HomeMy WebLinkAboutAppendix B-Notice of Preparation and Comment LettersAPPENDIX B
Notice of Preparation and Comment Letters
Froom Ranch Specific Plan Project
Draft EIR
This Page Intentionally Left Blank.
Notice of Preparation
To: EIR & Notice of Preparation Mailing List
SUBJECT: Notice of Preparation of a Draft Environmental Impact Report
Lead Agency: Consulting Firm: (if applicable)
Agency Name: City of San Luis Obispo EIR to be prepared by:
Department Name: Community Development Firm Name: To be determined
Street Address: 919 Palm Street Street Address:
City/State/Zip: San Luis Obispo, CA 93401 City/State/Zip:
Contact: Shawna Scott (781-7176; sscott@slocity.org) Contact:
The City of San Luis Obispo will be the Lead Agency and will prepare an environmental impact report
(EIR) for the project identified below. We need to know the views of your agency as to the scope and
content of the environmental information, which is germane to your agency’s statutory responsibilities
in connection with the proposed project. Your agency will need to use the EIR prepared by our agency
when considering your permit or other approval for this project. The project description, location, and
the potential environmental effects are summarized in the attached materials. A copy of the Initial
Study and additional background information is available here:
www.slocity.org/government/department-directory/community-development/documents-
online/environmental-review-documents/-folder-1911. Due to the time limits mandated by State law,
your response must be sent at the earliest possible date, but not later than 30 days after receipt of
this notice. Please send your response to the attention of Shawna Scott, Associate Planner for the
City of San Luis Obispo Community Development Department, at the address shown above. We will
need the name of a contact person in your agency.
Project Title: Froom Ranch Specific Plan Project
Project Location: The Froom Ranch Specific Plan Area consists of two parcels located at 12165 and
12393 Froom Ranch Way, totaling approximately 110 acres (ANP 067-241-030 and 067-241-031)
within unincorporated San Luis Obispo County, and adjacent to City of San Luis Obispo city limits. The
site is located immediately west of Los Osos Valley Road between U.S. 101 and the Irish Hills Plaza.
Project Description: The project includes a Specific Plan, General Plan Amendment, and related
actions that would allow for the development of the Froom Ranch Specific Plan Area, which is
identified as Specific Plan 3 (SP-3), Madonna on LOVR, in the City’s General Plan. The Land Use
Element requires that a Specific Plan be adopted prior to annexation. The project will be primarily
residential with some commercial development in the northeast portion of the site closest to Los Osos
Valley Road and the adjacent Irish Hills Plaza. A major component of the planned residential uses is a
Life Plan Community (LPC) known as Villaggio. Villaggio would provide a variety of different unit types
for independent senior housing as well as access to higher levels of care such as Assisted Living,
Memory Care, and Skilled Nursing, when needed. Additional residential uses in the northern portion of
the site will be multiple-family. As required by the Land Use Element, a minimum of 50% of the project
site must be designated Open Space; the current Plan designates approximately 51% of the site as
Open Space. The Specific Plan also includes a Neighborhood Trailhead Park to connect to the Irish
Hills Natural Reserve, which may incorporate onsite historic structures. The treatment and potential
use of the historic structures is currently under evaluation by the applicant.
Date: July 10, 2017
Signature:
Title: Associate Planner, City of San Luis Obispo Community Development Department
Reference: California Administrative Code, Title 14 (CEQA Guidelines) Sections 15082(a), 15103, 15375 (Revised October 1989)
Page 2
NOTICE OF PREPARATION ATTACHMENT
FROOM RANCH SPECIFIC PLAN PROJECT
The City of San Luis Obispo, as Lead Agency under the California Environmental Quality Act (CEQA),
is requesting comments on the scope and content of an environmental impact report (EIR) being
prepared for the Froom Ranch Specific Plan Project, as described in this Notice of Preparation.
Anticipated project entitlements are described below and issues anticipated being analyzed in the EIR
are listed below and described in the Initial Study. The Initial Study and additional background
information is available here: www.slocity.org/government/department-directory/community-
development/documents-online/environmental-review-documents/-folder-1911. The City requests your
written comments on the NOP by August 14, 2017 and also invites you to attend a public scoping
meeting to be held on July 26, 2017, as detailed below. Please contact Shawna Scott, Associate
Planner at (805) 781-7176 or sscott@slocity.org or Contract Planner and Project Manager Emily Creel
at (805) 543-7095 x6814 or ecreel@swca.com if you have any questions.
Project Location
The Froom Ranch Specific Plan Area consists of two
parcels located at 12165 and 12393 Froom Ranch Way,
totaling approximately 110 acres (APN 067-241-030 and
067-241-031) within unincorporated San Luis Obispo
County, and adjacent to City of San Luis Obispo city
limits. The site is located immediately west of Los Osos
Valley Road between U.S. 101 and the Irish Hills Plaza.
Based on a preliminary review, the project site is not on
the list of hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and there are no
records of previous or existing sources of hazardous
materials onsite.
Discretionary Permits
In order to implement development on the site consistent with the proposed project, the following
entitlements will need to be processed:
1. General Plan Amendment/Pre-Zoning
2. Specific Plan
3. Development Plan/Tentative Tract Map(s)
4. Architectural Review
5. Annexation
1. General Plan Amendment and Pre-Zoning. The applicant envisions a Specific Plan that
differs somewhat from the performance standards identified in the Land Use Element;
therefore, the project would require a General Plan Amendment to accommodate some
aspects of future development under the Specific Plan. Because the site is currently
unincorporated, it will need to be pre-zoned before annexation to the City could be
approved.
2. Specific Plan. The City of San Luis Obispo Land Use and Circulation Elements (LUCE)
identifies Froom Ranch as a Specific Plan Area (SP-3, Madonna on LOVR) that requires
the adoption of a Specific Plan prior to any development. The applicant is preparing a
Specific Plan to accommodate the proposed development consistent with guidance for
development contained in Section 8.1.5 of the Land Use Element.
Page 3
3. Development Plan/Tentative Tract Map(s). The applicant will submit tract maps to
implement the provisions of the Specific Plan. The Tract Map establishes the proposed
lot lines to allow individual ownership of properties and to layout the required
infrastructure and utilities.
4. Architectural Review – Ultimately final architectural review of housing, commercial
buildings, and some site facilities will be needed. The ARC will take an early look at design
guidance in the development plan and provide comments.
5. Annexation. If the project is approved, the City would initiate the annexation process with
the San Luis Obispo Local Agency Formation Commission (LAFCo). Annexation will
depend on the City’s ability to address key issues to LAFCo, including the ability to provide
public services to the site (including water) and the nature of a tax-sharing arrangement
with San Luis Obispo County.
In addition, the project will need to be formally reviewed by the Airport Land Use Commission (ALUC)
for consistency with the Airport Land Use Plan. Other advisory bodies that will weigh in on aspects of
the project development include the Parks & Recreation Commission reviewing park proposals,
Cultural Heritage Committee regarding the proposed use/treatment of historic structures, and the
Bicycle Advisory Committee advising on the proposed bicycle trail network.
