HomeMy WebLinkAboutBates 01698-02219 FroomRanchFEIR_compiledPart 2_ 3.15 MINERAL RESOURCES
Froom Ranch Specific Plan 3.15-1
Final EIR
3.15 MINERAL RESOURCES
This section describes existing mineral resources and analyzes the potential for the Project
to result in the loss of availability of a known mineral resource that is valuable regionally
or statewide, or of a locally important delineated mineral resource recovery site. A mineral
is a naturally occurring chemical element or compound formed from inorganic processes
(not biological in origin), with a definite chemical composition and orderly crystal
structure. Examples of minerals include metals, rock, sand, petroleum products, and
geothermal resources. Mineral deposits are important to many industries, including
construction, transportation, and chemical processing. Due to their importance for
construction purposes, the value of mineral deposits is enhanced by their close proximity
to urban areas; however, mineral deposits are endangered by the same urbanization that
enhances their value. The non-renewable characteristic of mineral deposits necessitates the
careful and efficient development of mineral resources to prevent the unnecessary waste of
these deposits due to exploitation and/or conflicts caused by land use decisions and
urbanization.
3.15.1 Environmental Setting
3.15.1.1 Regional Setting
There are a wide variety of mineral resources found in the County, although relatively few
minerals are currently extracted commercially. Quarries and mines in the San Luis Obispo
area produce basaltic stone for masonry, “red rock” for road base and surfacing, and
cinnabar, an ore of mercury. Petroleum, natural gas, mercury, gypsum, sand and gravel,
construction stone, and clay are also produced in the County. The primary factor in the
production of sand, gravel, and stone is local demand, and this activity is directly related
to growth trends and construction needs (County of San Luis Obispo 2010; City of San
Luis Obispo 2006).
The San Luis Obispo-Santa Barbara Production-Consumption Region is defined by the
California Department of Conservation as the 2,062 square miles in western San Luis
Obispo and Santa Barbara counties in which significant aggregate resources and active
operations exist (California Department of Conservation 2017b). Within the San Luis
Obispo-Santa Barbara Production-Consumption Region, mining sites are currently
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permitted for approximately 75 million tons of extraction, and there are an estimated total
of 10.7 billion tons of these resources present within the County. These resources cover an
estimated 40,895 acres. These estimates take into account existing land uses that preclude
mineral extraction (California Geological Survey 2011). The majority of extraction sites
are in the northern portion of the County.
3.15.1.2 Local Setting
The City has no active aggregate operations within its jurisdiction, and no quarry or mine
operations are pending reactivation or initiation (California Geological Survey 2011; City
of San Luis Obispo 2006). A petroleum company’s request in the 1980s to explore City-
owned land in the Lopez Lake area was denied based on the environmental qualities of the
area. Since that time, no other such requests have been received (City of San Luis Obispo
2006).
There are very few active mining sites in the San Luis Obispo area surrounding the Project
site. The Alberti Ranch Red Rock Quarry, located approximately 3.5 miles north of the
Project, is permitted for 5 acres of disturbance and mining for shale production. The
Mainini Home Pit, located approximately 6.5 miles northwest of the Project, is permitted
for mineral production but is considered idle as of 2017. The Beecham Red Rock Pit is
located approximately seven miles west near Los Osos (California Department of
Conservation 2017).
3.15.1.3 Project Site
A 5.5-acre permitted red rock quarry is located in the northwestern portion of the Project
site (see Figure 2-2). The quarry is known to have been mined for red rock as early as 1936.
The quarry is permitted under the Surface Mining and Reclamation Act (SMARA; Mine
ID; 91-40-0024) and has an associated reclamation plan and performance bond in place
with the County (California Department of Conservation 2017a). Under the SMARA
permit, the red rock quarry has no set limit to its approved production amount either
annually or gross; rather, the production limits are set by the permitted area boundaries,
which means the SMARA permit would expire once the boundaries of the permitted mine
area are reached. As of December 2017, approximately 0.5 acres of the quarry have been
reclaimed in accordance with the quarry’s approved reclamation plan; no areas are
currently undergoing reclamation. Mining continued within the remaining portions of the
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quarry, and in 2017, two acres of the quarry were disturbed for mining purposes. The quarry
is also currently used for concrete and asphalt recycling, temporary stockpiling, and a
construction office. Historically, the property was also mined for chromium during World
War II, though precise locations are unknown and these operations ceased following the
end of the war (FirstCarbon Solutions and Chattel, Inc. 2017). To date, up to five acres of
the permitted quarry area continue to be
disturbed for mining and construction
equipment and materials staging
purposes, while approximately 0.5 acre
has been reclaimed in accordance with
the approved reclamation plan with the
County (California Department of
Conservation 2017a).
The onsite quarry, including the current
ancillary construction activities, are
permitted and monitored annually by
the County, most recently in December
2017. The County recognizes the quarry as the Froom Ranch Pit, but the quarry is not
currently acknowledged in the County General Plan or specifically in the California
Department of Conservation’s designated San Luis Obispo-Santa Barbara Production-
Consumption Region; however, the Froom Ranch Pit is included in the proposed Mining
Designation Amendments for the Conservation and Open Space Element of the County’s
General Plan. These proposed amendments include the Project site as an Energy and
Extractive Area combining designation (EX) and would include a Mining Disclosure
Rezone area of 0.25 mile around the quarry (see Section 3.15.2, Regulatory Setting, for
more information). These proposed amendments are currently in draft form.
3.15.2 Regulatory Setting
State and local laws, regulations, plans, or guidelines that are potentially applicable to the
Project are summarized below.
The 5.5-acre permitted red rock quarry located within
the Project site is also permitted to store soil and
aggregate along with construction equipment.
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3.15.2.1 State
Surface Mining and Reclamation Act (SMARA)
SMARA is the primary regulator of onshore surface mining in the state. It delegates
specific regulatory authority to local jurisdictions. The Act requires the State Geologist
(California Geological Survey) to identify and classify all mineral deposits in the state
based on their local, regional, and state significance. Local jurisdictions are required to
enact specific procedures to guide mineral conservation and extraction at specific sites, and
to incorporate mineral resource management policies into their general plans, as well as
address mine waste management, closure, site cleanup, and restoration requirements.
Specifically, Section 3712 of the State’s Mine Reclamation Statutes and Regulations
require that all mine waste be handled and disposed of consistent with the State Water
Resources Control Board mine waste disposal regulations in Article 1, Subchapter 1,
Chapter 7 of Title 27 of the California Code of Regulations. A key concern of state
legislators in enacting SMARA was addressing the loss of mineral production sites as a
result of development practices that might preclude future extraction.
Mineral Resource Zones
SMARA Sections 2761(a) and (b) and 2790 provide for a mineral lands inventory process
termed Classification-Designation. The California Geological Survey and the California
State Mining and Geology Board are the state agencies responsible for administering this
process. The primary objective of the process is to provide local agencies, such as cities
and counties, with information on the location, need, and importance of minerals within
their respective jurisdictions. It is also the intent of this process, through the adoption of
general plan mineral resource management policies, that this information be considered in
future local land use planning decisions.
Areas are classified on the basis of geologic factors, without regard for existing land use
and land ownership for each Production-Consumption Region. The mineral resource areas
within the San Luis Obispo-Santa Barbara Production-Consumption Region are
categorized into one of four Mineral Resource Zones (MRZs), described below (California
Department of Conservation 1989).
MRZ-1: A Mineral Resource Zone where adequate information indicates that no
significant mineral deposits are present or likely to be present.
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MRZ-2: A Mineral Resource Zone where adequate information indicates that
significant mineral deposits are present, or a likelihood of their presence and
development should be controlled.
MRZ-3: A Mineral Resource Zone where the significance of mineral deposits
cannot be determined from the available data.
MRZ-4: A Mineral Resource Zone where there is insufficient data to assign any
other MRZ designation.
3.15.2.2 Local
City of San Luis Obispo Zoning Ordinance
The City Municipal Code, Title 17 Zoning Regulations, establishes allowable uses by
zoning district within the City. As the Project would be subject to City Municipal Code
upon annexation, these Zoning Regulations would apply to the Project site, including
Section 17.10.020.F Prohibited Uses, which prohibits mineral extraction and commercial
mining in all zones.
County of San Luis Obispo General Plan
The County General Plan designates mineral resources within the EX Area combining
designation in the Framework for Planning (Inland) (i.e., the County’s Land Use Element
equivalent). Mineral resources are also addressed in the County’s Conservation and Open
Space Element. Combining designations identify areas with characteristics that are either
of public value or are hazardous to the public. The special location, terrain, man-made
features, plants or animals of these areas create a need for more careful project review to
protect those characteristics, or to protect public health, safety and welfare. EX combining
designations are established to recognize the importance of continuing availability of
mineral and energy resources by avoiding land use decisions that may inhibit the
continuing viability of energy and extractive operations and result in unnecessary or
premature termination of the use of such resources. The EX combining designation is
intended to:
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1. Identify areas where mineral or petroleum extraction occurs, is proposed to occur,
or where petroleum or mineral reserves of statewide significance exist, as defined
by the State Geologist.
2. Protect existing extraction areas so that land uses incompatible with continuing
extraction activities will not be developed on adjacent properties.
3. Protect existing energy production areas and regional production facilities so that
incompatible uses will not be developed on adjacent properties such that the energy
production facilities may become dangerous or detrimental to public health and
safety.
4. Protect energy production areas from encroaching urban development or other
incompatible land uses that may hinder their continued operation.
The existing onsite quarry, or Froom Ranch Pit, is not currently identified by the County’s
General Plan as a specific mapped mineral resource and is not within an EX combining
designation.
Draft EX Combining Designations Amendments
The County is currently updating the EX combining designations and has included the
Froom Ranch Pit as a part of this proposed amendment. The proposed update would
incorporate recent updates by the California Mining and Geology Board. These proposed
amendments adjust boundary maps of regionally significant Mineral Resource Areas, EX
designated areas, and Mining Disclosure Zones (MDZ) throughout the County. For EX
designated areas, the proposed amendments also include a MDZ combining designation,
which would apply to a 0.25 mile buffer around legally established mining activities that
is intended to serve as a means of notification and public disclosure for landowners and the
general public within the vicinity of the mine. The proposed amendments would designate
the Froom Ranch Pit within the EX combining designation and apply a 0.25 mile MDZ to
the site. While a portion of the Project site would be designated MDZ under the County’s
draft amendments, there are no proposed specific restrictions for this designation. The
proposed amendments are expected to be reviewed and adopted by the County Board of
Supervisors in spring 2020 (Cody Scheel, San Luis Obispo County Planner 2019).
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Froom Ranch Specific Plan 3.15-7
Final EIR
Despite these EX combining designation amendments and designation of the Froom Ranch
Pit, the Draft FRSP is being evaluated under the City’s regulatory framework in
anticipation of annexation of the site. The City and County have coordinated on this issue
and have agreed that the proposed EX combining designation amendments would not apply
to the Project site in the event of an annexation.
3.15.3 Environmental Impact Analysis
3.15.3.1 Thresholds of Significance
With respect to mineral resources, applicable sections of Appendix G of the CEQA
Guidelines provide that a project would have a significant impact on the environment if it
would:
a) Result in the loss of availability of a known mineral resource that would be of value
to the region and the residents of the state;
b) Result in the loss of availability of a locally important mineral resource recovery
site delineated on a local general plan, specific plan or other land use plan.
3.15.3.2 Impact Assessment Methodology
This section evaluates the impact of the Project on the availability of significant mineral
resources within the region and state. Regional importance of the onsite quarry was
determined by reviewing proposed amendments to the County EX combining designation,
as well as associated boundary maps. Production levels for concrete aggregate in the San
Luis Obispo-Santa Barbara Production-Consumption Region were determined by the
Mineral Land Classification Update published by California Geological Survey.
Production and capacity levels of the onsite quarry were determined using SMARA Permit
Annual Reports for 2018. Permitted land uses within the City were determined using the
City’s Zoning Ordinance.
3.15.3.3 Project Impacts and Mitigation Measures
Impacts to mineral resources associated with the Project are summarized in Table 3.15-1
below.
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3.15-8 Froom Ranch Specific Plan
Final EIR
Table 3.15-1. Summary of Project Impacts
Mineral Resources Impacts Mitigation Measures Residual Significance
MN-1. Project implementation would result in
the loss of the existing onsite red rock quarry
(Froom Ranch Pit)
None required Less than Significant
Impact MN-1 Project implementation would result in the loss of the existing
onsite red rock quarry (Froom Ranch Pit) (Less than
Significant).
Current operations at the onsite quarry are limited to asphalt and concrete recycling and
stockpiling, though the SMARA permit is active and approximately five acres of
unreclaimed area remains available for red rock mining. Although the quarry has
historically mined red rock for use in regional construction projects, it is not planned to be
utilized for further production. Despite general cessation of red rock production, the quarry
is included in the County mining designation amendments because the owner continues to
hold an active SMARA permit, reclamation plan, and performance bond, and currently
uses the 5.5-acre quarry area for aggregate recycling and construction storage activities.
The Project would reclaim the existing quarry site consistent with the SMARA permit
reclamation plan (including grooming and reseeding the area with pasture mix) and then
develop up to 130 units of medium-high density multi-family housing within the Madonna
Froom Ranch area of the site. Reclamation would occur during Phase 1 of Project
construction and, consistent with the quarry’s reclamation plan (County of San Luis Obispo
1980), would include removal of excess materials and waste, recontouring, topsoil
replacement, and hydroseeding with native grasses and fertilizers. Reclamation would be
financed by the independently held performance bond that guarantees funds would be
available.
Proposed annexation of the quarry site into the City would result in the prohibition of
continued mining activities, consistent with the City’s Zoning Ordinance. Although the
quarry is considered a mineral resource by the state and County, mining is not allowed
within the City and the quarry would no longer be usable for mineral production. When the
mine closes and the reclamation plan is completed, the quarry would no longer be subject
to ongoing permitting or regulation by the state and would not be subject to the mineral
resources policies of the County.
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3.15 MINERAL RESOURCES
Froom Ranch Specific Plan 3.15-9
Final EIR
The impact of the Project on available resources within the region and state would be
minimal. There is no current or expected future red rock production from the 5.5-acre
quarry, and further mining would be prohibited under the Project following annexation to
the City. Available acreage for onsite mineral production is 0.01 percent of the 40,895 acres
available within the Production-Consumption Region for this resource, which is a nominal
loss of mineral production to local and state needs. There are also local sources of red rock,
including the Alberti Ranch Red Rock Quarry and the Beecham Red Rock Pit, that would
continue to produce this particular mineral to meet local and regional demand. This
nominal reduction in available acreage for red rock extraction that would result from the
Project would be less than significant.
