan if
water sources were used to irrigate the land for crop cultivation. However, no portion of
the Project site is currently irrigated and there is no history of irrigated crop production
Froom Ranch Specific Plan 3.2-15
Draft EIR
3.2 AGRICULTURAL RESOURCES
within the Project site. A California Agricultural Land Evaluation and Site Assessment
(LESA) Model was prepared for the Project, resulting in a scoring decision of less than
significant. LESA is a method used to define an approach for rating the relative quality of
land resources based upon specific measurable features. The California Agricultural LESA
Model is composed of six different factors: two Land Evaluation (LE) factors are based
upon measures of soil resource quality, and four Site Assessment (SA) factors provide
measures of a given project’s size, water resource availability, surrounding agricultural
lands, and surrounding protected resource lands. The factors are then weighted relative to
one another and combined, resulting in a single project score that becomes the basis for
making a determination of a project’s potential significance, based upon a range of
established scoring thresholds.
• If the total LESA score is from 0 to 39 points, the scoring decision is “not
considered significant.”
• If the score is from 40 to 59 points, it is “considered significant only if LE and SA
subscores are each greater than or equal to 20 points.”
• If the score is from 60 to 79 points, it is “considered significant unless either LE or
SA subscore is less than 20 points.”
• If the score is from 80 to 100 points, it is “considered significant” (California
Department of Conservation 1997).
LESA scores for the Project site (including the offsite stormwater basin) are summarized
in Table 3.2-5 below.
Table 3.2-5. Final LESA Score Sheet
Factor
Scores
Factor
Weight (%)
Weighted
Factor Scores
Land Evaluation Factors
Land Capability Classification <1> 52.79 25 13.2
Storie Index <2> 51.22 25 12.81
Subtotal 50 26.01
Site Assessment Factors
Project Size <3> 80 15 12
Water Resource Availability <4> 25 15 3.75
Surrounding Agricultural Land <5> 0 15 0
Protected Resource Land <6> 50 5 2.5
Subtotal 50 18.25
Final Score 44.26
Significance Determination Less than Significant
Source: Appendix L.
3.2-16 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
The Project would also be required to comply with LAFCO Policy 2.9.12, Agricultural
Policies, which provides that the Commission may approve annexations of prime
agricultural land only if mitigation that equates to a substitution ratio of at least 1:1 for the
prime land to be converted from agricultural use is agreed to by the applicant (landowner),
the jurisdiction with land use authority.
The Project would not convert Important Farmland (as defined by the FMMP of the
California Resources Agency) or prime agricultural soils (due to lack of historic or current
irrigation), and is not considered a significant conversion of land per the California
Agricultural LESA Model. Therefore, the loss of this resource through development of the
Project is considered less than significant.
Impact AG-2 Implementation of the Project would create potential conflicts with
existing agricultural zoning (Less than Significant).
The Project site currently contains land within the Agriculture and Rural Lands land use
designations within the County and Commercial Retail land use within the City and
supports some limited grazing uses, historic structures utilized to support a construction
business, and an active permitted rock quarry. Currently, the Specific Plan area is leased
for horse grazing; the proposed stormwater detention basin area is vacant and not used for
agricultural activities. Upon Project approval, the Specific Plan area would be designated
for residential, commercial/retail, and parks/open space uses within the City. The proposed
residential, commercial/retail, and public park land uses would convert more rural uses to
urban uses and eliminate existing grazing uses. The Project site is planned for urban
development with a Specific Plan (SP-3) land use designation under the City’s LUE and
the Project would be consistent with Policy 1.7.3, Interim Uses, where grazing uses would
continue until urban development occurs under a Specific Plan.
There are parcels within the Agriculture and Rural Lands designations within the County
adjacent to the Project site to the west and south. However, none of the immediately
adjacent lands currently support agricultural uses, including cultivation or grazing. Instead,
adjacent agricultural parcels contain open space within conservation easements and
Mountainbrook Church. In the vicinity, agriculturally zoned lands exist within 0.25 mile
of the Project site on the east side of U.S. 101, which are currently in active agricultural
production (row crops). Further to the south, some of these agricultural parcels are subject
to Williamson Act contracts. However, agricultural parcels within 0.5 mile of the Project
site are separated from the Project site by the existing urban development, such as the Irish
Hills Plaza, hotels, and Mountainbrook Church, as well as non-agricultural open space
Froom Ranch Specific Plan 3.2-17
Draft EIR
3.2 AGRICULTURAL RESOURCES
areas, such as the Irish Hills Natural Reserve. This substantial distance and developed
buffer would prevent indirect impacts of the Project on existing agriculturally zoned
parcels or existing agricultural operations in the Project vicinity.