Probable Environmental Effects/Issues Scoped for EIR
The EIR will be a full-scope document, which covers all environmental issue areas as summarized in
the preliminary Initial Study and as required by State CEQA Guidelines Article 9, Contents of
Environmental Impact Reports. Issue areas identified in the Initial Study as requiring evaluation in the
EIR and that may be determined to be potentially significant include:
Aesthetics
Agricultural Resources
Air Quality
Biological Resources
Cultural Resources
Energy
Geology and Soils
Greenhouse Gas Emissions
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use/Planning
Noise
Population and Housing
Public Services
Recreation
Transportation and Traffic
Tribal Cultural Resources
Utilities and Service Systems
In addition, the following anticipated key issues are highlighted and summarized below.
Page 4
Potential Impacts to Environmental Resources Due to Development Above the 150-foot Elevation
The applicant’s request includes a General Plan Amendment to modify the current language
presented in City of San Luis Obispo Land Use Element (LUE) Policy 6.4.7.H to allow for hillside
development above the 150-foot elevation. The EIR will evaluate the potential impacts to visual,
biological, and hydrological resources, potential geologic and soils hazards, and consistency with
plans and policies specifically identified to protect these sensitive resources. Additional analysis
including photo simulations of the proposed development within the hillside context will be necessary
to determine if the project could be designed to protect hillside views, consistent with LUE hillside
development policies and LUE resource protection policies, Open Space Policies protecting scenic
vistas, and Circulation Element policies which call for the protection of views from roadways
designated as having scenic value.
Potential Impacts as a Result of Froom Creek Realignment
The proposed project includes the realignment and restoration of Froom Creek within the property
boundaries, and construction of pathways. City creeks and wetlands management objectives
applicable to Froom Creek include:
A. Maintaining and restoring natural conditions and fish and wildlife habitat;
B. Preventing loss of life and minimizing property damage from flooding;
C. Providing recreational opportunities which are compatible with fish and wildlife habitat, flood
protection, and use of adjacent private properties.
D. Recognizing and distinguishing between those sections of creeks and Laguna Lake which
are in urbanized areas, such as the Downtown core, and sections which are in largely
natural areas. Those sections already heavily impacted by urban development and activity
may be appropriate for multiple use whereas creeks and lakeshore in a more natural state
shall be managed for maximized ecological value (LUE Section 6.6.1 Creek and Wetlands
Management Objectives).
City staff and the applicant have met with resource agencies including the U.S. Army Corps of
Engineers, National Oceanic and Atmospheric Administration (NOAA) Fisheries, Regional Water
Quality Control Board, and California Department of Fish and Wildlife to review conceptual plans and
determine preliminary information that will be required for the agencies to formally respond to the
project. Key considerations include review of hydrological modeling to determine the gradient and
width necessary to provide suitable conditions for steelhead migration from the upper pools of Froom
Creek, through the project site, and connecting with San Luis Creek. Additional project details and
technical information will be provided by the applicant. Additional analysis will be required to ensure
consistency with regulations specific to floodway and floodplain management.
Potential Impacts to Historic Resources
The Froom Ranch Historic Complex is located within the project site, approximately at and below the
150-foot elevation line. This complex is not currently accessible to the public, and is generally blocked
from public view. The applicant submitted an evaluation of prehistoric and historic resources present
on the project site (First Carbon Solutions 2015), which determined that the Froom Ranch complex
(seven structures) is historically significant under National Register of Historic Places, California
Register of Historical Resources, and City of San Luis Obispo Historic Resources criteria. The LUE
states that the proposed project design should be sensitive to environmental constraints, including
historic structures, and adjust accordingly through design. The City Conservation and Open Space
Element (COSE) provides additional specific policy direction including the following:
Page 5
• Significant historic and architectural resources should be identified, preserved, and
rehabilitated.
• Historically or architecturally significant buildings shall not be demolished or substantially
changed in outward appearance, unless doing so is necessary to remove a threat to health
and safety and other means to eliminate or reduce the threat to acceptable levels are
infeasible.
• Buildings and other cultural features that are not historically significant but which have
historical or architectural value should be preserved or relocated where feasible. Where
preservation or relocation is not feasible, the resource shall be documented and the
information retained in a secure but publicly accessible location. An acknowledgement of the
resource should be incorporated within the site through historic signage and the reuse or
display of historic materials and artifacts.
• Changes or additions to historically or architecturally significant buildings should be consistent
with the original structure and follow the Secretary of Interior’s Standards for the Treatment of
Historic Buildings. New buildings in historical districts, or on historically significant sites, should
reflect the form, spacing and materials of nearby historic structures. The street appearance of
buildings which contribute to a neighborhood’s architectural character should be maintained”
(COSE Section 3.2 and 3.3, Historical and Architectural Resources and Policies).
Full analysis of historic resources in the EIR will be necessary. The EIR will include an evaluation of
the proposed project, in addition to feasible alternatives to mitigate potential impacts to historic
resources. The EIR will also provide a preliminary assessment of the project’s consistency with the
General Plan and Historic Preservation Ordinance and Guidelines.
Development of a Reasonable Range of Alternatives
Factors that will influence the formulation of alternative project configurations include considerations
of project objectives, site suitability, economic viability, availability of infrastructure, General Plan
consistency, and the proponent’s control over alternative sites. The EIR will discuss the rationale for
selection of alternatives that are feasible and therefore, merit in-depth consideration, and which are
infeasible (e.g., failed to meet Project objectives or would not avoid significant environmental effects)
and therefore rejected. As directed by the City Council, the EIR will include a project alternative that
locates all development below the 150-foot elevation line. The City has requested this design
alternative from the applicant for incorporation and analysis in the EIR. The Alternatives Analysis will
also include an Alternative that retains and restores Froom Creek in its current location. In order to
present actionable alternatives in the EIR, the alternatives chapter will be comprehensive, provide
clear descriptions and graphics, and clearly identify potential impacts, associated levels of
significance, and identification of the mitigation measures that would be required to reduce potential
impacts. Additional alternatives are likely, but are not identified at this time.
Public Scoping Meeting
A public scoping meeting has been scheduled to allow for any interested persons to provide input on
issues to be discussed in the EIR:
Date and Time: July 26, 2017 at 6:00 p.m.
Place: 990 Palm Street (City Council Chamber upstairs)
The meeting is an opportunity for City staff to gather information from the public regarding the
potential environmental impacts of the project that need to be evaluated in the EIR. It is not intended
to be a hearing on the merits of the project. Therefore, members of the public should keep their
comments focused on potential significant changes to the environment that may occur as a direct
result of project development.
APPENDIX B – NOP COMMENTS AND RESPONSES
INDEX TO NOP COMMENTS
Appendix B includes a copy of the Notice of Preparation (NOP) for the proposed Project,
transcripts from the Public Scoping Hearings conducted on the NOP, copies of all comment letters
received on the NOP during the public comment period, and an indication (Section or Sub-Section)
where each individual comment is addressed in the Draft EIR. Table B-1 lists all comments and
shows the comment set identification number for each letter or commenter. Table B-2, identifies
the location where each individual comment is addressed in the Draft EIR. Comment letters are
present chronologically followed by the transcripts from the Public Hearing.