3.15.3.4 Cumulative Impacts
The Project would not result in effects that, when considered in combination with the
impacts of nearby regional projects, would be considered significant. The City does not
allow mineral resource extraction and there are no other proximate active mines identified
for future annexation into the City. Therefore, there are no projects within the City that are
expected to further reduce currently available supplies. The County’s proposed mining
designation amendments would adjust EX combining designations to reflect state-
designated regionally significant mineral resources and would help prevent closure and
elimination of these sites. The County’s Infrastructure and Facilities Capital Improvement
Plan does not indicate expectation of any projects that would impact availability of mineral
resources or mineral resource recovery sites. Therefore, the Project is not expected to result
in significant cumulative impacts to mineral resources or mineral resource recovery sites.
Potential cumulative impacts would be less than significant.
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Froom Ranch Specific Plan 4-1
Final EIR
4.0 OTHER CEQA ISSUES
This chapter presents the evaluation of additional environmental impacts analyses required
by CEQA that are not covered within the other chapters of this EIR, including significant
unavoidable environmental effects of the Project, irreversible environmental changes,
growth inducing impacts (including removal of obstacles to growth), and resource areas
that are found not to be significant. Section 15126 of the CEQA Guidelines requires that
all aspects of a project must be considered when evaluating its impact on the environment,
including planning, acquisition, development, and operation. Accordingly, in addition to
the analysis provided in Chapter 3, Environmental Impact Analysis and Mitigation
Measures, this EIR must identify growth inducing impacts and significant irreversible
environmental changes that would potentially result from implementation of the Project.
4.1 IRREVERSIBLE ENVIRONMENTAL IMPACTS
CEQA Guidelines, Section 15126.2(d) requires evaluation of irretrievable commitments of
resources to assure that such consumption is justified. This includes use of nonrenewable
resources, the commitment of future generations to similar uses, and irreversible damage
that can result from environmental accidents associated with the Project.
The Project would facilitate the construction of new buildings and paved surfaces,
involving consumption of building materials and energy, some of which are nonrenewable
or locally limited natural resources (e.g., fossil fuels and wood). Non-renewable resources
utilized for the Project could no longer be utilized for other purposes. Consumption of
building materials and energy is associated with any development in the region, and these
commitments of resources are not unique or unusual to the Project. The Project would
represent an incremental commitment to long-term use of non-renewable resources,
particularly gasoline for increased automobile use and oil, coal, and natural gas for power
generation (see also, Section 3.14, Utilities and Energy Conservation). Although not
unique to the Project, the automobile-oriented nature of the Project would result in it being
a larger energy consuming development, particularly for gasoline, than most current
projects in the City (see also, Section 3.0.3, Cumulative Impacts Analysis for discussion of
cumulative projects). In addition, as discussed in Section 3.3, Air Quality and Greenhouse
Gas Emissions, use of each of these forms of non-renewable energy would contribute to
the generation of GHGs with an incremental contribution to global climate change. To help
alleviate impacts to non-renewable resources, the Project would meet or exceed the
requirements of the California Building Code (CBC) and California Title 24 in effect at the
time of construction, and would comply with the City’s green building certification system
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4-2 Froom Ranch Specific Plan
Final EIR
and City Conservation and Open Space Element (COSE) Policy 5.5.7, which outlines
energy efficiency and green building certifications in new development. Proposed
sustainable site design and development practices would include water conservation
measures, efficient appliances, and energy conscious heating and cooling systems to offset
new energy demand. Moreover, the Project is proposed to include native and non-invasive
drought tolerant plant materials to conserve water. These sustainable building features
could reduce new energy demand and the consumption of water and non-renewable fossil
fuels. Consumption of these resources would occur with any development in the region
and are not unique to the Project.
As described in Section 3.2, Agricultural Resources, implementation of the Project would
irreversibly commit approximately 47.6 acres of prime (if irrigated) soils designated as
Farmland of Local Potential by the California Department of Conservation to residential
and other development. The Project would commit future generations to similar uses within
the Specific Plan area. The irretrievable commitment of this site for these uses is mitigated
through compliance with City LUE Policies 1.8.1, Open Space Protection, and 1.9.2, Prime
Agricultural Land, which require permanent protection of offsite agricultural lands of equal
area and quality to be put into an agricultural conservation easement via mitigation measure
MM AG-1.
The Project would not be expected to result in environmental accidents or upsets that have
the potential to cause irreversible damage to the natural or human environment; however,
the potential for wildfire is exacerbated by the Project (see also, Section 3.7, Hazards,
Hazardous Materials, and Wildfires). While recovery from wildfire damage involves
rebuilding and restoration of damaged areas, which would ultimately correct the effect on
the natural and human environment, there is a possibility that wildfire may result in the
permanent loss of structures or natural features (e.g., sensitive habitats and species, heritage
and other mature trees), which would be potentially irreversible. The commitment of these
resources for Project development has been planned for and would achieve implementation
of the City’s General Plan.
4.2 GROWTH-INDUCING IMPACTS
Section 15126.2(e) of the CEQA Guidelines requires a discussion of how the Project could
foster economic or population growth, or the construction of additional housing (either
directly or indirectly) in the surrounding environment. Induced growth is distinguished
from the direct economic, population, or housing growth of a project. Induced growth is
any growth that results from new development that would not have taken place in the
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Froom Ranch Specific Plan 4-3
Final EIR
absence of the project and that exceeds planned growth. CEQA Guidelines also state that
growth in any area should not be assumed to be necessarily beneficial, detrimental, or of
little significance to the environment.
Growth-inducing impacts are caused by those characteristics of a project that tend to foster
or encourage population and/or economic growth. The Project could result in five types of
growth-inducing impacts: 1) the creation of short- and long-term employment
opportunities which draw newcomers to the region and increase economic growth; 2)
increase in residential population from development of new residential development; 3) the
generation of new commercial and tourist accommodations to entice people to the area; 4)
expansion of utilities and infrastructure; and 5) removal of an obstacle to future
development.
1) As discussed in Section 3.11, Population and Housing, the Project would construct
174 multi-family housing units and 404 independent and 51 assisted living units
and provide approximately 332 full-time equivalent jobs, in addition to short-term
construction employment. Most of the Project’s labor force is expected to come
from the local labor pool; however, some workers may come from outside areas.
Therefore, there would be a minor increase in economic growth which would be
further minimized by the fact that new jobs created by the Project would may be
absorbed by existing residents or future residents of the City and Project.
2) The Project would result in the construction of up to 578 new units would result in
a residential population growth of approximately 1,231 persons. However,. Based
on the Applicant’s current deposit list, approximately 300 persons proposing to
reside at Villaggio once constructed are current City residents that would move
from and vacate their existing house (RRM Design Group 2019). Though future
residents of the Project are likely to be existing residents of the City, the action of
moving to the Project and vacating their homes has the potential to attract new
residents to the City from outside the existing population. Given this circumstance
and the fact that the origin of future residents of the Project cannot reliably be
forecasted, the Project is estimated to result in a residential population growth of
approximately 1,231 persons, as discussed in detail in Section 3.11, Population &
Housing. However, construction of 174 housing units within Madonna Froom
Ranch would help alleviate the City’s increased housing demand, and the
construction of 404 units within Villaggio would fulfill a specialized housing need
and is thus not considered growth-inducing as it would not foster the need for future
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Final EIR
construction of additional housing. Population growth within the City is directly
related to the increase in available housing supply, and the City’s LUE Policy
1.11.2 limits the City-wide increase in housing units to one percent annually,
excluding affordable housing (refer to Impact PH-1 in Section 3.11, Population and
Housing). Therefore, population growth in the City is already controlled through
General Plan policies that limit residential growth rates; the Project would be
subject to these residential growth rate limits.
3) The Project would attract visitor populations to the area, including overnight
visitors associated with the proposed 70,000-sf hotel. A new hotel development
could attract tourists and travelers to the area and generate additional revenue for
local businesses. Visitors may also come to Villaggio to stay with relatives.
Associated increases in visitors could potentially result in increased traffic and use
of public facilities and services and has the potential to incrementally induce growth
in the City.
4) As discussed in Section 2.4.4, Utilities and Services, the Project includes the
construction of water supply and wastewater collection systems for the Project site
that would tie into City systems. Further, the Project would allow for the extension
of roadways into the site, including two commercial collectors, as well as roadway
and intersection improvements on LOVR. The extension of roadways and
improvements would improve access and circulation within the immediate vicinity
of the site and would enable a future extension of Commercial Collector B to
connect to Irish Hills Plaza. Extension of utilities and roadways within the site
would not facilitate additional development along the hillside, particularly of the
undeveloped 7.39-acre parcel zoned retail commercial (C-R) and located north of
the Project site and adjacent to the Irish Hills Plaza. There is limited opportunity
for additional future development due to the expansion of utilities and services in
the Project area, as most undeveloped land surrounding the Project site is within
open space easements.
5) There is an undeveloped parcel in the immediate vicinity of the Project site, which
could experience development in the future due to the removal of an obstacle to
development brought about by the Project. A portion of the 7.39-acre parcel north
of the Project site is below the 150-foot elevation line and currently subject to City
LUE Policy 6.4.7, Hillside Planning Areas, which prohibits development above the
150-foot elevation within the Irish Hills Planning Area. The Project would amend
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Froom Ranch Specific Plan 4-5
Final EIR
Policy 6.4.7 to allow for development over the 150-foot elevation. This could open
the door for other future development in the Irish Hills area, specifically for the
7.39-acre parcel. However, all other adjacent lands surrounding the Project site are
already developed (e.g. hotels along Calle Joaquin), constrained by steep slopes and
existing development (Mountainbrook Church), or protected as open space lands
within the Irish Hills Natural Reserve by a 2010 conservation easement owned by
the Land Conservancy of San Luis Obispo; thus, these lands would not be affected
by the amendment to Policy 6.4.7.
4.3 EFFECTS FOUND NOT TO BE SIGNIFICANT
CEQA Guidelines state that the EIR shall contain a statement briefly indicating the reasons
that various possible significant effects of a project were determined not to be significant
and were therefore not discussed in detail in the EIR (Section 15128). After standard
regulatory conditions and/or mitigation measures are applied, several resource areas were
found to be below the level of significance, as identified in the Initial Study Checklist
(Appendix A). Effects found not to be significant and a brief explanation as to why is
included below.
4.3.1 Forestry Resources
No known forestry resources are associated with the Project site; therefore, no impact to
forestry resources would result from the Project.
4.4 SIGNIFICANT UNAVOIDABLE ENVIRONMENTAL EFFECTS
CEQA Guidelines, Section 15126.2(c) requires a description of any significant
unavoidable impacts resulting from implementation of a project, including impacts that
cannot be mitigated to below a level of significance. The Project was evaluated with respect
to specific resource areas to determine whether implementation would result in significant
adverse impacts. A detailed discussion of each of the impacts can be found in Chapter 3,
Environmental Impact Analysis and Mitigation Measures.
Specific significance thresholds were defined for each potential impact associated with
each resource area. Based on the environmental impact assessment presented in Chapter 3,
Environmental Impact Analysis and Mitigation Measures, of this EIR, the resource areas
of aesthetics and visual resources, air quality and GHGs, cultural and tribal resources,
hazards/hazardous materials and wildfire, land use and planning, noise, and transportation
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4-6 Froom Ranch Specific Plan
Final EIR
would result in significant impacts even after mitigation is applied to reduce the level of
impact.
Under CEQA Guidelines Section 15065, when an EIR demonstrates that implementation
of a proposed project will cause significant and unavoidable impacts, the agency must issue
a Statement of Overriding Considerations before approving the project. A Statement of
Overriding Considerations is a report of the lead agency’s findings regarding the merits of
approving a proposed project despite its significant environmental impacts and reflects the
balancing of competing public objectives. Therefore, the City will be required to adopt a
Statement of Overriding Considerations to address the significant impacts identified above
and discussed in detail in Chapter 3, Environmental Impact Analysis and Mitigation
Measures. In this instance, the City may weigh the long-term benefits of the Project, such
as fostering additional regional housing opportunities, including senior housing, against
potentially adverse impacts created by the Project. To facilitate consideration of these
issues, this EIR discloses potential impacts and provides a range of Project alternatives that
could more fully alleviate environmental concerns. In addition, Section 3.9, Land Use and
Planning, provides an overview of the City’s policy context, which provides information
on how the Project meets several important City policy objectives and where it may raise
concerns over consistency with other City policies. All this information should be reviewed
when considering this Project.
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Froom Ranch Specific Plan 5-1
Final EIR
5.0 ALTERNATIVES
5.1 INTRODUCTION
The California Environmental Quality Act (CEQA) Guidelines state that an
“Environmental Impact Report (EIR) shall describe a range of reasonable alternatives to
the project, or to the location of the project, which would feasibly attain most of the basic
objectives of the project but would avoid or substantially lessen any of the significant
effects of the project, and evaluate the comparative merits of the alternatives” (Section
15126.6).
The CEQA Guidelines state that “the range of alternatives required in an EIR is governed
by a rule of reason” that requires the EIR to set forth only those alternatives necessary to
permit a reasoned choice. The alternatives shall be limited to ones that would avoid or
substantially lessen any of the significant effects of the project. Of those alternatives, the
EIR need examine in detail only the ones that the Lead Agency determines could feasibly
attain most of the basic objectives of the Project (Section 15126.6).
In defining feasibility of alternatives, the CEQA Guidelines state that “among the factors
that may be taken into account when addressing the feasibility of alternatives are site
suitability, economic viability, availability of infrastructure, general plan consistency,
other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent
can reasonably acquire, control or otherwise have access to the alternative site” (Section
15126.6).
The alternatives must adequately represent the spectrum of environmental concerns in
order to permit a reasoned choice among alternatives. The document must also provide the
rationale for selecting or defining the alternatives evaluated throughout the document,
including the identification of alternatives that were considered by the Lead Agency but
rejected as infeasible during the scoping process.
The alternatives analysis for this EIR is presented in four sections. Section 5.2, Project
Objectives, describes the objectives of the Froom Ranch Specific Plan (FRSP) (Project).
Section 5.3, Summary of Significant and Unavoidable Impacts, summarizes the potentially
significant and unavoidable short- and long-term impacts of the Project from information
presented in Chapter 3, Environmental Analysis and Mitigation Measures. Section 5.4,
Alternatives Analysis, discusses potential impacts under the Project alternatives, including
a discussion of the alternatives considered but discarded. Section 5.5, Identification of
Environmentally Superior Alternative, concludes with the selection of an environmentally
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5-2 Froom Ranch Specific Plan
Final EIR
superior alternative, based on a Project configuration that results in the fewest significant
impacts and feasibly attains most of the Project objectives.