Development of the Project site would convert 116.8 acres of Agriculture, Rural Lands,
and Commercial Retail designated land uses to urban uses. This includes 59.0 acres of
Agriculture and Rural Lands designated land use that would be annexed and re-designated
as Open Space under the Project, making these areas not suitable for agricultural uses in
the future. However, the site is planned for urban development, park land, and open space
consistent with the City’s General Plan. Therefore, impacts would be adverse, but less than
significant.
Impact AG-3 The Project would adjust the boundary of an existing open space and
agricultural conservation easement to a location that would reduce the
viability of agricultural operations within the recorded easement (Less
than Significant).
The 7.1-acre open space and agricultural conservation easement was established onsite in
2010 based on LAFCO Policy 2.9.12 and requires that the land within the easement be
capable of retaining historical onsite agricultural operations, and/or provide open space and
biological resource value, such as wetlands. The easement currently encircles a contiguous
block of land with soils that are prime if irrigated within the southeast area of the Project
site. The Project would adjust the boundary of the 7.1-acre easement (refer to Figure 2-4).
The proposed easement boundary adjustment would retain a total of 7.1 acres of land;
however, the dedicated area would be divided into two isolated areas. Approximately 5.5
acres of the proposed reconfigured easement area would be located west of Calle Joaquin,
while approximately 1.6 acres would be located east of Calle Joaquin.
To comply with LAFCO requirements and the 2010 Open Space and Agricultural
Conservation Easement agreement, the proposed adjusted easement would need to support
historical agricultural operations, including existing grazing uses, or allow for conservation
of biological resources, including wetlands. Adjustment of the existing easement boundary
would effectively reduce the extent of lands dedicated to grazing uses from 7.1 acres to 5.5
acres, as livestock would not have the ability to access or utilize the 1.6-acre portion east
of Calle Joaquin. This effective reduction would also reduce the viability of existing
grazing operations or other agricultural operations to occur within the 5.5-acre portion of
the adjusted easement. However, realignment of the easement would support conservation
of habitat and biological resources, particularly the protection of existing wetlands within
3.2-18 Froom Ranch Specific Plan
Draft EIR
3.2 AGRICULTURAL RESOURCES
this 1.6-acre portion east of Calle Joaquin, which is consistent with the terms of the
easement. Thus, adjustment of the 7.1-acre easement would continue to meet the objectives
and LAFCO requirements of the 2010 Open Space and Agricultural Conservation
Easement agreement and this impact is considered less than significant.
3.2.3.4 Cumulative Impacts
Implementation of the Project would contribute incrementally to the loss of agricultural
land (Grazing Land and Farmland of Local Potential) to development within the County
and particularly within the City’s Sphere of Influence. Although agricultural resources in
the Project vicinity are predominantly located outside of City limits, agriculture is a major
industry in the County. The County has experienced the trend of conversion of agricultural
resources to developed uses; between 2010 and 2012, the FMMP recorded a net loss of
3,601 acres of Important Farmland, and between 2012 and 2014, the FMMP recorded a net
loss of 10,706 acres of Important Farmland. However, between 2014 and 2016, FMMP
reports indicate that this trend in conversion of agricultural resources to development uses
began to reverse, and approximately 1,758 acres of Important Farmland were gained
(California Department of Conservation, Division of Land Resource Protection 2012,
2014, 2016). In addition, within the City, projects such as the San Luis Ranch Specific Plan
and Avila Ranch Development Plan would result in the conversion of over 200 acres of
agricultural land to urban uses in the Project vicinity.
The Project would not contribute to the loss of Important Farmland. Consistent with the
LUCE Update EIR, the Project would implement mitigation measures to ensure
compliance with the goals and policies of the General Plan. Similar to the Project, other
cumulative development within the City that would result in the conversion of agricultural
resources would be subject to Policy 1.9.2 in the LUE, Prime Agricultural Land, and Policy
8.6.3 in the COSE, Required Mitigation. However, cumulative development would
continue to result in the irreversible loss of agricultural resources. The Project would result
in the incremental loss of agricultural resources within the County, including the loss of
Grazing Lands and loss of Farmland of Local Potential, per the FMMP. The County has
experienced a net gain of 8,117 acres of Grazing Land between 2010 and 2016 (California
Department of Conservation, Division of Land Resource Protection 2014; 2012; 2016).
However, the Project site does not contain prime agricultural resources per the FMMP,
current soil classifications, or the California Agricultural LESA Model, nor would it
contribute to the loss of prime agricultural land within the County. Therefore, the Project’s
cumulative contribution to loss of agricultural resources would be less than significant.
Froom Ranch Specific Plan 3.2-19
Draft EIR