HomeMy WebLinkAboutLAFCO_Froom Ranch DEIRCOMMISSIONERS
Chairperson
LYNN COMPTON
County Member
Vice -Chair
TOM MURRAY
Public Member
DEBBIE ARNOLD
County Member
ROBERT ENNS
Special District Member
ROBERTA FONZI
City Member
MARSHALL OCHYLSKI
Special District Member
ED WAAGE
City Member
ALTERNATES
ED EBY
Special District Member
STEVE GREGORY
City Member
HEATHERJENSEN
Public Member
JOHN PESCHONG
County Member
STAFF
DAVID CHURCH
Executive Officer
BRIAN A. PIERIK
Legal Counsel
MIKE PRATER
Deputy Executive Officer
IMELDA MARQUEZ
Commission Clerk
LAFCO - San Luis Obispo - Local Agency Formation Commission
SLO LAFCO - Serving the Area of San Luis Obispo County
December 16, 2019
Ms. Shawna Scott, Senior Planner
Community Development Department
City of San Luis Obispo
919 Palm Street
San Luis Obispo, CA 93401
Subject: Comments Draft Environmental Impact Report (EIR) —
Froom Ranch Specific Plan
Dear Ms. Scott:
Thank you for the opportunity to comment on the draft Environmental
Impact Report for the Froom Ranch and Villaggio Life Plan
Community project. The Local Agency Formation Commission
LAFCO) is a Responsible Agency that may use this document for
consideration of a future annexation to the City. Thank you for taking
the time to discuss the project with us on December 9, 2019. The
meeting covered how the City intends to address protection of
important agricultural and open space lands as the project proceeds.
Please consider the following comments:
1. General Comment. The use of the Land Evaluation Site
Assessment Model for the definition of prime agricultural land
may not align with the Cortese -Knox -Hertzberg Act (CKH Act)
definition of prime agricultural land. It appears that when the
CKH definition of prime agricultural land is used, more prime
land would be converted under the current project plan. This
could represent a gap in the CEQA record and should be
addressed in the Response to Comments, Final EIR and the
Cities conditioning authority.
2. LAFCO's comments were submitted as part of the Notice of
Preparation process and were focused on the protection of
such lands. It is important to address this issue through either
mitigation measures or the City's conditioning authority. We
appreciate that the City will make an effort to meet the intent of
LAFCo's prime agricultural policies through the adopted
conditions of approval placed on the project.
Froom Ranch-EIR Page 2 of 2
Comments December 16, 2019
3. Upper Terrace. The alternative project being considered would no longer
develop the upper terrace area as originally proposed. In fact, this area would
be placed in a protective easement because of the important natural resources
and wildlife corridor habitat. This change would be consistent with LAFCO's
policies that call for this type of protection.
4. Reconfigured Agricultural Easement. The proposed reconfiguration of the
7.1 acres that are already under a conservation easement from the Gap
annexation appears to be consistent with the original condition.
5. Off -Site Protection Opportunities. LAFCO encourages the City and applicant
to look for an off -site opportunity to preserve prime agricultural land that meets
LAFCO's 1:1 preservation requirements. This was accomplished when San Luis
Ranch and Gap annexations were approved.
6. Open Space Easements. It is our understanding the Froom Ranch Specific
Plan will include all open space and protection areas within easements with
approximately 63% (74ac) of the site being preserved in conservation/open
space. This type of conservation effort is consistent with LAFCO's goals and
policies. As with prior annexations, the timing of the easements will be required
to be in place prior to LAFCO filing the final annexation (if approved) with the
state Board of Equalization.
We appreciate being contacted with regard to this project. If you have any
questions regarding these comments please contact Mike Prater or me at 805-781-
5795.
Sincerely,
00ZI
David Church
LAFCO Executive Officer
cc. Brian Pierik, LAFCO Counsel
Lynda Auchinachie, Agricultural Commissioner's Office