5.2 PROJECT OBJECTIVES
Section 15124(b) of the State CEQA Guidelines requires a statement of a project’s
objectives that includes the underlying purpose of the project. The major objectives of the
Project are described in Section 2.3, Project Objectives, and restated below.
1. Development of a mix of uses while protecting sensitive environmental resources and
maintaining public views of the Irish Hills.
2. Provision of a range of housing options, including workforce housing, senior housing,
and inclusionary housing.
3. Development of an economically feasible, healthy, safe, and secure Life Plan
Community that will serve residents 60 years of age and over.
4. Development of multi-family housing, including housing consistent with the adopted
City of San Luis Obispo (City) Inclusionary Housing Requirements in effect at the time
of the Specific Plan adoption.
5. Provision of commercial retail uses that complement residential uses and facilitate
pedestrian and bicycle access.
6. Provide site hydrology design to improve stormwater conveyance and management,
provide a restored riparian creek corridor, and enhance fishery habitat and biological
resource value.
7. Development of a public park that includes access and connection to existing trails in
the Irish Hills Natural Reserve and proposed trails within the Specific Plan area.
8. Reconstruction, rehabilitation, and adaptive reuse of architecturally significant historic
structures within a public park, in a setting and configuration that retains historic
integrity, while avoiding seismic impacts.
9. Establishment of a cohesive transportation and circulation network of collector and
residential roads, bicycle lanes, transit opportunities, and pedestrian sidewalks that is
integrated with and enhances the regional transportation system.
10. Incorporation of sustainability measures that meet or exceed the requirements of the
California Building Standards Code (Title 24) and California Energy Code (Part 6) in
effect at the time of construction, as well as provide onsite renewable energy facilities
and Electric Vehicle (EV) charging infrastructure in all land use types.
11. Avoidance of impacts to sensitive plant and wildlife species, such as the state and
federally-endangered Chorro Creek bog thistle (Cirsium fontinale var. obispoense).
01715
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-3
Final EIR
5.3 SUMMARY OF SIGNIFICANT AND UNAVOIDABLE IMPACTS
The Project would result in significant and unavoidable impacts to the following resources
areas: aesthetics and visual resources; air quality and greenhouse gas emissions; biological
resources; cultural and tribal cultural resources; hazards, hazardous materials, and
wildfires; land use and planning, noise; and transportation and traffic, as summarized
below.
5.3.1 Aesthetics and Visual Resources
Project development would result in significant impacts to the existing visual character of
the site by changing an open space and rural setting to a commercial and residential setting,
particularly as viewed from the Irish Hills Natural Reserve public trail system. As
demonstrated in key viewing areas (KVAs) 4 and 5 in Section 3.1, Aesthetics and Visual
Resources, the Project would develop up to 581 single and multi-family residences, senior
assisted living facilities, commercial uses, a trailhead park, roads, bicycle paths, and other
urban infrastructure that would eliminate existing high-quality scenic views. These new
uses would be highly visible from numerous public trails along the southeastern edge of
the Irish Hills Natural Reserve. Additionally, the Upper Terrace of Villaggio and portions
of the Madonna Froom Ranch area would be developed above the 150-foot elevation line,
an area that the City’s General Plan currently states should be secured as permanent open
space with no building sites above the 150-foot elevation in conjunction with any
subdivision or development of the lower areas. These portions of the Project would be the
only development above this line in the vicinity besides Mountainbrook Church, located in
the unincorporated County of San Luis Obispo (County). Implementation of required
mitigation measure MM VIS-1 would interrupt the contiguous massing of proposed multi-
family and commercial structures by requiring onsite native tree screening plantings,
although this would not sufficiently reduce the substantial damage to scenic resources
resulting from loss of open space and natural visual setting. Therefore, impacts to aesthetics
and visual resources under the Project would be considered significant and unavoidable.
5.3.2 Air Quality and Greenhouse Gas Emissions
During operation, air emission impacts from reactive organic gases (ROG) and nitrogen
oxide (NOx) as a result of vehicle trips, energy emissions, and additional area source
emissions associated with the Project would be significant and unavoidable. In accordance
with the San Luis Obispo County Air Pollution Control District’s (SLO County APCD’s)
CEQA Air Quality Handbook (as amended by the 2017 Clarification Memorandum), all
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5.0 ALTERNATIVES
5-4 Froom Ranch Specific Plan
Final EIR
standard mitigation measures and feasible discretionary mitigation measures would be
incorporated into the Project (see MM AQ-4). Many of these measures would be
incorporated as policies of the FRSP for which future development would be required to
implement and would manifest as site design measures which would reduce area source
emissions. Many other measures identified in MM AQ-4 emphasize transportation
strategies to reduce vehicle miles traveled (VMT) and associated mobile-source NOx
emissions. Incorporation of this mix of measures is considered feasible for the Project and
would substantially reduce operational ROG and NOx emissions. However, many measures
listed in MM AQ-4 do not contain quantifiable air quality emissions reductions for
programs under the FRSP. While implementation of these measures can feasibly reduce
ROG and NOx, the Project’s estimated emissions after implementation of these measures
cannot reasonably be quantified, and long-term operational residual impacts would remain
above the significance threshold identified in Section 3.3 Air Quality and Greenhouse Gas
Emissions.
The Project was also found to have significant and unavoidable impacts related to
consistency with the SLO County APCD’s 2001 Clean Air Plan. The design of the Project
would require relatively substantial changes to reduce inconsistency with overall land use
planning principles contained in the Clean Air Plan to less than significant. The Project
could hinder the County’s ability to attain the state ozone standard because the emissions
reductions projected in the Clean Air Plan may not be met. The anticipated population
growth and increase in vehicle trips associated with the Project is inconsistent with the
projections contained within the 2001 Clean Air Plan. Therefore, inconsistencies with
assumptions in the Clean Air Plan would remain significant and unavoidable, even after
implementation of MM AQ-4 and MM TRANS-5 and -8 through -10.
5.3.3 Biological Resources
Implementation of the Project would result in significant and unavoidable impacts to
biological resources. Construction and operation of the Project would impact sensitive
habitats and species, including sensitive riparian, wetland, and native grassland habitats,
migratory wildlife corridors, and sensitive and endangered species. The Project would
substantially impact 14 special status plant species, including the state and federally
endangered Chorro Creek bog thistle, and serpentine native bunchgrass and associated
habitat. Development within the Upper Terrace of Villaggio would have substantial
adverse effects on native grasslands and existing springs, seeps, and wetland habitats along
Drainages 1, 2, and 3, and associated wildlife corridors. The 5.81-acre wetland adjacent to
01717
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-5
Final EIR
Calle Joaquin, a federal jurisdiction wetland, could be significantly impacted through
modifications to site hydrology with the realignment of Froom Creek. Additionally,
development located between the realigned Froom Creek and upland grassland habitats
and drainages would have significant impacts on habitat connectivity and animal
movement corridors along the urban-rural interface of the City’s boundary. While
mitigation measures proposed in Section 3.4, Biological Resources, would minimize or
reduce adverse effects, impacts would continue to be substantial and are, therefore,
considered significant and unavoidable.
5.3.4 Cultural and Tribal Cultural Resources
The Project would result in significant impacts to onsite historic resources, including a
City-, state-, and federally-eligible historic district associated with the historic Froom
Ranch Dairy complex. The Project would result in a loss of three out of seven buildings
that contribute to the eligibility of the Froom Ranch Dairy complex for listing on the
National Register, California Register of Historic Resources (CRHR), and City Master List
of Historic Resources as a historic district. Though MM CR-9 through MM CR-14 would
reduce the severity of this loss, impacts to the potential Froom Ranch Dairy historic district
are considered significant and unavoidable.
5.3.5 Hazards, Hazardous Materials, and Wildfires
The Project would expose occupants to substantial wildfire hazards and would impair
emergency response to fires in the Irish Hills Natural Reserve. The Project site is located
in an area with moderate to very high fire hazard potential due to highly flammable
vegetation and fire-prone topography within the adjacent Irish Hills Natural Reserve, as
well as winds that periodically blow southeast downslope toward the Project site.
Additionally, the Project would utilize security fencing, retaining walls, and closely spaced
residential units in the western portion of Villaggio’s Lower Area that would limit access
for firefighters and vehicles to the wildfire interface. Although the Project would be
required to implement mitigation measures to reduce wildfire risks, occupants would still
be exposed to wildfire hazards and emergency response to a wildfire in the Irish Hills
would continue to be impaired by the Project as currently designed. Therefore, impacts
related to wildfire hazards would remain significant and unavoidable.
5.3.6 Land Use and Planning
The Project would substantially conflict with City General Plan policies for the protection
of visual, biological, cultural resources, and wildfire hazards. The Project would develop
01718
5.0 ALTERNATIVES
5-6 Froom Ranch Specific Plan
Final EIR
residential units above the 150-foot elevation line in Villaggio’s Upper Terrace, which
would be require a General Plan amendment and would be substantially inconsistent with
the General Plan Land Use Element (LUE) and Conservation and Open Space (COSE)
policies. These policies protect sensitive biological, open space, and visual resources,
including LUE Policies 1.8.6, Wildlife Habitats, and 6.4.7, Hillside Planning Areas, and
COSE Policies 7.3.1, Protect Listed Species, 7.3.2, Protect Species of Local Concern, and
9.2.1, Views to and from public places, including scenic roadways. Additionally, the
Project would relocate or demolish structures associated with the historic Froom Ranch
Dairy complex, a potential historic district under the City’s Historic Preservation
Ordinance and the CRHR. While mitigation measures would minimize these impacts,
potential adverse physical effects related to the potential inconsistencies with City policies
would remain significant and unavoidable.
5.3.7 Transportation and Traffic
Project traffic would exacerbate existing queuing and peak hour traffic congestion for
automobiles, and poor levels of service for pedestrian, bicycle, and transit modes of
transportation, causing transportation deficiencies in the Project vicinity, including Los
Osos Valley Road (LOVR) and U.S. Highway 101 (U.S. 101), resulting in significant
impacts. Although the Project would implement MM TRANS-2 and MM TRANS-12
through -18, which would require roadway improvements to improve multimodal facilities,
increase capacity, and alleviate queuing impacts, feasible mitigation is not available to fully
mitigate the Project impacts. Specifically, implementation of MM TRANS-6b requires the
completion of the Prado Road Overpass/Interchange project, which cannot be ensured by
this Project. Therefore, if Prado Road Overpass/Interchange project is not in place by
Project occupancy, impacts would be significant and unavoidable.
5.4 ALTERNATIVES ANALYSIS
This section discusses alternatives to the proposed Project, including alternatives which
were considered and discarded. Each of these considers the ability of a particular
alternative to comply with the City General Plan or substantially reduce or eliminate the
Project’s significant environmental impacts, while still meeting basic project objectives.
The EIR also includes a No Project Alternative and an analysis of possible alternative sites
that may not have the same environmental resource sensitivity as the selected project site.
Those alternatives carried forward for consideration and analysis include:
CEQA “No Project” Alternative;
01719
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-7
Final EIR
Alternative 1 – Clustered Development Below the 150-Foot Elevation Alternative
(Actionable Alternative)
Alternative 2 – Residential Development Project Alternative
Alternative 3 – Minimum LUCE-Compliant Alternative
5.4.1 Alternatives Considered but Discarded
CEQA Guidelines Section 15126.6(c) requires that an EIR disclose potential alternatives
that were considered and discarded and provide a brief explanation as to why such
alternatives were not fully considered in the EIR. As required by the State CEQA
Guidelines, the selection of alternatives includes a screening process to determine a
reasonable range of alternatives that could reduce significant effects but also feasibly meet
most of the Project objectives. If an alternative does not clearly provide any environmental
advantages compared to the proposed Project, meet key project objectives, or achieve
overall agency policy goals, it has been eliminated from further consideration.
Characteristics used to eliminate alternatives from further consideration include:
Failure to meet basic Project objectives;
Limited effectiveness in reducing Project environmental impacts;
Inconsistency with City policies regarding jobs/housing balance and provision of a
mix of housing types;
Potential for inconsistency with applicable plans and policies; and
Reasonableness of the alternative when compared to other alternatives under
consideration.
The following alternatives were considered but eliminated from further analysis by the
Lead Agency based on the above considerations.
5.4.1.1 Alternative Land Use Mixes – Increased Commercial Retail/Elimination of
Housing
Under this potential alternative, the site would not be developed with residential uses or
the Life Plan Community and would instead be developed with commercial retail uses
within the proposed developed portion of the site. Froom Creek would not be realigned,
and additional flood control improvements may be required to accommodate increased
runoff from additional impermeable surfaces and development. To accommodate increases
in personal and commercial vehicle trips to serve the commercial uses, a secondary access
road would also be constructed onto LOVR. Under this alternative, 50 percent of the site
would remain dedicated open space.
01720
5.0 ALTERNATIVES
5-8 Froom Ranch Specific Plan
Final EIR
This alternative would be inconsistent with the General Plan LUE performance standards
for the Project site and would not achieve a majority of the Project objectives, which
include the provision of a variety of housing types and provision of commercial uses that
complement residential uses. Further, development of the site solely for commercial uses
would not meet identified housing needs and would be inconsistent with City goals to
provide a mix of housing types and increase the City’s housing stock for residents. Further,
this alternative would likely result in increased impacts to traffic, roadway congestion, and
associated air quality due to the increased number of trips to and from the site. Therefore,
this option was considered and discarded, consistent with CEQA Guidelines Section
15126.6(c).
5.4.1.2 Maximum Buildout Consistent with the General Plan, including LOVR Bypass
Under this alternative, substantially less housing and substantially more commercial uses
would be developed on the site, consistent with the General Plan LUE and the existing
performance standards for the SP-3, Madonna on LOVR Specific Plan area. These
performance standards include a maximum of 350 residential units and 350,000 square feet
(sf) of commercial space with a minimum of 50 percent of the site designated for open
space. This alternative would not develop the site for a senior Life Plan Community as
envisioned under the Project. This change in land use could change the mix and type of
residential units, with a lower percentage of medium density units compared to commercial
uses than the proposed Project. Further, analysis of this alternative would include
consideration of planned transportation and traffic improvements (primarily the LOVR
Bypass) and the effects those improvements would have on allowable General Plan
buildout of the Project site and cumulative regional transportation. The LOVR Bypass
would present additional offsite environmental impacts in addition to site development
consistent with the General Plan.
However, this alternative would not meet several of the Project objectives, including
development of a Life Plan Community and development of a broader range of housing
options, including multi-family units, senior, and inclusionary housing. In addition, the
City has conducted a cost-benefit analysis for the LOVR Bypass and found that there were
little-to-no benefits to overall traffic circulation associated with the project to justify the
costs of the project and potential impacts to agricultural resources and riparian habitat.