Table B-1. NOP Commenters and Comment Set Numbers
Agency /Affiliation Name of Commenter Date of Comment Received
NOP Comment Set
Interested Party Kathleen Choal 7/19/2017 1
Sierra Club Andrew Christie 7/25/2017 2
Interested Party Mila Vujovich-La Barre 7/26/2017 3
Native American Heritage Commission Gayle Totton 7/27/2017 4
Salinan Tribe Patti Dutton 7/31/2017 5
Bicycle Advisory Committee Lea Brooks (1) 8/1/2017 6
San Luis Obispo Local Agency Formation Commission David Church 8/1/2017 7
CAL FIRE San Luis Obispo County Fire Department Travis Craig 8/2/2017 8
County of San Luis Obispo Department of Agriculture Lynda L. Auchinachie 8/4/2017 9
Interested Party Lea Brooks (2) 8/4/2017 10
California Department of Transportation – District 5 Melissa Streder 8/10/2017 11
California Native Plant Society Neil Havlik 8/11/2017 12
San Luis Obispo Council of Governments Jeff Brubaker 8/14/2017 13
United States Fish and Wildlife Service Stephen P. Henry 8/14/2017 14
Table B-2. Response to NOP Commenters
Comment # Responses
Kathleen Choal
1-1 Thank you for your comments. Please refer to Section 3.13, Transportation and Traffic for
impacts concerning traffic. With regard to what sidewalk improvements are proposed, please refer
to Section 2.0, Project Description.
1-2 Section 3.14, Utilities and Energy Conservation, provides discussion and analysis of impacts
associated with water use and water supply.
1-3 Please refer to Section 3.8, Hydrology and Water Quality, which provides the analysis of flood
potential upon Project implementation.
Sierra Club – Andrew Christie
2-1 Thank you for your comments. Please refer to Section 5.0, Alternatives, for descriptions and
analysis of multiple Project alternatives, including consideration for an alternative with all
development below the 150-foot elevation line.
Froom Ranch Specific Plan Project B-1
Draft EIR
APPENDIX B – NOP COMMENTS AND RESPONSES
Comment # Responses
2-2 Please refer to Section 2.0, Project Description, for the list of Project objectives, and to Section
5.0, Alternatives, for the assessment of alternatives against Project objectives.
2-3 Section 3.0.4, Cumulative Impact Analysis, describes the methodology and cumulative projects
list utilized for analysis within the EIR. Each resource section (Sections 3.1 through 3.15) also
contains cumulative analysis associated with each resource area.
Mila Vujovich-La Barre
3-1 Thank you for your comments. Please refer to Section 3.14, Utilities and Energy Conservation,
which provides discussion and analysis of impacts associated with water use and water supply.
3-2 Section 3.9, Land Use and Planning, provides consideration for design restrictions and site
constraints established by the LUCE, including the 150-foot height line, and Section 3.11,
Population and Housing, considers the proposed residential component associated effects.
3-3 Please refer to Section 3.13, Transportation and Traffic, for impacts concerning traffic, including
cumulative considerations.
3-4 Section 3.0.4, Cumulative Impact Analysis, describes the methodology and cumulative projects
list utilized for analysis within the EIR, including the Prado Road project.
3-5 Section 3.11, Population and Housing, considers the proposed residential component associated
effects, including the City’s affordable housing requirement.
3-6 Please refer to Section 3.8, Noise, which provides analysis for potential noise from vehicular
traffic and potential mitigation.
3-7 Section 3.4, Biological Resources, discusses animal and vegetation protection within the site, and
Section 3.1, Aesthetics, addresses viewshed impacts in the vicinity.
3-8 Refer to Section 3.13, Transportation and Traffic for impacts concerning access, sidewalks, and
bike paths, and Section 3.12, Public Services and Recreation, for proximity and access to
recreational facilities and open spaces in the area.
3-9 With regard to the EIR process, please refer to Section 1.0, Introduction, for a summary of the
public outreach undertaken during EIR preparation.
3-10 Please refer to Section 3.2, Agricultural Resources, which addresses agricultural resources on-site
and potential impacts from the Project on agricultural activities.
Native American Heritage Commission – Gayle Totton
4-1 Thank you for your comments and guidance. Please refer to Section 1.0, Introduction, for a
summary of outreach undertaken during EIR preparation, and Section 3.5, Cultural and Tribal
Cultural Resources, for the implementation of CEQA updates associated with tribal cultural
resources, including adherence to AB 52, SB 18, and the NAHC’s recommendations for
conducting cultural resources assessments.
Salinan Tribe – Patti Dutton
5-1 Thank you for your comment.
Bicycle Advisory Committee – Lea Brooks (1)
6-1 Thank you for your comments. Regarding what street improvements are proposed, please refer to
Section 2.0, Project Description. Please refer to Section 3.13, Transportation and Traffic for
impacts concerning traffic, and potential mitigations that would affect proposed improvements
and existing connections.
6-2 Refer to Section 3.13, Transportation and Traffic for impacts concerning pedestrian and bicycle
access, and Section 3.12, Public Services and Recreation, for proximity and access to recreational
facilities and open spaces in the area, including the existing trail network.
San Luis Obispo Local Agency Formation Commission – David Church
7-1 Thank you for your comments. Please refer to Sections 3.12, Public Services and Recreation, and
3.14, Utilities and Energy Conservation, which address the majority of potential increases in
services that may be required to the Project site, though associated information is located
throughout the EIR.
7-2 Please refer to the prepared EIR, which contains all associated information, especially within
Sections 3.12, Public Services and Recreation, and 3.14, Utilities and Energy Conservation.
7-3 Section 2.0, Project Description, contains a list of required approvals, including annexation and
prezoning.
B-2 Froom Ranch Specific Plan Project
Draft EIR
APPENDIX B – NOP COMMENTS AND RESPONSES
Comment # Responses
7-4 Please refer to the regulatory setting descriptions within the EIR, which contain relevant LAFCo
policies for agricultural resources, public safety, water/wastewater, land use, and growth inducing
impacts.
7-5 Refer to Sections 3.2, Agricultural Resources, and 3.9, Land Use and Planning, for discussion of
agricultural conservation easement holdings and associated impacts of the Project, including
consideration for LAFCo’s Madonna-Gap annexation.
7-6 Please refer to the analysis within the EIR, which contain relevant LAFCo policies and mitigation
measures, notably within Sections 3.2, Agricultural Resources, 3.3, Air Quality and Greenhouse
Gas Emissions, 3.12, Public Services and Recreation, and 3.13, Transportation and Traffic.
7-7 Please refer to Section 5.0, Alternatives, for the descriptions and associated analyses for each
Project alternative.
CAL FIRE San Luis Obispo County Fire Department – Travis Craig
8-1 Thank you for your comments. With regard to discussion and impacts on emergency services and
CALFIRE/San Luis Obispo County Fire Department facilities pursuant to CEQA, please refer to
Section 3.12, Public Services and Recreation.