Therefore, this potential alternative is not reasonable or feasible to mitigate environmental
impacts and this alternative has been considered and discarded, consistent with CEQA
Guidelines Section 15126.6(c). In addition, this alternative was already considered within
01721
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-9
Final EIR
the Land Use and Circulation Element (LUCE) Update EIR under the ‘Maximum
Circulation Improvement Alternative,’ which assessed both buildout of the Project site
under the General Plan scenario and development of the LOVR Bypass improvements.
Further detailed analysis of this alternative need not be reconsidered under this EIR.
5.4.1.3 Land Swap Alternative
Under this alternative,
development proposed within
Villaggio’s Upper Terrace would
be relocated below the 150-foot
elevation contour line. The Upper
Terrace area would be dedicated
open space and an emergency/trail
access easement would be
constructed from Mountainbrook
Church to the Villaggio Life Plan
Community development. To
accommodate relocation, building
density would be increased, along
with structure heights within the Lower Area of Villaggio. In addition, an approximately
10-acre area outside the Project site within the eastern edge of the Irish Hills Natural
Reserve and situated below the 150-foot elevation (referred to as the “land swap” area)
would be developed with R-3-SP zoned residential senior housing. On the Madonna Froom
Ranch portion of the site, this alternative would result in relocation of historic structures
and the proposed trailhead park to the upper northwestern corner of the Project site along
Froom Creek, while the four attached multi-family housing structures would be relocated
to the prior proposed trailhead park location. Further, this alternative would include
additional circulation improvements, such as an easement onsite for a Class I bike path that
parallels LOVR, a multi-modal roadway connection to Calle Joaquin, and a multi-modal
roadway connection to the Irish Hills Plaza from Mountainbrook Church. Consistent with
the General Plan development standards for the site, 50 percent of the site would remain
dedicated for open space.
While this alternative would relocate some development below the 150-foot elevation
contour in the Upper Terrace, structures would remain above this elevation and
development would intrude into 10 acres of the Irish Hills Natural Reserve in the Lower
Early consideration of alternatives to the FRSP included a
conceptual plan to “swap” land in the City-owned Irish
Hills Natural Reserve. In this considered but discarded
alternative, the Project would develop land at the base of
the Irish Hills Natural Reserve but would dedicate the
Upper Terrace to the City. This land swap was deemed
infeasible in consultation between the Applicant and the
City.
01722
5.0 ALTERNATIVES
5-10 Froom Ranch Specific Plan
Final EIR
Area. Increased density and building heights in the Lower Area of Villaggio to
accommodate relocation of proposed Upper Terrace development would result in similar
or incrementally greater obstruction of views of the natural hillsides of the Irish Hills. As
such, this alternative would continue to result in conflicts with the development standards
and policies of the General Plan LUE. While benefits would include increased multi-modal
connectivity to the Project site, reduced impacts associated with construction on slopes,
and greater avoidance of sensitive serpentine bunchgrass grasslands and the federally-
endangered Chorro Creek bog thistle (Cirsium fontinale var. obispoense), development
would not lessen or avoid significant impacts associated with air quality, greenhouse gas
(GHG) emissions, and transportation, and would conflict with conservation plans and
easements for the Irish Hills Natural Reserve. Further, acquisition of the proposed land
swap area would require modifications of a conservation easement held by The Land
Conservancy for San Luis Obispo County, an Open Space Easement held by the County of
San Luis Obispo, and restriction included in a Grant Agreement with The Nature
Conservancy. Acquisition of this land for development would directly conflict with those
plans, making acquisition of the land swap area infeasible. As such, this alternative was
considered and discarded, consistent with CEQA Guidelines Section 15126.6(c).
5.4.1.4 Low Density Upper Terrace Alternative
Under this alternative, development proposed within Villaggio’s Upper Terrace would be
substantially reduced to include four large-lot estates relocated below the 150-foot
elevation contour line. Each estate would include a 10-acre lot with a one-story single-
family home within a one-acre building envelope. Areas in the Upper Terrace outside the
estates would be dedicated open space. Access to the estates would be provided via a Calle
Joaquin and the driveway to Mountainbrook Church, where a new local road would
connect the estates then terminate at a cul-de-sac. The roadway would require three culvert
crossings of Drainages 1, 2, and 3. An emergency/trail access easement would be
constructed from the cul-de-sac to the Lower Area of Villaggio. Within the Lower Area
and Madonna Froom Ranch, no changes would be made compared to the Project.
While this alternative would reduce the density of development above the 150-foot
elevation contour in the Upper Terrace, structures and private yard space would remain
above this elevation. Estate lots would disturb approximately 40 acres in the Upper Terrace,
potentially impacting biological and cultural resources similar to the Project. Benefits
would include reduced impacts associated with construction on slopes, and greater
avoidance of sensitive serpentine bunchgrass grasslands and the federally-endangered
01723
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-11
Final EIR
Chorro Creek bog thistle (Cirsium fontinale var. obispoense). However, the area of
disturbance, including indirect impacts from private use of land during operation, would
continue to impact these resources. Further, while the reduced density would substantially
increase development setbacks from drainages, the estate lots would disrupt wildlife
corridors and habitat continuity in the Irish Hills. The reduced building density and heights
would reduce visual change in the Upper Terrace, but the development would remain
visible from public trails in the Irish Hills Natural Reserve. As such, this alternative would
continue to result in conflicts with the development standards and policies of the General
Plan LUE. Development would not substantially lessen or avoid significant impacts
associated with air quality, biological resources, GHG emissions, and transportation. As
such, this alternative was considered and discarded, consistent with CEQA Guidelines
Section 15126.6(c).
5.4.1.5 Alternate Site in City of San Luis Obispo
Alternate sites within the City were considered for development of the proposed Project.
Such sites would need to be large enough to accommodate the proposed Life Plan
Community, multi-family housing, commercial square footage, public park, and
requirement for 50 percent preservation of the site as open space (minimum 101.4 acres or
greater) and be undeveloped or underdeveloped. Very few sites within the City are large
enough to accommodate the proposed Project and those that do are already programmed
for development under the General Plan LUE. In fact, many larger sites are currently
undergoing concurrent development proposals, including the Avila Ranch Development
Plan (SP-4 Avila Ranch) and the San Luis Ranch Specific Plan (SP-2 San Luis Ranch).
Other large sites addressed within the General Plan LUE include properties in the County
that lie outside the City’s urban reserve line (URL) and may not align with City policies
and regulations.
Further, alternate locations in the City may also be constrained (e.g., presence of historic
resources, hazardous material site, etc.) in ways that would not permit the development of
the Project with fewer potential impacts, including aesthetics, hazards, traffic, noise, and
air quality. Alternate sites in the City are also not under ownership or management of the
Project Applicant, nor do they have an interest from Villaggio as candidates for the Life
Plan Community component. Because alternate locations are constrained in ways that
would not permit the development of the Project with fewer potential impacts, and the
alternate sites are not under the ownership or management of the Project Applicant and are
not currently available for development, alternate locations in the City were determined
01724
5.0 ALTERNATIVES
5-12 Froom Ranch Specific Plan
Final EIR
not to be feasible for development of the Project. Therefore, this alternative was discarded
from further consideration, consistent with CEQA Guidelines Section 15126.6(c).
5.4.2 Alternatives Carried Forward for Analysis
5.4.2.1 No Project Alternative
Under the No Project Alternative, no development or annexation of the site to the City
would occur, and the site would remain designated for agricultural and commercial uses
by the County. The site would continue to be designated as SP-3 of the City General Plan
and remain within the City’s Sphere of Influence, and all General Plan LUE requirements
for SP-3 for potential future development would remain applicable. No new development
or construction would occur under this alternative – for an analysis of development that
could be allowed under the current General Plan, see Alternative 3.
Under the No Project Alternative, the site would continue to be used as grazing land and
as a staging and operations site for the existing construction company. There would be no
disturbance to existing soils or vegetation, except for any ongoing grading permitted by the
County, and the site would remain as undeveloped open space. Froom Creek would not be
realigned or enhanced and no changes to existing stormwater conveyance and management
systems would occur. The existing wetlands and onsite stormwater detention basin would
remain. All structures associated with the Froom Ranch Dairy complex would remain in
place, would not be rebuilt or restored, and would continue to be utilized for construction
business operations (offices, equipment storage, etc.). Daily vehicle trips would remain
low/negligible associated with limited employee trips from the existing construction
business onsite.
Analysis – No Project Alternative
Under the No Project Alternative, a number of significant and unavoidable environmental
impacts would be avoided or reduced compared to the proposed Project, although
beneficial impacts to population and housing would also not occur. Impacts to aesthetics
and visual resources, biological resources, cultural and tribal cultural resources, noise, and
impacts to and/or from hazards would be substantially less when compared to the Project,
due to the absence of construction activities and operation of the Project. Mitigation
measures would not be necessary for these resource areas to avoid significant impacts
under this alternative. However, Froom Creek would not be enhanced or restored, and
existing historic structures would likely continue to deteriorate.
01725
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-13
Final EIR
Aesthetics and Visual Resources
This alternative would result in no impact to aesthetics and visual resources, as there would
be no new development of the site which would result in obstruction or degradation of
views of the Irish Hills or from the public trails within the Irish Hills Natural Reserve.
Agricultural Resources
This alternative would result in no impact to agricultural resources, as there would be no
development that would affect agricultural soils or conflict with existing agricultural
zoning. The No Project Alternative would not require reconfiguration of the existing
agricultural conservation easement and would not reduce the viability of existing or
potential agricultural operations onsite, including within the existing open space.
Air Quality and GHG Emissions
Impacts to air quality and GHG emissions within the Project site and immediate vicinity
would be reduced, as there would be no construction emissions under this alternative.
Continued dust generation from construction company operations (e.g., staging of
construction equipment, storage of fill material, site grading) would contribute to air
quality emissions; however, such emissions would be the same as existing conditions and
would be substantially less than the construction and operational emissions produced by
the Project. Further, as no new development would occur, this alternative would remain
consistent with the City and state goals for achieving carbon neutrality, and would be
consistent with the land uses and VMT traveled identified in the 2001 Clean Air Plan.
Biological Resources
Impacts to biological resources would be negligible and substantially less than under the
proposed Project. Existing wetland and riparian habitat and associated sensitive species
within the Project site would be subject to ongoing management practices, including
grazing and occasional maintenance and removal of wetland vegetation with the existing
stormwater detention basin. Realignment of Froom Creek would not occur and adjacent
unpermitted grading would need to be addressed. Froom Creek would also not be enhanced
with habitat for steelhead and riparian habitat areas. LOVR widening improvements would
not occur and would not impact Calle Joaquin wetlands or the LOVR ditch. Sensitive plants
species and habitats within the Upper Terrace would continue to be subject to low to
moderate impacts from horse and cattle grazing and would remain unprotected through any
01726
5.0 ALTERNATIVES
5-14 Froom Ranch Specific Plan
Final EIR
land protection mechanism. Compared to the Project, no mitigation measures would be
required to lessen the significance of impacts upon the site’s biological resources.
Cultural and Tribal Cultural Resources
Identified historic structures would remain in place under the No Project Alternative; no
structures would be rebuilt or restored and the main residence and some of the structures
would continue to be utilized for construction business operations (offices, equipment
storage, etc.). Permanent direct loss of structures composing a potential historic district
would not occur as a result of this alternative, although some historic structures would
continue to deteriorate. Impacts to buried or undiscovered cultural and archaeological
resources within the Project site would be avoided, although ongoing onsite activities
(mining, construction staging, grading) may impact such features.
While the No Project Alternative would not involve the physical alteration of any onsite
historic structures affecting their significance or eligibility, these historic resources would
not receive the same benefits as under the Project. Eligible historic structures/resources
would not be rehabilitated and preserved, nor would they be relocated outside the potential
active fault zone to more geologically stable locations. Under the No Project Alternative,
these resources would continue to be utilized for storage and construction business
operations, with no specialized maintenance or upkeep. As such, these structures may
further deteriorate and continue to be at risk of failure or collapse. Over time, the
deterioration of the structures may result in a loss of integrity while remaining on site and
a loss of the resource value entirely when deterioration results in removal of the structures.
Retention of these structures in their current place and status would not result in any
changes to the eligibility of the resources or the potential historic district in the short-term,
which would less impacts compared to the Project, but in the long-term, the No Project
Alternative would inevitably result in negligence of the buildings and eventual loss of
eligible structures. Therefore, impacts would ultimately be greater than under the Project.
Geology and Soils
Impacts to and from geologic and soil resources under the No Project Alternative would
be much less than under the proposed Project. No soil disturbance beyond existing
agricultural operations and ongoing period grading would occur. Implementation of this
alternative would not expose structures or persons to or create or exacerbate known or
potential geologic and soils hazards.
01727
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-15
Final EIR
Hazards and Hazardous Materials and Wildfire
Implementation of the No Project Alternative would not result in any impacts to hazards
and hazardous materials. This alternative would not construct new development that
exacerbates existing hazards and would not expose persons to existing hazards or
hazardous materials. This alternative would also avoid exacerbation of wildfire hazards,
by both reducing the potential for ignition and keeping residential land uses out of high fire
hazard areas at the urban wildland interface.
Hydrology and Water Quality
Implementation of the No Project Alternative would not result in any impacts to hydrology
or water quality. This alternative would not increase impermeable surfaces on the Project
site and would not result in the potential to expose surface and groundwater sources to
pollutants from construction and equipment. Froom Creek would not be realigned and
restored, the habitats within the Calle Joaquin wetlands and LOVR ditch would remain
similar to existing conditions, and the existing Irish Hills stormwater detention basin and
associated wetlands would remain in operation along with impacts of periodic maintenance
activities. However, this alternative would not result in alleviation or improvement of flood
conditions at the U.S. 101 box culvert. Compared to the Project, flood conditions under
this alternative would be worsened and result in greater impacts.
Land Use and Planning
Impacts to land use under this alternative would be less than those anticipated under the
proposed Project. The No Project Alternative would result in continued discrepancies
between the existing agricultural uses and the General Plan LUE intent for the area to
provide a substantial number of residential units, Neighborhood Commercial or Retail
Commercial uses, and preserved open space; however, the existing use would continue to
be consistent with the County General Plan. This alternative would result in less than
significant impacts related to consistency with General Plan LUE policies as no
development would conflict with policies relating to Froom Creek, development above the
150-foot elevation contour, and development on agricultural and biologically sensitive
lands. However, the City’s housing supply, particularly for senior units, would not be
expanded, and conflicts with Housing Element (HE) goals for provision of such housing
could potentially occur.
01728
5.0 ALTERNATIVES
5-16 Froom Ranch Specific Plan
Final EIR
Noise
The No Project Alternative would not result in any impacts related to noise. Under this
alternative, no construction or operational noise would be generated. Noise levels at the
site would remain similar to the existing setting at the Project site.
Population and Housing
Impacts to population and housing under this alternative would likely be greater than under
the proposed Project. Compared to the Project, this alternative would not result in
beneficial impacts to the housing supply nor assist in meeting the City’s Regional Housing
Needs Allocation targets. The No Project Alternative would not meet existing and future
housing needs or provide increased affordable housing opportunities. The jobs/housing
imbalance within the City, as described in Section 3.11, Population and Housing, would
continue or be exacerbated. Increased demand for housing within the City to support
employment and economic growth would continue. As a result, increasing numbers of
households may opt to find housing opportunities outside of the City, and would travel to
job opportunities within the City, as further discussed in Section 3.11, Population and
Housing. Indirect impacts caused by the jobs/housing imbalance within the City and
associated commuter trips include increased energy consumption, GHG emissions, and air
pollutant emissions from additional commuters and increased commute distances and
times. As the No Project Alternative would not provide housing opportunities within the
Project site, this alternative would not partially alleviate some of these direct and indirect
impacts to population and housing.
Public Services and Recreation
The No Project Alternative would not result in any impacts to public services and
recreation. Under this alternative, no additional police officers or fire fighters would be
needed and there would not be an increase in population that would require construction of
additional educational or recreational facilities.
Transportation and Traffic
Traffic and transportation impacts would be much less than the proposed Project under this
alternative, as there would be no development that would generate additional trips to and
from the Project site or on adjacent roadways. Therefore, the significant and unavoidable
impacts caused by the Project would not occur under this alternative. This alternative
would also not contribute to transportation improvements in the vicinity, such as LOVR
01729
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-17
Final EIR
improvements (i.e., Class IV bike lanes and sidewalks) or intersection improvements at
Auto Park Way.
Utilities and Energy Conservation
Impacts to utility and energy supplies and services would be much less compared to the
proposed Project. There would be no new significant demand for water, electricity, natural
gas, and fuel supplies nor additional demand for or increased strain on utility services and
infrastructure. Implementation of the No Project Alternative would not require treatment
capacity from the Wastewater Resource Recovery Facility (WRRF) during dry or wet-
weather conditions.
Mineral Resources
Under this alternative, the onsite red rock quarry would continue as an existing permitted
mining site in the County, though the quarry is not planned to be utilized for further
production. Impacts to this mineral resource would be less than the proposed Project.
5.4.2.2 Alternative 1 – Clustered Development Below the 150-foot Elevation Alternative
(the Actionable Alternative)
Through review of the Draft FRSP, the City acknowledged potential inconsistencies of the
Project with hillside protection policies prohibiting development above 150-foot elevation
line within the Irish Hills, requiring a General Plan amendment as part of the Project to
accommodate the proposed Upper Terrace and Madonna Froom Ranch development that
would intrude into the hillsides onsite. In the interest of Project review and decision-
making, the City requested the Applicant develop an “Actionable Alternative” involving a
land use configuration that would meet the Project objectives but could be approved under
the existing City policy framework without substantial amendments. Alternative 1 was
directly influenced by the Applicant’s work on the Actionable Alternative, which proposes
to relocate development downhill and increased density within the Lower Area. This
alternative is analyzed in project-level of detail compared to the Project to facilitate
flexibility in City decision-making and action.
Alternative 1 would include a major reconfiguration of the proposed land use plan and
redesign of key Project elements specifically to cluster proposed land uses into a smaller
development footprint, thereby reducing environmental impacts identified in the EIR.
Alternative 1 represents an alternative largely designed by the Project Applicant (see
Appendix C for a conceptual design plan that informed this alternative analysis) with three
01730
5.0 ALTERNATIVES
5-18 Froom Ranch Specific Plan
Final EIR
key changes to respond to the EIR’s impact analysis for the Project, as discussed further
below. This alternative is analyzed at a high level of detail to allow City adoption of this
alternative (if selected).
Alternative 1 would include three primary features that differ from the Project to
substantially reduce identified Project impacts:
1) Consistent with the 2014 General Plan LUE, all new urban development would
occur below the 150-foot elevation line. All residential land uses under Alternative
1 would be relocated to areas within the Project site that are below the 150-foot
elevation line and all development within the Upper Terrace would be removed.
The only development that would occur above the 150-foot elevation line would be
the proposed public park containing the same four Froom Ranch Dairy structures
proposed to be retained by the proposed Project. This would restrict development
to roughly 30 percent of the site;
2) Development would be clustered within the Lower Area of Villaggio and Madonna
Froom Ranch. Overall building density in developed areas of the site would
increase to accommodate the same capacity for development as the Project but
within a smaller area. Maximum heights of some buildings would increase by
approximately one story.
a. The Lower Area would remain designated R-3-SP, but development of
buildings within the Lower Area would be reconfigured and some building
heights and sizes would increase by one story, including the Villaggio
Commons buildings and the proposed tower.
b. Residential areas within Madonna Froom Ranch would be designated R-4-
SP and maximum residential density would increase to 24 units per acre
from 20 units per acre under the Project;
3) Emergency access would be provided via three different connections: 1) from the
Irish Hills Plaza into Madonna Froom Ranch; 2) from LOVR to the Lower Area of
Villaggio; and 3) from Calle Joaquin to the Lower Area of Villaggio through the
proposed stormwater detention basin area.
Required discretionary actions would be similar to the proposed Project:
General Plan Amendment and Pre-zoning. Similar to the Project, Alternative 1
would exceed a maximum of 350 units as identified in Section 8.1.5 of the General
01731
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-19
Final EIR
Plan LUE, which would require a General Plan amendment to LUE SP-3
performance standards to ensure consistency with the Specific Plan. Because the
site is currently unincorporated, it would also need to be pre-zoned based on the
approved Project before annexation to the City could be approved (see Table 5-1).
Since Alternative 1 would only include a public park within the existing permitted
quarry area developed above the 150-foot elevation, including retention of rural
ranch buildings from the Froom Ranch Dairy complex, and would not involve
urban development above the 150-foot elevation line, this alternative would not
require a General Plan amendment to address hillside policy inconsistency related
to grading, visual resources, biological and cultural resources, and hydrology
associated with the Project. Specific amendments to the General Plan include:
o Amend LUE Section 8.1.5 – Performance Standards to allow a Life Plan
Community senior housing land use, including health, support, and
recreational amenities, and up to 404 senior housing residential units with
51 beds in health care facilities within the Specific Plan area.
FRSP Adoption. The General Plan LUE 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 proposed Project would require adoption by the City prior
to implementation, including Planning Commission and City Council discretionary
review proceedings.
Vesting Tentative Tract Map (VTTM). The Project would require a vesting
tentative tract map (VTTM) to implement the provisions of the adopted Specific
Plan. The VTTM establishes the proposed lot lines to allow individual ownership
of properties and to layout the required infrastructure, water supply assessment, and
utilities.
Architectural Review and Planning Commission Approval. Final architectural
review of housing, commercial buildings, and some site facilities by the City’s
Architectural Review Commission would be required, with a recommendation
provided to the final action hearing body.
Annexation. If the Project is approved, the City would initiate the annexation
process with the San Luis Obispo County Local Agency Formation Commission
(LAFCO). Annexation would depend on the City’s ability to address any key issues
raised by LAFCO, such as the ability to provide public services to the site (e.g.,
01732
5.0 ALTERNATIVES
5-20 Froom Ranch Specific Plan
Final EIR
water, wastewater treatment, solid waste collection and disposal, and fire and police
services) and the nature of a tax-sharing arrangement with the County.
Responsible and trustee agency permit requirements would remain similar to the Project
and regulatory permits would be required from the California Department of
Transportation (Caltrans), U.S. Army Corps of Engineers (USACE), California
Department of Fish and Wildlife (CFDW), U.S. Fish and Wildlife Service (USFWS),
National Oceanic and Atmospheric Administration Fisheries (NOAA Fisheries), Federal
Emergency Management Agency (FEMA), and SLO County APCD (refer to Section 2.5,
Required Approvals).
Land Use Plan and Site Design
The land use plan under Alternative 1 would substantially reduce the area of disturbance
and development compared to the Project, including limiting residential and commercial
land uses to areas of the site below the 150-foot elevation line (see Figure 5-1). Overall
developed area would decrease by 8.2 acres as compared to the Project, and more than 6.1
additional acres within the Upper Terrace area would remain as open space, substantially
reducing direct and indirect disturbance of habitats and natural resources in this area.
Similar to the Project, Alternative 1 would allow for the development of up to 174 multi-
family units, 404 independent and assisted senior villas and townhomes, and 51 beds in
residential health care facilities. These residential uses would be located within medium-
high and high-density residential zones, with 100,000 sf of commercial uses within retail-
commercial zones (Table 5-1).
01733
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-21
Final EIR
Table 5-1. Summary of Alternative 1 Zoning and Land Uses
Proposed Zones Acreage Housing Units/ sf
VILLAGGIO
R-3-SP Medium-High Density Residential 23.5 404 units/ 51 beds
Independent Living Units 366 units
Assisted Living Units 38 units
Health Care Units (Skilled Nursing & Memory Care) 51 beds
Health Care Administration Building 85,670 sf
Ancillary Uses (wellness center, restaurants, theater,
etc.)
76,509 sf
MADONNA FROOM RANCH
R-4-SP High Density Residential 7.4 174 multi-family units
C-R-SP Retail-Commercial 3.1 100,000 sf
Hotel with Restaurant 70,000 sf
Other Commercial 30,000 sf
PF-SP Public Facilities 3.3 --
ADDITIONAL USES
C/OS-SP Conservation/ Open Space 66.8 --
Designated Open Space 59.7 --
Reconfigured Agricultural Easement 7.1 --
Roadways 5.6 --
TOTAL 109.7 578 units/51 beds1
100,000 sf commercial
1 Total exceeds Maximum 350 units as allowed in Section 8.1.5 of the General Plan LUE due to transition of allowed
commercial land uses to residential land uses. This total assumes all units planned within residential land uses.
Similar to the Project, Alternative 1 would include adoption of specific zoning standards
to govern development within the Specific Plan area. Modified development standards for
residential uses from the City’s Municipal Code would apply to the Specific Plan area
(Table 5-2).
01734
5.0 ALTERNATIVES
5-22 Froom Ranch Specific Plan
Final EIR
Table 5-2. Proposed Development Standards for Residential Zones
Standard R-3-SP R-4-SP
Maximum Density (units/acre) 20 du/ac 24 du/ac
Maximum Building Coverage 60% 60%
Maximum Building Height1,2,3 55 feet for Villaggio only 35 feet
Minimum Street Yard Setback4 15 feet 15 feet
Minimum Other Yard Setback4 0-5 feet 0-5 feet
Minimum Lot Size5 1,000 sf 1,000 sf
Minimum Lot Width5 20 feet 20 feet
Minimum Lot Depth5 50 feet 50 feet
1 Building heights are measured from finished grades established at the time of completion of subdivision grading.
3 Components of solar energy systems, towers, and mechanical equipment screening may extend up to 10 feet above
the maximum building height.
4 Yard setbacks do not apply to development in Villaggio as all development is located along private streets.
5 Lot area and dimensions standards do not apply to Villaggio as individual lots for housing units are not proposed.
Villaggio Development
Alternative 1 would continue to provide a Life Plan Community in Villaggio, designated
within 23.4 acres of R-3-SP located entirely within the lower portion of the site. Alternative
1 development standards would only differ from the Project related to maximum building
heights, where maximum building height within Villaggio would increase from 45 feet to
55 feet to accommodate higher density development within the Lower Area. This would
result in changes to building configurations in proposed structures surrounding the
Commons where additional Piazza Apartments and Community Village Suite Apartments
would be provided (see Appendix C). Clustered development and taller buildings in the
central Community Village area of Villaggio, including the proposed apartment buildings
in the Commons, would accommodate more units compared to the Project in this area.
Similar to the Project, Villaggio would provide planned residential use with independent
living units and specialized residential facilities for assisted living, skilled nursing, and
memory care (Table 5-3).
01735
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-23
Final EIR
Table 5-3. Types of Senior Housing within Villaggio
Type of Senior Housing Units Size (sf)
Independent Living Units 366 units 700-2,000 sf
Piazza Apartments 180 units 700-1,900 sf
Village Suites 85 units 700-1,900 sf
Garden Terraces 60 units 1,300-1,800 sf
Villas 41 units 1,700-2,000 sf
Assisted Living Units1 38 units 310-620 sf
1 Assisted Living Units are assumed to be single occupancy.
Independent living units would vary in size, as follows:
Piazza Apartments and Village Suites – 265 total units within the upper floors of
three- to four-story multi-use buildings up to 55 feet in height;
Garden Terraces – two- to three-story apartment buildings, containing a total of 60
two-bedroom units; and
Villas – 41 detached one-story single-family homes with two bedrooms, up to 20
feet in height.
Similar to the Project, residential land uses would extend to the southwest portion of the
Project site and would be proximate (i.e., within 50 feet) to the confluence of Drainages,
1, 2 and 3 with Froom Creek, but would not extend to the Upper Terrace. Alternative 1
would replace two Garden Terrace apartment buildings along the western bank of Froom
Creek with Piazza Apartment development and would include additional Villas accessed
via cul-de-sac at the base of Drainages 1, 2, and 3 to accommodate more units within the
designated residential area.
Like the Project, Alternative 1 proposes non-residential development to serve future
Villaggio residents, including health care facilities, ancillary restaurant and recreational
uses, and other private amenities. These uses are proposed to serve onsite residents, guests,
and staff only, and would not be open to the public or residents of Madonna Froom Ranch.
Non-residential development within Villaggio would include:
Health Care Administration Building – A three-story 85,670-sf building within the
lower terrace near the Villaggio entrance gate. This building includes the assisted
living units, memory care, and skilled nursing beds where residents require 24-hour
care and supervision.
01736
5.0 ALTERNATIVES
5-24 Froom Ranch Specific Plan
Final EIR
Wellness Center – A 17,720-sf wellness center located within the lower terrace
would provide recreational facilities, including an outdoor swimming pool,
restrooms, lockers, yoga area, exercise equipment, and physical therapy services.
The Commons – A four-story mixed-use building, known as “The Commons”,
would serve as the community center and include ground floor resident-serving
uses, such as restaurants, craft areas, workshops, recreation rooms, and a movie
theater.
Assembly Room – A 5,688-sf room would accommodate a variety of functions and
gatherings.
Tower – A 60-foot-tall tower is proposed that would include a library on the first
floor, a total of four guestrooms on the second and third floors, and an observation
deck on the fourth floor.
Security Gatehouse – An approximately 250-sf security gatehouse structure would
be located at the main entrance to Villaggio to control access and entry of residents,
and provide directions, parking passes, etc. for visitors, employees, and deliveries.