County of San Luis Obispo Department of Agriculture – Lynda L. Auchinachie
9-1 Thank you for your comments. Please refer to Section 3.2, Agricultural Resources, which
addresses agricultural resources on-site such as prime agricultural land, the agricultural easement,
and potential impacts from the Project on agricultural activities.
Lea Brooks (2)
10-1 Thank you for your comments. Please refer to Section 3.13, Transportation and Traffic for
impacts concerning pedestrian and bicycle access and safety.
California Department of Transportation: District 5 – Melissa Streder
11-1 Thank you for your comments. Section 3.11, Population and Housing, provides discussion and
analysis of work force housing and consideration for the City’s jobs-housing balance. Associated
Vehicle Miles Traveled and vehicle dependency is discussed within Section 3.13, Transportation
and Traffic.
11-2 Section 3.13, Transportation and Traffic, provides discussion and analysis of potential impacts of
the Project on surrounding roadways and intersections, in addition to consideration for cumulative
impacts.
11-3 Refer to Section 3.13, Transportation and Traffic, for discussion of multimodal transportation
strategies alternate circulation patterns and connectivity to the Project site.
11-4 Please refer to Section 3.8, Hydrology and Water Quality, which provides the analysis of flood
potential upon Project implementation, including modifications to creeks and culverts within the
Project site and vicinity, including culverts within Caltrans right-of-way near U.S. Highway 101.
California Native Plant Society – Neil Havlik
12-1 Thank you for your comments. With regards to potential impacts above the 150-foot elevation
line associated with aesthetics, biological, hydrological, and noise, please refer to Sections 3.1,
Aesthetics, 3.4, Biological Resources, 3.8, Hydrology and Water Quality, and 3.10, Noise.
12-2 Please refer to Section 3.1, Aesthetics, for aesthetics discussion and impacts associated with
implementation of the Project.
12-3 Please refer to Section 3.4, Biological Resources, for biological resource discussion and impacts
associated with implementation of the Project.
12-4 Please refer to Sections 3.4, Biological Resources, and 3.8, Hydrology and Water Quality, for
discussion and impacts associated with implementation of the Project, including water flow and
biological resources.
12-5 Please refer to Section 3.4, Biological Resources, for discussion and impacts associated with
implementation of the Project, including protection of the federally-listed Chorro Creek bog
thistle.
12-6 Please refer to Sections 3.8, Hydrology and Water Quality, and 3.4, Biological Resources, for
discussion and impacts associated with implementation of the Project, including realignment of
Froom Creek and the potential destruction of delineated wetland areas.
12-7 Section 3.8, Hydrology and Water Quality, addresses Froom Creek, subsurface flows, potential
effects of the creek’s proposed realignment, and flooding.
Froom Ranch Specific Plan Project B-3
Draft EIR
APPENDIX B – NOP COMMENTS AND RESPONSES
Comment # Responses
12-8 Refer to Section 3.5, Cultural and Tribal Cultural Resources, for analysis of the Froom Ranch
historic buildings and measures to preserve their integrity.
12-9 Please refer to Sections 3.2, Agricultural Resources, and 3.9, Land Use and Planning, for
discussion of open space and agricultural conservation easement holdings, in addition to impacts
to these areas upon implementation of the Project.
12-10 Refer to Section 1.0, Introduction, which summarizes easements associated with the Project site
and that may be affected by the Project and/or alternatives, and Section 3.4, Biological Resources,
which discusses potential impacts to biological resources.
12-11 Please refer to Section 5.0, Alternatives, for the descriptions and associated analyses for each
Project alternative.
San Luis Obispo Council of Governments – Jeff Brubaker
13-1 Thank you for your comments. For discussion and consideration for SLOCOG’s 2014 Regional
Transportation Plan and Sustainable Communities Strategy, please refer to Section 3.9, Land Use
and Planning, and Section 3.13, Transportation and Traffic.
13-2 Please refer to Section 3.11, Population and Housing, which provides discussion and analysis of
affordable housing, including consideration for SLOCOG’s 2050 Regional Growth Forecast, and
very low-, low-, and moderate-income households. Associated impacts to transportation and
traffic are addressed within Section 3.13, Transportation and Traffic, and associated greenhouse
gas emissions addressed within Section 3.3, Air Quality and Greenhouse Gas Emissions.
13-3 Section 3.13, Transportation and Traffic, provides discussion and analysis of potential impacts of
the Project on surrounding roadways and intersections, in addition to consideration for cumulative
projects and transportation demand management.
13-4 Refer to Section 3.13, Transportation and Traffic for impacts concerning pedestrian and bicycle
access, and Section 3.12, Public Services and Recreation, for proximity and access to recreational
facilities and open spaces in the area, including the existing trail network.
United States Fish and Wildlife Service – Stephen P. Henry
14-1 Thank you for your comments. Please refer to Section 3.4, Biological Resources, which discusses
animal and vegetation protection within the site, including consideration for federally-listed
threatened animal species, the Endangered Species Act, and associated mitigations. Section 4.0,
Alternatives, provides descriptions and analysis of alternatives and their potential impacts to
biological resources.
B-4 Froom Ranch Specific Plan Project
Draft EIR
July 19, 2017
City of San Luis Obispo
c/o Community Development
919 Palm Street
San Luis Obispo, CA 93401
Re: Froom Ranch Specific Plan Project
To Whom It May Concern:
RECEIVED
CITY OF SAN LUIS OBISPO
JUL 2 5 2017
COMMUNITY DEVELOPMENT
I am writing regarding the EIR for the Froom Ranch Specific Plan Project. As a business
owner in the area, I have 3 major concerns that I would like to have included in the EIR:
Traffic congestion/Roadway Improvements
Water Use
Flooding
The traffic on Los Osos Valley Road has grown tremendously over the last few years as
more retail has moved into the area. The roadway improvements completed last summer
have helped but traffic still backs up at the major intersections and the entrances to retail
areas by Costco and Target. I would like to see what kind of impact this project would
have on the traffic in the area and what kind of roadway improvements would be needed
to handle the increased congestion. Of note, would a sidewalk be included on the
southside of LOVR?
Although we have left the drought behind for now, I would like to know if water use will
be an issue for this project.
The intersection of LOVR & Calle Joaquin flooded several times during our rainy season.
Sections of roadway along LOVR were also reduced to one lane due to water overflow.
As part of the EIR, I would like to see how the potential for flooding along the roadway
and any sidewalk would be addressed.
Thank you.
Sincerely,
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Kathleen Choal
KSBY-TV, President & General Manager
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CITY OF SAN LUIS OBISPO
JUL 2 5 2017
COMMUNITY DEVELOPMENT
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Scott, Shawna
From:Santa Lucia Chapter of the Sierra Club <sierraclub8@gmail.com>
Sent:Tuesday, July 25, 2017 3:33 PM
To:Scott, Shawna
Subject:Comments on Froom Ranch NOP
July 25, 2017
Shawna Scott, Associate Planner
City of San Luis Obispo
Community Development
919 Palm St., San Luis Obispo CA 93401
Dear Ms. Scott,
We are in receipt of your July 10 letter requesting comment on the Notice of Preparation of an Environmental
Impact Report for the Froom Ranch Specific Plan Project.