Madonna Froom Ranch Development
Madonna Froom Ranch would continue to provide multi-family housing and retail
commercial uses similar to the Project within 7.4 acres of High Density Residential (R-4-
SP) and 3.1 acres of Retail Commercial/General Commercial (C-R-SP) designated areas.
All proposed development standards for R-4-SP would remain the same as the Project;
however, the proposed density of the residential areas would increase slightly from a
maximum of 20 units per acre under the Project to 24 units per acre under Alternative 1.
This change would accommodate the same number of residential units as the Project within
a smaller development footprint and cluster the residential development within areas below
the 150-foot elevation line. As a result of the reconfigured residential land uses, a portion
of the multi-family homes would be relocated eastward to lower elevations within
Madonna Froom Ranch, away from the habitats and wildfire hazards of the Irish Hills.
Under Alternative 1, the trailhead park would be provided within 3.3 acres of Public
Facilities (PF-SP) designated area and would be relocated above the 150-foot elevation line
in the northwest corner of the Project site adjacent to the Irish Hills Natural Reserve. This
would increase the size of the public park by approximately 0.4 acre. Alternative 1 would
include the same commercial uses as the Project located in the northeast portion of the
01737
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-25
Final EIR
Specific Plan area, including a three-story, 70,000-sf hotel up to 45 feet in height with
ground floor retail and restaurant uses and 30,000 sf of retail and office uses within a one-
story building up to 24 feet in height.
The reconfigurations included in Alternative 1 would ensure the land use plan better aligns
with the policies of the City’s General Plan regarding development above the 150-foot
elevation contour and natural resource protection. The land use plan for Alternative 1
would reserve 66 percent of the Specific Plan area (66.9 acres) in Conservation/Open Space
(C/OS-SP), which would be consistent with the City General Plan performance standard
of providing a minimum of 50 percent of the Specific Plan area as Open Space/Agriculture
(LUE Section 8.1.5. SP-3, Madonna on LOVR Specific Plan area). Alternative 1 would
also comply with the General Plan LUE 150-foot elevation development limit line within
the Irish Hills Hillside Planning Area, specifically, Subsection 6.4.7.H of the LUE (see
also, Section 3.9, Land Use and Planning).
Alternative 1 would be similar to the Project in many ways but would represent a
substantially more clustered approach to site design, with development restricted to
approximately 30 percent of the site (34 acres) in the lower portions of the site. Alternative
1 would reduce overall residential acreage by 8.2 acres while increasing open space by 7.9
acres and public park acreage by 0.4 acres. Increased clustering under Alternative 1 would
require substantial changes in the Villaggio design when compared to the Project, including
changes to building locations and footprints, increases in maximum residential building
heights by one floor (i.e., 10 feet), and an increase in the proposed tower height by five feet
(refer to Table 5-4). Most significantly, all development would be removed from the Upper
Terrace and nearly 50 acres of land in this area would be retained as contiguous, permanent
open space within Villaggio adjacent to the Irish Hills Natural Reserve. These changes
would substantially increase contiguous open space and result in improved ecologic and
hydrologic connectivity within the Project site compared to the Project.
01738
A-A
B-B
CROSS SECTIONCROSS SECTION
LOCATIONLOCATION
(FIGURE 5-4)(FIGURE 5-4)
Drainage 4Drainage 4
150-FOOT E L EVATION CONTO
UR LIN
EProposed Froom Creek RealignmentF ro o m C r e e k *Prefumo CreekSan Luis Obispo Creek101
CALLE JOAQUINLOS OSOS VALLEY ROADLOS OSOS VALLEY ROADCALLE JOAQUINAUTO PARK WAYAUTO PARK WAYIRISH HILLSIRISH HILLS
NATURALNATURAL
RESERVERESERVE
VISITOR SERVING COMMERCIALVISITOR SERVING COMMERCIAL
(HOTELS)(HOTELS)
COSTCOCOSTCO
MOUNTAINBROOKMOUNTAINBROOK
CHURCHCHURCH CALLE JOAQUINCALLE JOAQUINLOS OSOS VALLEY ROADAUTO PARK WAYIRISH HILLS
NATURAL
RESERVE
VISITOR SERVING COMMERCIAL
(HOTELS)
COSTCO
MOUNTAINBROOK
CHURCH
F ro o m C r e e k *Prefumo CreekSan Luis Obispo CreekUNINCORPORATEDUNINCORPORATED
SAN LUIS OBISPOSAN LUIS OBISPO
COUNTYCOUNTY
UNINCORPORATED
SAN LUIS OBISPO
COUNTY Proposed Froom Creek RealignmentVILLAGGIOVILLAGGIO
LIFE PLANLIFE PLAN
COMMUNITYCOMMUNITY
MADONNA FROOMMADONNA FROOM
RANCHRANCH
VILLAGGIO
LIFE PLAN
COMMUNITY
MADONNA FROOM
RANCH
AUTOAUTO
DEALERSHIPSDEALERSHIPS
IRISH HILLSIRISH HILLS
PLAZAPLAZA
SHOPPINGSHOPPING
CENTERCENTER
IRISH HILLS
PLAZA
SHOPPING
CENTER
AUTO
DEALERSHIPS
CITY OFCITY OF
SAN LUIS OBISPOSAN LUIS OBISPO
CITY OFCITY OF
SAN LUISSAN LUIS
OBISPOOBISPO
CITY OF
SAN LUIS OBISPO
CITY OF
SAN LUIS
OBISPO
Drainage 3
Drainage 4
Drainage 2
Drainage 1
150-FOOT E L EVATION CONTO
UR LIN
EEMERGENCYEMERGENCY
ACCESSACCESS
POINTPOINT
EMERGENCY
ACCESS
POINT
EMERGENCYEMERGENCY
ACCESSACCESS
EMERGENCY
ACCESS
EMERGENCYEMERGENCY
ACCESSACCESS
EMERGENCY
ACCESS
LOWER
AREA
UPPER
TERRACE
CROSS SECTION
LOCATION
(FIGURE 5-4)
LEGEND
Proposed Specific Plan Land Use
Project Site
Cross Section Location
(refer to Figure 5-2)
Villaggio (Private)
Madonna Froom Ranch
B-B
Public Site Access
Roadways: 5.6 acres
Easement for Relocated
Stormwater Basin: 7.1 acres
Reconfigured Open Space
and Agricultural Conservation
Easement
C-R-SP – Retail
Commercial/ General
Commercial: 3.1 acres
C/OS-SP – Conservation/
Open Space: 66.9 acres
PF-SP – Public Facilities:
3.3 acres
R-3-SP – Medium-High Density
Residential: 23.4 acres
R-4-SP – High Density Residential:
7.4 acres
*Notes: Roadways within Villaggio are private and are included as
part of the medium high density residential land use.
Froom Creek would be realigned.
Alternative 1 Land Use Plan 5-1
FIGURE
Aerial Source: Google 2018.
0 500
SCALE IN FEET
N
5-26 01739
200180160150140ELEVATION120100ElevatorElevator
Subterranean Parking28’18’18’LocalRoad “C”Mixed-Use Commericaland ResidentialResidentialCommercial Uses (i.e.,restaurants, recreationrooms, movie theater)Mixed-Use Commericaland ResidentialResidentialResidential ResidentialResidentialElevator
ResidentialResidential2nd Level SkybridgeResidentialResidentialResidentialCommercial Uses (i.e.,restaurants, recreationrooms, movie theater)PathPath55’ HighThe Commons45’ HighPiazza Apartments60’ HighTower150-FootElevationProjectGradeExistingGradeElevatorElevator
Subterranean ParkingResidentialResidentialResidentialResidentialResidentialResidentialElevator
Residential28’Local Road “C”3.5’ HighRetaining Wall5’ HighFence18’Path45’ HighPiazza Apartments20’ HighVillaIrish HillsNaturalReserve200180160150140ELEVATION120100150-FootElevationProjectGradeExistingGrade5-2FIGUREAlternative 1 –Villaggio Life Plan Community Conceptual Cross Sections (refer to Figure 5-1 for cross section locations)Cross Section B-B – Villaggio CenterCross Section A-A – Irish Hills Natural Reserve to Villaggio Center5-2701740
5.0 ALTERNATIVES
5-28 Froom Ranch Specific Plan
Final EIR
Site Design Features
Froom Creek would be realigned and restored similar to the Project and stormwater
management would be provided similar to the Project; see Section 2.5.4, Stormwater
Management System and Froom Creek Realignment. Froom Creek would be realigned to
along the eastern edge of development and a public trail along the realigned Froom Creek
would be developed, similar to the Project. Additionally, the LOVR ditch would be
reconstructed and revegetated similar to the Project and would experience the same
reconfiguration to accommodate widening of LOVR. However, due to the reduction in
developed area, fewer onsite retention and treatment features would be required, including
one stormwater treatment area, one linear water quality treatment area, and four headwall
and pipe culverts that would no longer be required in the Upper Terrace.
As with the proposed Project, at least two major retaining walls would be required under
Alternative 1. An approximately 300-foot-long retaining wall would be constructed along
the border of the Irish Hills Natural Reserve and northwestern area of Villaggio adjacent
to proposed Villa units (refer to Cross Section A-A on Figure 2-6 within Chapter 2, Project
Description). Another 75-foot-long retaining wall would be located near the historic dairy
barn in Madonna Froom Ranch to support the eastern corner of the building if it is retained
in its current location in the final design of the public park. These walls would vary from
3 feet to 8 feet in height but would be limited to a maximum exposed above ground height
of 8 feet.
Similar to the proposed Project, Alternative 1 would include five-foot-tall security fencing
to enclose Villaggio and adjacent to the residential areas within Madonna Froom Ranch.
Villaggio would be a gated community with keyed access points for residents to access the
Irish Hills Natural Reserve public trail system and the proposed public trail along the
realigned Froom Creek. In addition to Villaggio security fencing, five-foot-tall wildlife-
compatible agricultural fencing would surround the Specific Plan area and would be
designed to allow for animal passage to open space areas, water sources, and wildlife
corridors within the site.
In summary, Alternative 1 would differ from the Project in several ways, including a
reconfigured residential land use plan, but would retain the basic features of the Project to
provide a senior living community and multi-family neighborhood, as detailed in Table 5-
4.
01741
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-29
Final EIR
Table 5-4. Comparison of Alternative 1 to the Proposed Project
Item Project Alternative 1 Alternative 1
Difference
Froom Creek
Froom Creek Realignment Realigned Realigned None
Emergency access road
through proposed
stormwater detention basin
area.
No emergency access
road in proposed
stormwater detention
basin area.
20-foot-wide
emergency access road
along west edge of
proposed stormwater
detention basin area.
Emergency access
road would replace the
Project’s proposed
emergency access road
through
Mountainbrook
Church. Drainage
crossings would be
required for Drainage
1 and Drainage 4.
Residential Uses
Residential: Acreage 39.1 acres 30.9 acres -8.2 acres
Residential: Units 578 units/51 beds 578 units/51 beds None
Mix of Units 534 R-3-SP units
44 R-4-SP units
404 R-3-SP units
174 R-4-SP units
-130 R-3-SP units
+130 R-4-SP units
Retail Commercial Uses
Acreage 3.1 acres 3.1 acres None
Maximum Square Footage 100,000 sf 100,000 sf None
Potential Uses Hotel, restaurants, and
other commercial
Hotel, restaurants, and
other commercial
None
Open Space & Parks
Open Space: Acreage 59.0 acres 66.9 acres +7.9 acres
Parks: Acreage 2.9 acres 3.3 acres +0.4 acres
Parks: Number 1 trailhead Park 1 trailhead Park None
Building Heights
Maximum Height Residential: 20’ to 45’
(1 to 3 stories)
Tower: 55’
Residential: 20’ to 55’
(1 to 4 stories)
Tower: 60’
+10’ (1 story)
residential buildings
+5’ tower
Circulation and Site Access
Circulation within Alternative 1 would involve public roadways within Madonna Froom
Ranch and private roadways in Villaggio similar to the Project; however, the road system
would be substantially reduced in length compared to the Project due the clustered
development of Alternative 1. Similar to the Project, Alternative 1 would have a primary
entrance from LOVR at Auto Park Way. Private access roads within Villaggio would only
serve Villaggio and no roads would extend to the Upper Terrace above the 150-foot
elevation line. Public roadways would lead to the public park at the northwestern corner of
the site (above the 150-foot elevation) and the private gated entrance to Villaggio. Major
components of the Alternative 1 circulation system are similar to the Project and are
summarized below:
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5.0 ALTERNATIVES
5-30 Froom Ranch Specific Plan
Final EIR
1) A proposed signalized intersection with LOVR and the proposed main entrance to
serve as the primary access to the Specific Plan area;
2) Widening of LOVR along a portion of the Project site’s frontage;
3) Proposed internal roadway network consisting of public and private roads;
4) Proposed bicycle and pedestrian facilities throughout the Specific Plan area;
5) Parking facilities to accommodate residents, employees, and visitors within the
Specific Plan area; and
6) A new bus stop that would be integrated into the regional public transportation
system.
Major circulation improvements under Alternative 1 within Madonna Froom Ranch and
the lower portion of Villaggio would be the same as under the proposed Project. As with
the Project, primary access to the Specific Plan area under Alternative 1 would be via a
new two-lane road Commercial Collector “A”, which would intersect with LOVR at Auto
Park Way and would be located approximately 1,000 feet south of the intersection of
Froom Ranch Way with LOVR. The intersection would be signalized and would provide
four-way pedestrian crosswalks.
Alternative 1 would include improvements to an 813-foot-long segment of LOVR along
the northeastern boundary of the Specific Plan area at the proposed intersection of
Commercial Collector “A” and LOVR. LOVR would be widened along this segment by
about 35 feet into the Specific Plan area to accommodate new left and right turn lanes into
the Project site (Figure 2-9). Alternative 1 would also include restriping the existing travel
lanes, Class II bicycle lanes, and center median along this segment and a new sidewalk and
parkway would be installed along approximately 550 feet of the west side of LOVR to
connect to the Project site entrance (see Figure 2-10 in Chapter 2, Project Description).
Bicycle racks would continue to be provided at the proposed retail commercial zone and
the trailhead park within Madonna Froom Ranch.
Similar to the Project, all roadways within Madonna Froom Ranch would be open to the
public and accessible by motorists, bicyclists, and pedestrians from LOVR. Similar to the
Project, Alternative 1 would also include two public Commercial Collector roadways, “A”
and “B”. Commercial Collector “A” would connect LOVR to residential and commercial
areas within Madonna Froom Ranch. Commercial Collector “B” would connect to the main
entrance to Villaggio and terminate at the Project site’s boundary to the north to only allow
pedestrian, bicycle, and emergency access to Irish Hills Plaza. Local Road “A” would be a
public roadway that extends to residential areas within Madonna Froom Ranch and to the
01743
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-31
Final EIR
proposed trailhead park. Proposed Class II striped bicycle lanes would be included along
Commercial Collector “A” and Class III bicycle routes would be provided along
Commercial Collector “B” and Local Road “A” to connect the public park and residential
areas within Madonna Froom Ranch. All roads in Madonna Froom Ranch would have
sidewalks, similar to the Project (see Figure 2-11 in Chapter 2, Project Description).
As with the Project, all roadways within Villaggio would be private roads. Similar to the
Project, Alternative 1 would include Local Roads “B” and “C” as private roads within
Villaggio (see Figure 2-11 in Chapter 2, Project Description). Local Road “B” would serve
as the primary ingress/egress to Villaggio from Commercial Collector “B” to the Villaggio
entrance gate. Local Road “C” would provide private access throughout Villaggio and
would not provide sidewalks; however, a network of private walking trails separated from
vehicle roadways would be provided for Villaggio residents similar to the Project (see
Figure 2-12 in Chapter 2, Project Description).
Alternative 1 would include the proposed Froom Creek Trail that would be accessible from
Madonna Froom Ranch, Villaggio, and the existing Irish Hills Natural Reserve trails
system. The proposed Froom Creek Trail would be a 6-foot-wide, decomposed granite (or
other stabilized natural surface) public pedestrian trail along the north bank of the realigned
Froom Creek. Under Alternative 1, the public trail would terminate at a wetlands viewing
area adjacent to a Villaggio gated access point similar to the Project, but would provide an
additional connection through to the proposed emergency access road in the proposed
stormwater detention basin area. This additional connection would give pedestrians the
opportunity to reach the public trail and its connections to the Irish Hills Natural Reserve
and proposed public park, as well as Irish Hills Plaza, from Calle Joaquin, including the
adjacent hotel properties. In contrast to the Project, under Alternative 1, the trailhead park
would be located at the highest elevation on the Madonna Froom Ranch side of the site,
immediately adjacent to the Irish Hills Natural Reserve, providing complementary
amenities and direct access to this existing City open space.
Parking would be similar to the proposed Project and provided in accordance with City
development standards consistent with the requirements of Chapter 17.16 of the City
Municipal Code. Parking in Madonna Froom Ranch residential and commercial areas
would be provided via surface parking lots while parking in Villaggio would be a
combination of surface parking lots and subterranean parking garages. A public surface lot
would be located within the trailhead park, as under the Project.
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5.0 ALTERNATIVES
5-32 Froom Ranch Specific Plan
Final EIR
Similar to the Project, a single new bus stop is proposed at the site’s main entrance at Auto
Park Way. Refer to Section 3.13, Transportation and Traffic, for a more complete
description of transit operations.
Emergency Access
Emergency access to Mountainbrook Church would not be part of Alternative 1. Rather,
emergency access would be provided via three different connections:
1.From the Irish Hills Plaza into Madonna Froom Ranch. A paved, level connection
between Madonna Froom Ranch and Irish Hills Plaza would be provided near the
end of Commercial Collector “B” and controlled with removable bollards that
would be opened under emergency conditions, such as wildfire evacuation. This
would require an easement from Irish Hills Plaza owners.
2.From LOVR to Villaggio. Another emergency access point would be provided via
construction of a new free span bridge and access road across the realigned Froom
Creek channel to connect LOVR with Villaggio. This bridge and access road would
be located roughly 800 feet east of the primary project entrance at Auto Park Way.
3.From Calle Joaquin to Villaggio through the proposed stormwater detention basin
area. Because the two emergency access routes described above would funnel all
evacuees onto LOVR and introduce challenges for ingress and egress of emergency
responders, an additional 20-foot-wide paved emergency access road would be
installed along the western edge of the proposed stormwater detention basin to
connect Calle Joaquin to the Project site (see Figure 5-1); however, evacuees along
this route would also ultimately funnel to LOVR further south and would connect
to U.S. 101. This alternate emergency access road is included in Alternative 1 to
replace the Project’s proposed emergency access through Mountainbrook Church
and would supplement the two emergency access points discussed above to ensure
a southern access/evacuation route for Villaggio that connects with Calle Joaquin,
similar to the Project (See Figures 5-1 and 5-3). Given that this road would be
immediately adjacent to the proposed stormwater detention basin, during times of
very high stormwater flows the road could be partially submerged. Given that this
road is intended primarily for emergency access during the fire season (e.g.,
typically August-November), occasional submersions during periods of heavy rain
appears consistent with its use as a fire evacuation or access route. Figure 5-3
01745
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-33
Final EIR
presents a conceptual design, but final engineering design would account for City
standards.
Onsite Historic Structures
Similar to the Project, Alternative 1 would include relocation of three structures
contributing to the historic Froom Ranch Dairy complex, namely the creamery, the main
residence, and the dairy barn, to the public park area; the fourth contributing structure, the
granary, would remain in place within the park. These four structures would be
rehabilitated and adaptively reused as part of the trailhead park, including interpretive
signage/displays to document the history of Froom Ranch. The buildings would be
relocated and reconstructed on graded terrain to maintain the historic configuration and
proportional relationship of the buildings to each other. Similar to the Project, three
contributing structures (shed/storage building, old barn, and bunkhouse) to the potential
historic district would be demolished and removed from the site, and documented
consistent with Secretary of Interior (SOI) standards.
Proposed Housing and Population
The proposed mix of housing types under Alternative 1 would be similar to the Project
with slight modifications to the location/extent of residential zones and distribution of units
within each zone; the allocation of units between different allowable densities and product
types (e.g., Life Plan Community, multi-family units) would remain similar. Alternative 1
would alter the land use plan and incrementally adjust dwelling unit allocation, resulting
01746
5.0 ALTERNATIVES
5-34 Froom Ranch Specific Plan
Final EIR
in a reduction of 130 R-3-SP units to be replaced with an increase of 130 R-4-SP units, a
net zero change (Table 5-5).
Similar to the Project, proposed housing components of Alternative 1 would include a mix
of single-family or duplex units in Villaggio and higher density multi-family
condominiums and apartments in both Madonna Froom Ranch and Villaggio. Residential
uses would have a similar mix of housing densities and average lot sizes as proposed for
the Project, with dispersed single-story Villas, two story Garden Terraces, and up to four-
story buildings supporting Piazza Apartments and Community Village Apartment suites.
Exact unit layout and design is not currently known (see Appendix C for Applicant’s
conceptual site plan that informed Alternative 1).
Table 5-5. Summary and Comparison of Housing and Population
Residential Project Alternative 1
Housing Type Project
Proposed Units
Estimated
Population
Alternative 1
Proposed Units
Estimated
Population1
R-3-SP - Villaggio 404 units/51
beds
825 people 404 units/51
beds
825 people
R-3-SP – Madonna
Froom Ranch2
130 units 303 people - -
R-4-SP -Madonna
Froom Ranch2
44 units 103 people 174 units 406 people
TOTAL 578 units/51
beds
1,231 people 578 units/51
beds
1,231 people
1 Population estimates are based on the number of units multiplied by the average number of persons per household
Based on the 2050 Regional Growth Forecast, the City’s average persons per household is 2.33 as of 2015 (SLOCOG
2017)
2Per City zoning, R-3 and R-4 units are expressed as density units. The number of actual dwelling units in the R-3 and
R-4 zone may vary depending on the number of bedrooms.
Project Construction and Phasing
Similar to the Project, this EIR analysis assumes that Alternative 1 construction would
occur over approximately five years between 2020 and 2024 although Alternative 1 would
only require three phases (see Table 5-6).
Phase 1 would involve construction activities including site preparation such as
grading, realignment of Froom Creek, and installation of roadways, utility
infrastructure, and trails.
Phase 2 would include final grading and vertical development of Villaggio (to be
located entirely in the lower portion of the site).
01747
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-35
Final EIR
Phase 3 would include final grading and vertical development of Madonna Froom
Ranch, including extension of utilities and construction of residential and
commercial buildings.
Each phase of Alternative 1 would follow a progression of stages similar to that proposed
for the Project, as follows: construction design and permitting, site preparation and grading,
construction, and final landscaping. Equipment anticipated for use during these stages
would be similar to that of the Project. Alternative 1 would include a different assortment
of construction activities within each construction phase, but it would follow a similar
progression of development within the Project site. Each phase would be subject to permit
review to ensure conformity with the approved FRSP, and consistency with applicable
regulations. Each phase would identify the development activities to be performed during
the phase and specify mitigation measures and best management practices (BMPs) that
would apply.
Table 5-6 identifies which project component would occur within each phase.
Table 5-6. Alternative 1 Construction Phasing
Phase Project Component Year
Estimated
Grading
(cy)1
1
Installation of Project Infrastructure and Stormwater Management
System.
Rough grading for Madonna Froom Ranch and distribution of
export material to Phase 2 (31,800 cy stockpiled onsite).
Realign Froom Creek and reconstruct creek corridor.
Install proposed stormwater detention basin with emergency
access road and bridge between Villaggio and Calle Joaquin.
Widen LOVR and install frontage improvements along LOVR,
including bicycle lanes, sidewalks, bus stop, and signalized
intersection.
Install onsite public roads (Commercial Collectors “A” and “B”
and associated bicycle lanes and sidewalks).
Install public utility connections along Commercial Collectors “A”
and “B”.
Construct crossing across Froom Creek from Commercial
Collector “B”.
Construct crossing across Froom Creek from Local Road “C” to
LOVR for emergency access.
Modify Irish Hills Plaza drainage, including modifications to the
vegetated channel prior to connection with the realigned Froom
Creek.
2020 -
2021
65,800 cut/
34,000 fill
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5.0 ALTERNATIVES
5-36 Froom Ranch Specific Plan
Final EIR
Table 5-6. Alternative 1 Construction Phasing (Continued)
Phase Project Component Year
Estimated
Grading
(cy)1
Install stormwater management system, including removal of
existing culverts and onsite stormwater detention basin.
Installation of Froom Creek Trail.
Begin site clearing of lower portion of Villaggio in preparation for
Phase 2.
2
Development of Villaggio.
Grading of the lower portion of the Villaggio site and import fill
materials (158,000 cy import).
Install onsite private roads (Local Roads “B” and part of “C”).
Extend utility lines throughout Villaggio.
Construct water quality treatment areas within Phase 2.
Install fencing and pedestrian access gates.
Construct Villaggio residential uses.
Construct the Villaggio Health Administration Building.
Construct the Wellness Center.
Begin site clearing of Madonna Froom Ranch in preparation for
Phase 3.
2020 -
2023
27,500 cut/
185,000 fill
3
Development of Madonna Froom Ranch.
Extend utility lines throughout Madonna Froom Ranch.
Construction of multi-family units within Madonna Froom Ranch.
Construct commercial retail buildings, including hotel, within
Madonna Froom Ranch.
Construction of the public park.
2023-
2024 0 cut/ 0 fill
1 Grading estimates (cy) are approximate.
Analysis – Alternative 1 (Clustered Development Below the 150-Foot Elevation
Alternative – Actionable Alternative)
The significance of each impact resulting from implementation of Alternative 1 has been
determined based on impact significance criteria and applicable CEQA Guidelines for each
impact topic (see Table 5-7).
01749
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-37
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
Impacts Mitigation Measures Residual Significance
3.1 Aesthetics and Visual Resources
VIS-1. Alternative 1 implementation would change
views of scenic resources, including hillsides, rock
outcroppings, open space, and historic buildings,
from a State Scenic Highway or local scenic
roadway.
MM VIS-1 Less than Significant
with Mitigation
(Incrementally Less)
VIS-2. Alternative 1 would significantly impact the
existing visual character of the site by changing a
rural setting to a commercial and residential setting,
particularly as viewed from the Irish Hills Natural
Reserve trail system.
MM VIS-1 Less than Significant
with Mitigation
(Less)
VIS-3. Alternative 1 would introduce a major new
source of nighttime light, impacting the quality of
the nighttime sky and increasing ambient light.
None required Less than Significant
(Similar)
3.2 Agricultural Resources
AG-1. Alternative 1 would convert onsite Farmland
of Local Potential and prime soils if irrigated to non-
agricultural uses.
None Required Less than Significant
(Similar)
AG-2. Implementation of Alternative 1 would create
potential conflicts with existing agricultural zoning.
None Required Less than Significant
(Incrementally Less)
AG-3. Alternative 1 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
(Similar)
3.3 Air Quality and Greenhouse Gas Emissions
AQ-1. Alternative 1 would result in potentially
significant construction-related emissions, including
dust and air pollutant emissions.
MM AQ-1
MM AQ-2
MM AQ-3
Less than Significant
with Mitigation
(Incrementally Less)
AQ-2. Alternative 1 would result in potentially
significant long-term operational emissions.
MM AQ-4 Significant and
Unavoidable
(Incrementally Less)
AQ-3. Release of toxic diesel emissions or naturally
occurring asbestos during construction of Alternative
1 could expose sensitive receptors to emissions-
related health risks.
None required Less than Significant
(Incrementally Less)
AQ-4. Alternative 1 would be consistent with the
City’s Climate Action Plan, but would result in
potentially significant GHG emissions during
construction and operation which would be
inconsistent with other state and local goals for
reducing GHG emissions.
MM AQ-4
MM AQ-5
MM AQ-6
Significant and
Unavoidable
(Incrementally Less)
01750
5.0 ALTERNATIVES
5-38 Froom Ranch Specific Plan
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
AQ-5. Alternative 1 is potentially inconsistent with
the SLO County APCD’s Clean Air Plan.
MM AQ-2
MM TRANS-5
MM TRANS-8
MM TRANS-9
MM TRANS-10
Significant and
Unavoidable
(Similar)
3.4 Biological Resources
BIO-1. Alternative 1 implementation would impact
sensitive riparian, wetland, and native grassland
habitats identified as sensitive natural communities
under state and City policy.
MM BIO-1
MM BIO-2
MM BIO-3
MM BIO-4
MM BIO-5
MM BIO-6
MM BIO-7
MM BIO-8
MM BIO-Alt. 1
MM HAZ-2
Less than Significant
with Mitigation
(Less)
BIO-2. Alternative 1 implementation would have
substantial direct and indirect adverse impacts on
candidate, sensitive, or special-status species that are
known to or may occur on the Project site.
MM BIO-1
MM BIO-9
MM BIO-10
MM BIO-11
MM BIO-12
MM HAZ-2
Less than Significant
with Mitigation
(Less)
BIO-3. Alternative 1 implementation would have a
substantial adverse impact on state and federally
protected wetlands.
MM BIO-1
MM BIO-2
MM BIO-4
MM BIO-5
MM BIO-6
MM BIO-7
MM BIO-Alt. 1
Significant and
Unavoidable
(Less)
BIO-4. Alternative 1 construction and operation
would have a substantial adverse impact on the
movement of resident or migratory fish or wildlife
species or resident and migratory wildlife corridors
along Froom Creek, Drainages 1, 2, and 3 and across
open grasslands on the Upper Terrace of the Project
site.