The Sierra Club has three primary concerns with this project: Its proposed development beyond the Urban
Reserve Line, the definition of Project objectives, and the inclusion of a full analysis of the Project’s potential
cumulative impacts in the EIR.
We appreciate that the City has shown awareness of the first concern in the NOP’s discussion of the potential
impacts of the request by the applicant for a General Plan Amendment to allow for hillside development above
the 150-foot level, and the City’s stated intent to include a project alternative that locates all development below
the 150-foot elevation line.
Second, as we pointed out in our comments on the San Luis Ranch Project, when a Specific Plan/General Plan
amendment is proposed, the Project objectives should be stated in terms of development options within the
range of intensity of the residential and commercial development called out in the Land Use Element, not just
the high end of that range. The California Environmental Quality Act does not require analysis of only the
project design that will assure the maximum level of residential and commercial development allowed in the
General Plan and dismissal of any alternative of reduced scale as infeasible solely because the scale is reduced.
We urge the City not to take the position that Project objectives serve as a bar to the analysis of scaled-back
alternatives, nor maintain that a Project alternative may not be considered unless it meets all of the Project
objectives.
Third, per CEQA Guidelines, the EIR must evaluate “past, present, and reasonably foreseeable future projects,”
which “when considered together, are considerable or which compound or increase other environmental
impacts.”
2
As of July 20, the City’s website listed the following reasonably foreseeable future projects:
Projects Currently Posted on SLO City Web Site
Name
Residential
Units
Sq. Feet of
Commercial/Office Hotel
Open
Space Other
San Luis Ranch 500 350,000 200 5.8
Avila Ranch 720 20,000
Froom Ranch 130 30,000 120 2.9 398 Senior Units
1101 Monterey 27,079
Marsh & Carmel 8 1,100
Madonna Plaza 56,257
San Luis Square 62 19,792 36
Monterey Place 29 12,255 3
Vesper Hotel at the Creamery 6,698 47
Twin Creeks 102 6,566
Broad St. Collection 10 6
1185 Monterey 13 2,464
Bridge Street 21,000
71 Palomar Av 33
Wes Creek Development 172
Ferrini Apartments 5
22 North Chorro 27 2,000
Imel Ranch Subdivision 18
Olive Mixed Use 17 3,500
Wingate Homes 142 5,000
Righetti Ranch Subdivision 304
Digital West 775,000
Towne Place Suites 114
French Hospital Expansion
Motel Inn 55 13 RV spaces and 10 Airstream spaces
The Junction 69 3,000
Long Bonetti Public Market 47,000
Jones Subdivision 65 15,000
Granada Hotel Expansion 22
Ellsworth Tract 35 Commercial Lots
Aerovista Place 37,000
South Town 18 18 70
Discovery SLO Bowling 245,000 Reusing existing space
McCarthy Steel 9,840
The Yard 43
3
Bishop Street Studios 34
Caudill Mixed Use 36 5,500
Perry Ford 7,895
Laurel Lane Mixed Use 18 2,500
Poly Performance 30,000
Tank Farm Commerce Park 29,000
Broad Street Mixed Use 11 3,000
Shell Station Development 10,000
Higuera Brew 15,500 Reusing existing space
Iron Works 46 4,400
Monterey Hotel 102
Homeless Service Center 20,000
Toscano Moresco 161
BMW Dealership 23,945
625 Toro 14
Serra Meadows 247
Aerovista Office 37,000
Hotel Serra 8 25,000 64
Brownstones 8
Chinatown Hotel 30 25,000 78
Direct Injectors 6,200
Airport Business Center 75,000
SLO Brew Production 31,290
Avinvo Townhomes 161
Pacific Courtyards 9 8,000
Fxlini Tract 13
Bridge Street 26
Boysen Apartments 6
Total 3315 2,054,851 847 8.7
Compiled by David Blakely
We urge the City to insure that in addition to analyzing and considering mitigations for potential impacts on traffic,
greenhouse gas emissions, air quality, biological resources, land use/planning and all other areas identified in the Initial
Study as requiring evaluation, the EIR fully analyzes and mitigates the cumulative impacts likely to arise in those
categories from all of the above projects and any others that are likely to be developed within the approximate timeframe
of the Froom Ranch Specific Plan.
Thank you for inviting us to comment,
4
Andrew Christie, Director
Santa Lucia Chapter of the Sierra Club
P.O. Box 15755
San Luis Obispo, CA 93406
(805) 543-8717
From: Mila Vujovich-LaBarre <
Sent: Wednesday, July 26, 2017 12:26 PM
To: Advisory Bodies; E-mail Council Website; Lichtig, Katie
Cc: Harmon, Heidi; Pease, Andy; Gomez, Aaron; Rivoire, Dan; Christianson, Carlyn
Subject: Froom Ranch Scoping Meeting Concerns
To: Planning Commission - City of San Luis Obispo
Cc: San Luis Obispo City Council Members
Katie Lichtig - City Manager
Re: Froom Ranch Development
From: Mila Vujovich-La Barre
Date: July 26, 2017
RECEIVED
CITY OF SAN LUIS OBISPO
JUL 26 2017
COMMUNITY DEVELOPMENT
Dear Planning Commission Members -
Thank you for the opportunity to voice opinions about the Froom Ranch Development. Many of my
concerns were expressed during the Land Use Circulation Element (LUCE) meetings a few years ago and
at some recent meetings, due to the rush of development in the southern part of our city.
I wanted to express my concerns for your consideration and the public record.
From the publicity, it is my understanding that "John Madonna plans to transform 111 -acres in San Luis
Obispo into a $500 million mixed-use project that caters to the city's aging population. The proposed Froom
Ranch project includes a continuing care retirement community (CCRC) that offers 350 residential units for
seniors, 150,000-350,000 square feet of commercial retailers for its residents, 200 apartments and around
60-100 single-family detached units."
This particular developer has long and honorable ties to our community. It is my hope that he will realistically
adjust his development plans after this scoping meeting.
A development of this magnitude will drastically alter the traffic and the visual attractiveness of this part of
town.
As you all know, the Land Use Circulation Element (LUCE) was funded by a state grant that maximized
development in San Luis Obispo. It may have been good in theory for the majority of the LUCE members
who had a background or personal financial interest in development. However, the LUCE document - which
has become the blueprint for future development - did not take into consideration many realities. The
minority report from the LUCE highlights this and the fact that the LUCE process did not provide for
substantial public input.
My concerns about the Froom Ranch Development are primarily the following:
1.Water.
Where is the water for this development? City and County residents have been asked to conserve for
months and I do not see water levels increasing at the sources of our water for a development of this
magnitude. John Madonna has stated that, "The project would use some existing wells on the property and
draw from the city's reservoirs to satisfy its water needs."
2. Design
The continuing care retirement community (CCRC) that offers 350 residential units for seniors, will be an
asset. However, the proposed 200 apartments and 60-100 single-family detached units and commercial
space are not necessary. By changing this configuration, and just building the CCRC there will be no
need to encroach over the 150 foot height line established in the LUCE document.
3. Traffic
This upcoming generation may focus on walking, biking and bus travel out of respect for climate change,
however most people will still utilize a car. People in the surrounding neighborhoods and businesses of
Laguna Lake deserve an authentic study of what traffic will look like with this proposed development,
including the cumulative impacts of the traffic from San Luis Ranch and the traffic from the Avila
Ranch development.
They also deserve an authentic appraisal of parking for the Froom Ranch development.
Traffic flow from the existing proposed business development should also be part of that same study. If
John Madonna wants to include commercial development in the Froom Ranch development, that increased
traffic also needs to be factored in.
4. Prado Road.
As I wrote previously, the proverbial "elephant in the room" is Prado Road. For years now, people have
been asking whether Prado Road is going to be an interchange or an overpass. They have been asking
whether or not it a four -lane truck highway as it appears on the adopted LUCE plan.
Prado Road was indeed part of the updated Land Use Circulation Element (LUCE) Plan. Also, the LUCE
plan is cited in meetings as the rationale for immense and dense developments. Prado Road is also part of
the traffic circulation plan for San Luis Ranch and Avila Ranch. The public deserves to see the entire plan
and the inclusion of the Prado Road overpass or interchange. One cannot "cherry pick" the LUCE plan
and provide for just the parts that are "easy" and/or profitable. All of the support system should be
in place.
Since the developers are to date solely responsible for traffic/road improvements - their "fair share" - this
overpass or interchange, will substantially impact the cost of the projects being proposed.
City staff continues to entertain and even approve development without getting a clear answer on whether
or not the overpass or interchange is even viable. This is unconscionable.
A transparent, public discussion should occur with CALTRANS about the Prado Road interchange
and/or overpass with both the Planning Commission and City Council present as soon as possible.
Real financial figures and real measurements should be included at that meeting.
I have personally been on the course of the planned Prado Road with an old-fashioned tape
measure and elected officials, and made the point very clear that at certain points along the route -
Prado Road - as a "four lane truck highway" simply does not fit.
After a public meeting City staff and elected officials should insist that the traffic infrastructure - out of the
pocket of the developer - be completed either at the same time the development is being constructed or
prior to it.
The developer of San Luis Ranch has already received approval to build homes in the first phase in back of
Target and funnel all of the resulting traffic onto Froom Ranch Road and then onto Los Osos Valley Road.
This was not what was guaranteed in the LUCE and in public meetings.
The San Luis Ranch developer's representative has publicly quipped, "Who knows when the Prado Road
overpass will ever be built?" For those of us that care about "smart growth" and keeping one's word, that
statement is not comforting.
The construction of Prado Road cannot be an aft9rthought. According to CEQA, when "a larger
project is identified" - as in Prado Road from Madonna Road to Broad Street that has been on the
City Master Plan since 1960- it needs to have a comprehensive Environmental Impact Report (EIR)
and be evaluated on the merits of that study. Currently, city staff is allowing Prado Road to be
illegally segmented" or "piecemealed" which is in violation of CEQA.
As was mentioned in the previous Planning Commission meeting on San Luis Ranch, what happens when
people transit in cars over Highway 101 eastbound towards Broad Street. The "four -lane truck highway" -
Prado Road - will then cross South Higuera... and then what? Will traffic be funneled to two lanes through
Serra Meadows? Turn North or South onto South Higuera? We deserve to have these answers now.
5. Affordable housing and Workforce Housing
Affordable housing is proposed and the question is, "At what price?" The cost of road improvements needs
to be factored into the purchase price so that the developer can make a profit.
It would be good business sense to know where the workers for this CCRC will be living. Will they
be making a "living wage?" Most employees in these types of developments are making $12-$18 per hour.
There are only a handful of highly -paid doctors and therapists that will be employed. Let's analyze this ratio
ahead of time and discuss where the housing exists for these modestly paid workers.
6. Affordable housing vs. Student rentals.
Unless there is an opportunity for deed restrictions and/or strict "Conditions, Covenants and Restraints"
CC and R's) on the proposed homes and apartments, who is to say that the residential units will not be
turned into a mass of student rentals.
7. Noise
The noise from this development will need to be mitigated. The noise will be from the people and the
vehicular traffic. Currently that area has a rural atmosphere.
8. Trees and animal protection
Having viewed the preliminary plan, my attention is also on the fact that construction is on environmentally
sensitive areas. It is my hope that any development will be below the 150- foot line to preserve the view as
established in the LUCE. Even with that, it is my hope that any development will include as many trees and
preservation of the public viewshed of the foothills.
9. Access to existing commercial development and recreation
Since this is a scoping meeting, I would also like to see access to walking and biking trails be apparent. I
would also like to see access to public transportation for these seniors and future residents. Access to the
Laguna Lake recreational area has not been given the attention that it deserves.
Having looked at the preliminary plan, I would also like to see as many Class 1 bike paths in the
development to ensure the safety of residents and workers.
10.Public Input
As I mentioned at the LUCE meetings, it would serve the developer well to send a notice to the
neighborhoods that will be impacted and receive public feedback on the development.
11. Agricultural Land
wish that John Madonna could use a good portion of this land for grazing or crops. I mourn the demise of
local agricultural land in the name of infill. I believe that it is myopic for the sake of the next generation.
In closing, thank you for the opportunity to enumerate concerns now so that they can be addressed in the
near future.
Sincerely,
Mila Vujovich-La Barre
Mila Vujovich-La Barre
650 Skyline Drive
San Luis Obispo, CA 93405
1
Scott, Shawna
From:Salinantribe <salinantribe@aol.com>
Sent:Monday, July 31, 2017 8:22 PM
To:Scott, Shawna
Subject:Froom Ranch Specific Plan Project
Greetings Scott, I have reviewed the proposed project and have no concerns at this time. Thanks, Patti Dunton, Tribal
Administrator
Sent from my iPhone
Bicycle Advisory Committee
July 30, 2017
Draft
-Safe, convenient and consistent bicycle-pedestrian access through Irish Hills Plaza to
Froom Ranch Road, preferably a multi-use trail along the western edge of the plaza so
bicyclists and pedestrians can avoid maneuvering through the parking lots. This trail
would enable pedestrians and people on bikes to shop at Irish Hills Plaza without
having to travel on Los Osos Valley Road; and to cross Los Osos Valley Road to
access bike/pedestrian improvements being constructed as part of the San Luis Ranch
development.
-Safe and convenient bicycle/pedestrian a ccess to C.L. Smith Elementary School and
Laguna Middle School for students and employees who live in the planned multi-family
units.
-Protected intersections on Los Osos Valley Road at Froom Ranch and Auto Park Way.
-Auto Park Way should be a complete street.
-Froom Ranch Road from Los Osos Valley Road to its terminus at the Irish Hills Open
Space should be a complete street.
-Fair share contribution to construct and connect these Bob Jones Trail segments to the
existing segment from Prado Road to Los Osos Valley Road: Los Osos Valley Road to
the Octagon Barn, a grade-separated crossing of Los Osos Valley Road under Highway
101 and the Prefumo segment from Oceanaire Drive to Calle Joaquin.
COUNTY OF SAN LUIS OBISPO
DEPARTMENT OF AGRICULTURE / WEIGHTS & MEASURES
Martin Settevendemie, Agricultural Commissioner / Sealer of Weights & Measures
2156 Sierra Way, Suite A | San Luis Obispo, CA 93401 | (P) 805-781-5910 | (F) 805-781-1035
slocounty.ca.gov/agcomm | agcommslo@co.slo.ca.us
DATE: August 4, 2017
TO: Shawna Scott, Associate Planner
FROM: Lynda L. Auchinachie, Agriculture Department
SUBJECT: Froom Ranch Specific Plan Notice of Preparation (1957)
Thank you for the opportunity to comment on the scope and content of the draft
environmental impact report (DEIR) for the Froom Ranch Specific Plan Project. In addition to the
issues identified in the initial study the following is recommended to be evaluated in the DEIR:
• The project includes annexation to the City of San Luis Obispo. The Cortese-Knox-Hertzberg
Local Government Reorganization Act’s definition of “prime agricultural land” should be
included as part of the evaluation of project impacts to agricultural resources. Prime
agricultural land as defined in Government Code 56064 includes:
“Prime Agricultural land” means an area of land, whether a single parcel or contiguous
parcels, that has not been developed for a use other than an agricultural use and that
meets any of the following qualifications:
a) Land that qualifies, if irrigated, for rating as class I or class II in the USDA Natural
Resources Conservation Service land use capability classification, whether or not land is
actually irrigated, provided irrigation is feasible.
Irrigation was determined to be feasible on the project site at the time the agricultural
easement offset was proposed and established for the Madonna-Gap annexation.
• How will the integrity of the existing agricultural easement be maintained with the
proposed development?
Thank you for your consideration. If you have questions, please call 781-5914.
From: Lea Brooks <leabrooks332@gmail.com>
Sent: Tuesday, August 01, 2017 11:50 AM
To: Fukushima, Adam
Subject: More Froom Ranch and Broad Street Bike Blvd
Hi Adam:
Regarding Froom Ranch scoping, I rode the west segment of Calle Joaquin today to KSBY and the Mountainbrook
Church at the top of the hill. The proposed secondary emergency access from Froom Ranch is a road to the
church. Planning Commission Chair Chuck Stevenson was concerned that this road would be closed unless there
is an emergency and expressed support for keeping it open and visible so residents of Froom Ranch will know of
its existence. It's surprisingly remote back there.
From a BAC perspective, I'm not sure if it's worthwhile to augment Chuck's concerns. This segment of Calle
Joaquin is definitely not a complete street. If the emergency road is open and residents use it, some
improvements to make it safer for bicyclists should be added. I didn't realize there is access to the Irish Hills Open
Space via the driveway to the church. Do you know if the driveway is part of the church property ‐ maybe the trail
access was a mitigation ‐ or a city maintained road? It looks more like a driveway, but you never know.
Regarding the bicycle boulevard: How can the BAC invite city council members on a tour to show the three
alternatives? As an advisory body, do we need to vote via e‐mail to offer a tour and can staff participate? I think a
tour would be really helpful to council members.
Thanks.
Lea
August 14, 2017
Emily Creel
Contract Planner and City Project Manager
SWCA
Shawna Scott
Associate Planner (Staff Liaison)
City of San Luis Obispo
RE: Froom Ranch Specific Plan Environmental Impact Report (Notice of Preparation)
Dear Ms. Creel and Ms. Scott:
This letter submits comments from the San Luis Obispo Council of Governments (SLOCOG) related to the
scope of the Environmental Impact Report (EIR) to be prepared for the subject project.
Many comments reference SLOCOG’s 2014 Regional Transportation Plan and Sustainable Communities
Strategy (2014 RTP-SCS). A link to this document, along with project references, is included at the end of
this letter.
Land Use/Planning
1. The site is not within an adopted Target Development Area of the 2014 RTP-SCS (p. 2-18).
2. The 2014 RTP-SCS’s Sustainable Communities Strategy (SCS, Ch. 2) includes policies that
support, among other things, reducing vehicle miles traveled (VMT) and related emissions
(SCS 4); compact, mixed-use, and infill development in Target Development Areas (SCS 5);
equitable, affordable housing (SCS 7); and protection of important farmland and valuable
habitats (SCS 14 and 15). These policies are related to CEQA impacts, including agricultural
resources, biological resources, transportation/traffic, climate change, and population and
housing.
Population/Housing
3. SLOCOG’s 2050 Regional Growth Forecast (2017) found that San Luis Obispo County’s
housing market is the tenth-least affordable market in the country, and fourth-least
affordable small market in 2016 Q4 (National Association of Home Builders/Wells Fargo
Housing Opportunity Index [HOI]). Based on the HOI, only 21.1 percent of family households
could afford a median-priced home in the region in 2016 Q4 (see Figure 31, page 62). The
2014 RTP/SCS’s Sustainable Communities Strategy includes policy language that is
supportive of equitable, affordable housing… for people of all ages, incomes, races and
ethnicities to increase mobility and lower the combined cost of housing and transportation
(SCS 7).
The EIR should consider the potential impacts of not accommodating deed-restricted
affordable housing as part of the project. Not accommodating very low-, low-, and
moderate-income households may result in increased regional traffic congestion from
intercity commutes and an associated increase in vehicle-generated greenhouse gas
emissions.
Transportation/Traffic
US 101
4. The 2014 RTP-SCS (Figure 4-3, p. 4-11) projects the following LOS for US 101 between South
Higuera and Monterey:
a. 2010 peak hour: LOS F
b. 2035 PM peak hour: LOS F
The EIR should consider these projections as it evaluates the project’s impacts to freeway
LOS.
Prado Road
5. The 2014 RTP-SCS recommends construction of an overcrossing and interchange at Prado
Rd. (see “References” section at the end of this letter). The EIR should analyze the project
trip contribution to the anticipated Prado Rd. overcrossing and US 101-Prado Rd.
northbound ramp improvements discussed in the San Luis Ranch EIR (now certified) and
potential mitigations.
Senior transportation
6. The EIR should assess the availability of senior shuttle services, fixed-route bus service, and
other transportation services for seniors. It should consider a senior shuttle service or
contribution to existing senior shuttle services that would provide transportation from the
project to services in San Luis Obispo.
Transportation demand management
7. The EIR should consider transportation demand management (TDM), including
encouragement and education about non-single-occupancy-vehicle travel modes, as a
potential mitigation measure.
SLOCOG’s 2014 RTP-SCS MSE Policy 3 states: “Assist local jurisdictions in developing communities in
ways that reduce the demand on the roadway system by coordinating residential, commercial and
industrial development in ways that reduce the need to drive”.
Multi-modal access
8. The number of internal capture trips assumed in the multimodal transportation study’s trip
generation calculations will affect the projected net external auto trips into and out of the
site. In addition to internal capture, given the substantial amount of retail in the vicinity, the
potential for some external trips to be walking and cycling should be studied. Residents may
be more likely to make those trips if the development’s layout, sidewalks, and bike facilities
offer convenient, safe, and low-stress connections to the adjoining retail.
9. The EIR should include a consideration of how potential connections to existing and
proposed future sections of the Bob Jones Trail affect the proposed development’s traffic
impacts and possible mitigations. For example, the City is in the preliminary engineering
phase of two trail segments: the Oceannaire-to-Calle Joaquin / Prefumo Creek Connector
and the Los Osos Valley Rd.-to-Octagon Barn segment. Currently, Class II bike lanes exist on
Los Osos Valley Rd. between the proposed project site and the expected intersection of the
LOVR-Octagon Barn segment. The City will be making bike lane and bike-vehicle conflict
area striping upgrades as part of its repaving project, underway at the time of this writing.
San Luis Obispo County will soon commence the plans, specifications, and estimate (PS&E)
phase for the County segment between Octagon Barn and the existing trailhead on Ontario
Road. Taken together, these segments, once built, will fulfill a vision of having a bikeway
from the City of San Luis Obispo to the Pacific Ocean that is almost completely separated
from motor vehicle traffic.
10. Assess the impacts of potential use of existing and proposed open space in the vicinity of
the development, including the potential need for a public parking lot/staging area to
enhance access to trails.
Please let me know if you have any questions or need more information: 788-2104 or
jbrubaker@slocog.org.
Sincerely,
Jeff Brubaker, AICP
Transportation Planner
References
SLOCOG 2014 Regional Transportation Plan and Sustainable Communities Strategy (2014 RTP-SCS)
http://www.slocogconnectingcommunities.com/
SLOCOG 2050 Regional Growth Forecast
http://www.slocog.org/programs/data-services/regional-growth-forecast
2014 RTP-SCS project references
Froom Ranch Way, Bob Jones Trail: Prefumo Creek Connection
1. CEN-RORS-1013: Froom Ranch Way extension: end of Froom Ranch Way to Dalidio Dr.
2. CEN-AT1-1014: Bob Jones Trail: Prefumo Creek bike path connector [Madonna Rd. to US
101]
United States Department of the Interior
IN REPLY REFER TO:
OSEVEN00-2017-CPA-0183
FISH AND WILDLIFE SERVICE
Ventura Fish and Wildlife Office
2493 Portola Road, Suite B
Ventura, California 93003
Shawna Scott, Associate Planner
Community Development Department
City of San Luis Obispo
919 Palm Street
San Luis Obispo, California 93401
August 14, 2017
Subject: Notice of Preparation of a Draft Environmental Impact Report for the Froom
Ranch Specific Plan Project, San Luis Obispo County, California
Dear Ms. Scott:
This letter provides the U.S. Fish and Wildlife Service's (Service) comments on the Notice of
Preparation (NOP) regarding the Draft Environmental Impact Report (DEIR) for the subject
project area located within unincorporated San Luis Obispo County immediately west of Los
Osos Valley Road between U.S. 101 and the Irish Hills Plaza. The 110-acre project includes a
Specific Plan, General Plan Amendment, and related actions that would allow for the
development of the Froom Ranch Specific Plan Area (SPA) identified in the City of San Luis
Obispo's General Plan. Completion of a Specific Plan is necessary before the project area can be
annexed into the City of San Luis Obispo. Project elements would consist primarily of residential
uses with some commercial development adjacent to Los Osos Valley Road and the existing
Irish Hills Plaza.
The Service's responsibilities include administering the Endangered Species Act of 1973, as
amended (Act), including sections 7, 9, and 10. Section 9 of the Act and its implementing
regulations prohibit the taking of any federally listed endangered or threatened species. Section
3(19) of the Act defines "take" to mean "to harass, harm, pursue, hunt, shoot, wound, kill, trap,
capture, or collect, or to attempt to engage in any such conduct." Harm is further defined by the
Service to include significant habitat modification or degradation that results in death or injury to
listed species by significantly impairing essential behavioral patterns, including breeding,
feeding, or sheltering. Harass is defined by the Service as intentional or negligent actions that
create the likelihood of injury to a listed species by annoying it to such an extent as to
significantly disrupt normal behavioral patterns which include, but are not limited to, breeding,
feeding, or sheltering. The Act provides for civil and criminal penalties for the unlawful taking
of listed species. Exemptions to the prohibitions against take may be obtained through
coordination with the Service in two ways. If a project is to be funded, authorized, or carried out
by a Federal agency, and may affect a listed species, the Federal agency must consult with the
Service pursuant to section 7(a)(2) of the Act. If a proposed project does not involve a Federal
Shawna Scott 2
agency but may result in take of a listed animal species, the project proponent should apply to the
Service for an incidental take permit pursuant to section lO(a)(l)(B) of the Act.
According to the NOP, the DEIR will identify and evaluate potentially significant impacts,
whether direct or indirect, that may result from Project implementation. It will also determine
whether mitigation measures and/or alternatives can be implemented that would mitigate such
impacts to a level that is less than significant. The NOP identifies a number of environmental
issues that will be analyzed in the DEIR, one of which is biological resources. Of particular
concern to us is the presence of Chorro Creek bog thistle ( aka Chorro Creek fountain thistle;
Cirsiumfontinale var. obispoense), a federally-listed endangered plant, which has been
documented to occur onsite. We request an alternative that avoids impacts to this edaphic
endemic species and its necessary hydrology be considered in the DEIR.
Also of concern to us is the possibility of presence of two federally-listed threatened animal
species: California red-legged frog (Rana draytonii) and vernal pool fairy shrimp (Branchinecta
lynchi). We reviewed the evaluation for these species provided in the biological resource report
prepared for the proposed project (KMA 2016) but currently do not concur with its conclusion
that presence of either of these species is not likely. The data for vernal pool fairy shrimp is from
over 10 years ago and California red-legged frogs may use the ephemeral features identified as
drainages 1, 2, and 3 (KMA 2016) as well as Froom Creek for some portion of their life cycle.
Because there may be habitat suitable to support one or both of these species within the project
area habitat assessments for each, conducted in accordance with current Service guidance, should
be prepared for inclusion as appendices to the biological resources section of the DEIR.
We appreciate the opportunity to provide comments on the NOP for the Froom Ranch Specific
Plan Project DEIR and look forward to receiving the draft document, inclusive of all relevant
technical appendices and reports, during the public review period. If you have any questions
regarding our response to the NOP, please contact Julie M. V anderwier of my staff at (805) 677-
3400 or at julie _ vanderwier@fws.gov.
Sincerely,
.cf,, -;;1-�;itephen P. Henry
Field Supervisor
cc:
Brandon Sanderson, California Department of Fish and Wildlife
Reference Cited
KMA. 2016. Froom Ranch Project, San Luis Obispo County California. Biological Resources
Inventory prepared for John Madonna Construction, Inc. January