MM BIO-1
MM BIO-2
MM BIO-3
MM BIO-4
MM BIO-5
MM BIO-6
MM BIO-9
MM BIO-11
MM BIO-12
MM BIO-14
Less than Significant
with Mitigation
(Less)
BIO-5. Alternative 1 construction would result in the
potential disturbance, trimming, or removal of up to
75 mature trees.
MM BIO-15 Less than Significant
with Mitigation
(Incrementally Less)
3.5 Cultural and Tribal Resources
01751
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-39
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
CR-1. Alternative 1 grading and construction would
occur within areas of prehistoric archaeological
sensitivity with the potential to impact subsurface
cultural or tribal cultural resources.
MM CR-1
MM CR-2
MM CR-3
MM CR-4
MM CR-5
MM CR-6
MM CR-7
Less than Significant
with Mitigation
(Incrementally Less)
CR-2. Future resident recreational activities could
impact archaeological resources located within
proposed open space.
MM CR-8 Less than Significant
with Mitigation
(Less)
CR-3. Alternative 1 would result in relocation,
demolition, disturbance, and/or removal of historic
resources onsite, including individually eligible
historic resources and a historic district.
MM CR-9
MM CR-10
MM CR-11
MM CR-12
MM CR-13
MM CR-14
Significant and
Unavoidable
(Similar)
3.6 Geology and Soils
GEO-1. Alternative 1 would expose people or
structures to adverse effects from earthquakes and
seismically induced hazards.
None required Less than Significant
(Similar)
GEO-2. Alternative 1 has the potential to exacerbate
potential soils hazards, including expansive soils,
differential settlement, and subsidence.
None required Less than Significant
(Similar)
GEO-3. Alternative 1 would potentially cause
erosion, landslides, and rockfall.
None required Less than Significant
(Similar)
GEO-4. Alternative 1 would include subterranean
parking in Villaggio and may require groundwater
dewatering in areas with high groundwater.
None required Less than Significant
(Similar)
GEO-5. Alternative 1 construction could uncover
paleontological resources in geologic deposits during
earthwork activities. If improperly handled, such
resources could be adversely impacted.
MM GEO-1 Less than Significant
with Mitigation
(Similar)
3.7 Hazards, Hazardous Materials, and Wildfires
HAZ-1. Alternative 1 would exacerbate wildfire
risks by exposing occupants to wildfire hazards and
impairing emergency response and would require
wildfire fuel management in the Irish Hills Natural
Reserve.
MM HAZ-1
MM HAZ-2
MM HAZ-3
MM HAZ-4
MM HAZ-5
Significant and
Unavoidable
(Less)
HAZ-2. Alternative 1 would potentially expose
persons to toxic, hazardous, or otherwise harmful
chemicals through accidental conditions involving
None required Less than Significant
(Similar)
01752
5.0 ALTERNATIVES
5-40 Froom Ranch Specific Plan
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
the release of hazardous materials into the
environment.
HAZ-3. Alternative 1 site is located within the
ALUP Safety Areas and would potentially result in
an airport-related safety hazard for people residing or
working in the Project site.
None required Less than Significant
(Similar)
3.8 Hydrology and Water Quality
HYD-1. Alternative 1 construction activities would
result in impacts to water quality due to polluted
runoff and increased erosion or siltation.
MM HYD-1
MM HYD-2
MM HYD-3
Less than Significant
with Mitigation
(Less)
HYD-2. Alternative 1 would potentially exacerbate
flooding and erosion hazards onsite and in areas
downstream, particularly related to the proposed
alignment and design of Froom Creek and developed
areas of the site.
MM HYD-4 Less than Significant
with Mitigation
(Similar)
HYD-3. Operation of Alternative 1 would potentially
impact water quality of Froom Creek and San Luis
Obispo Creek due to polluted urban runoff and
sedimentation.
None required Less than Significant
(Similar)
HYD-4. Alternative 1 would involve development of
new impervious surfaces and potentially interfere
with groundwater recharge.
None required Less than Significant
(Similar)
3.9 Land Use and Planning
LU-1. Alternative 1 would allow urban development
above the 150-foot elevation and would relocate
portions of the Froom Ranch Dairy complex, which
would potentially conflict with City General Plan
policies adopted for the purpose of avoiding impacts
to visual, biological, and cultural resources and
wildfire hazards.
MM BIO-1
MM BIO-2
MM BIO-3
MM BIO-4
MM BIO-5
MM BIO-6
MM BIO-9
MM BIO-10
MM BIO-11
MM BIO-12
MM BIO-13
MM BIO-14
MM CR-9
MM CR-10
MM CR-11
MM CR-12
MM CR-13
MM CR-14
Significant and
Unavoidable
(Less)
01753
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-41
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
MM HAZ-1
MM HAZ-2
MM HAZ-3
MM HAZ-4
MM HAZ-5
LU-2. Alternative 1 would potentially be
inconsistent with existing easements and setback
requirements onsite.
None Required Less than Significant
(Incrementally Less)
3.10 Noise
NO-1. Alternative 1 construction, including site
grading and heavy truck trips, would generate noise
levels that exceed thresholds established in the City’s
General Plan NE and Noise Guidebook with
potential impacts to sensitive receptors.
MM NO-1
MM NO-2
MM NO-3
Less than Significant
with Mitigation
(Incrementally Less)
NO-2. Alternative 1 construction activities (e.g.,
excavation, transportation of heavy equipment) could
result in exposure of sensitive receptors and
buildings to excessive groundborne vibration.
None required Less than Significant
(Less)
NO-3. Long-term operational noise impacts would
include higher roadway noise levels from increased
vehicle traffic generated by Alternative 1,
Alternative 1 operational noise, and exposure of
future residents to high noise levels that could result
in the exceedance of thresholds in the City’s General
Plan Noise Element and Noise Guidelines.
None Required Less than Significant
(Similar)
NO-4. Future residents and occupants of Alternative
1 could be exposed to periodic high noise levels
from nearby commercial uses (e.g., delivery trucks,
forklifts, backup alarms) that would exceed City
thresholds for residential land uses.
MM NO-4 Less than Significant
with Mitigation
(Similar)
3.11 Population and Housing
PH-1. Residential and commercial development
associated with the Project would induce population
growth.
None required Less than Significant
(Similar)
PH-2. Alternative 1 would provide additional
housing for the City, assisting the jobs-to-housing
ratio.
None required Less than Significant
(Similar)
PH-3. The construction of affordable housing units
under the Project would provide additional
affordable housing for the City.
None required Less than Significant
(Similar)
3.12 Public Services and Recreation
PS-1. Alternative 1 would increase demand on the
SLOPD for police protection services.
None required Less than Significant
(Similar)
01754
5.0 ALTERNATIVES
5-42 Froom Ranch Specific Plan
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
PS-2. Alternative 1 would increase the demand for
SLOFD and CALFIRE fire protection services and
create potential declines in firefighter-to- resident
ratios, however would be located within the accepted
response time performance area. Development of
senior residential uses, which are associated with
extraordinary calls for emergency medical service,
would increase emergency calls for service beyond
what the SLOFD anticipates being able to
accommodate.
None required Less than Significant
(Similar)
PS-3. Alternative 1 would generate increases in
enrollment at public schools (especially C.L.
Elementary and Laguna Middle).
None required Less than Significant
(Similar)
PS-4. Alternative 1 would increase the demand for
public parkland and neighborhood parks from
increased residential population.
MM PS-1
MM PS-2
Less than Significant
with Mitigation
(Incrementally Less)
3.13 Transportation and Traffic
TRANS-1. Alternative 1 construction activities
would potentially create traffic impacts due to
congestion from construction vehicles (e.g.,
construction trucks, construction worker vehicles,
equipment, etc.) as well as temporary traffic lane and
sidewalk closures.
MM TRANS-1 Less than Significant
with Mitigation
(Incrementally Less)
TRANS-2. Under Existing plus Project conditions,
the addition of Alternative 1 traffic would exacerbate
existing queuing and peak hour traffic for
automobiles, and poor levels of service for
pedestrians and bicycle modes of transportation,
causing transportation deficiencies in the Project
vicinity.
MM AQ-6
MM TRANS-2
MM TRANS-3
MM TRANS-4
MM TRANS-5
MM TRANS-6a
MM TRANS-6b
MM TRANS-7
MM TRANS-8
MM TRANS-9
MM TRANS-10
MM TRANS-11
Significant and
Unavoidable
(Similar)
TRANS-3. Under Near-Term plus Project (Scenario
2) conditions, the addition of Alternative 1 traffic
would exacerbate existing queuing and peak hour
traffic for automobiles and poor levels of service for
pedestrians and bike modes of transportation,
causing transportation deficiencies in the Project
vicinity.
MM TRANS-2
MM TRANS-5
MM TRANS-6a
MM TRANS-6b
MM TRANS-7
MM TRANS-8
MM TRANS-9
Significant and
Unavoidable
(Similar)
01755
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-43
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
MM TRANS-12
MM TRANS-13
MM TRANS-14
MM TRANS-15
MM TRANS-16
MM TRANS-17
MM TRANS-18
MM TRANS-19
MM TRANS-20
TRANS-4. Alternative 1 would result in traffic
safety impacts and inadequate emergency access and
evacuation options, resulting in potential for
structural damage, injuries, or loss of life due to
wildland fires or other emergency situations.
MM HAZ-4
MM TRANS-1921
MM TRANS-2022
MM TRANS-2123
Less than Significant
with Mitigation
(Incrementally Less)
TRANS-5. Onsite circulation would result in safety
impacts to pedestrian and bicycle access.
MM TRANS-2224 Less than Significant
with Mitigation
(Incrementally Less)
TRANS-6. Under long-term Cumulative plus Project
conditions, Alternative 1-generated traffic would
result in a cumulatively considerable contribution to
traffic for automobiles and poor levels of service for
pedestrians and bike modes of transportation,
causing transportation deficiencies in the Project
vicinity.
MM TRANS-2
MM TRANS-8
MM TRANS-9
MM TRANS-12
MM TRANS-13
MM TRANS-14
MM TRANS-16
MM TRANS-18
MM TRANS-25
MM TRANS-2326
MM TRANS-2427
MM TRANS-2528
MM TRANS-29
MM TRANS-30
Less than Significant
with Mitigation
(Incrementally Less)
3.14 Utilities and Energy Conservation
UT-1. Alternative 1 would require the expansion of
utility infrastructure to serve new development,
including water, sewer, natural gas, and electricity
into the site; the construction of which could cause
environmental effects.
MM AQ-1
MM BIO-1
MM CR-3
MM CR-4
MM CR-5
MM HAZ-1
MM HYD-1
Less than Significant
with Mitigation
(Less)
01756
5.0 ALTERNATIVES
5-44 Froom Ranch Specific Plan
Final EIR
Table 5-7. Alternative 1 Impacts, Mitigation Measures, and Residual Impacts
(Continued)
Impacts Mitigation Measures Residual Significance
MM HYD-2
MM NO-1
MM NO-2
MM NO-3
MM NO-4
MM TRANS-1
MM UT-1
UT-2. Alternative 1-related increases in water use
would increase demand for the City’s potable water
supply.
None required Less than Significant
(Similar)
UT-3. Alternative 1-generated wastewater would
contribute to demand for wastewater collection
facilities and remaining available and planned
capacity of the City’s WRRF.
MM UT-2 Less than Significant
with Mitigation
(Similar)
UT-4. Alternative 1 would generate additional solid
waste for disposal at the Cold Canyon Landfill.
None required Less than Significant
(Incrementally Less)
UT-5. Alternative 1 would result in an increase of
energy consumption and requirement for additional
energy resources.
None required Less than Significant
(Similar)
3.15 Mineral Resources
MN-1. Alternative 1 implementation would result in
the loss of the existing onsite red rock quarry (Froom
Ranch Pit).
None required Less than Significant
(Similar)
Aesthetics and Visual Resources
Under Alternative 1, site design alterations would substantially reduce aesthetic impacts in
comparison to the Project. Although total residential units and commercial square footage
would remain the same, urban development would not occur above the 150-foot elevation
line. Avoiding development of the Upper Terrace of Villaggio would reduce impacts to
scenic resources, including natural habitats, historic resources, and rock outcroppings, that
are visible to viewers in the surrounding area, including within the public trail system of
the Irish Hills Natural Reserve. Further, relocation of the public park to the northwest
corner of the Project site would relocate residential development to areas below the 150-
foot elevation and reduce impacts to the scenic transition between adjacent natural habitats
and residential development in the Madonna Froom Ranch.
01757
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-45
Final EIR
Impact VIS-1 regarding impacts to scenic resources from a state scenic highway or local
scenic roadway would be similar impacts under the Project. Unlike the Project, Alternative
1 would not include development within the Upper Terrace and scenic natural resources
within this area, including serpentine rock outcroppings, woodlands, open grasslands and
riparian habitat, would be preserved. Similar to the Project, impacts to views from the
portion of U.S. 101 eligible for State Scenic Highway designation would not be significant,
nor would impacts to viewers along Calle Joaquin (see KVA 1). Similar to the Project,
views from LOVR would be substantially impacted, and increased building density and
height under Alternative 1 would incrementally increase the severity of these impacts (see
KVAs 2 and 3). However, implementation of MM VIS-1 would ensure that landscape
screening shields views of development as much as possible, and impacts would continue
to be less than significant with mitigation.
Impact VIS-2, which addresses impacts to the
visual character of the Project site, would be
substantially reduced under Alternative 1 as
compared to the Project. While residential
buildings would be up to 10 feet taller under
the Project, the overall aerial extent and level
of development and associated changes in
aesthetic character of the Project site would be
less than under the Project. Under Alternative
1, the Upper Terrace of Villaggio would
remain undeveloped and scenic undeveloped
open grasslands, woodlands, and chaparral
habitats adjacent to the Irish Hills Natural Reserve would remain intact. Alternative 1
would improve the visual transition between the Irish Hills Natural Reserve and residential
development as compared to the Project by relocating the public park adjacent to the Irish
Hills Natural Reserve and relocating residential uses eastward. By avoiding development
above the 150-foot elevation line, Alternative 1 would preserve aesthetic resources and
provide a more natural transition from rural to urban settings, particularly for viewers
located above proposed development within the Irish Hills Natural Reserve (see
Alternative KVAs 4 and 5). Including implementation of MM VIS-1, impacts under
Alternative 1 would be substantially less than under the Project and would be less than
significant with mitigation.
Alternative 1 would eliminate development of
the Upper Terrace portion of Villaggio,
preserving open space within scenic vistas
designated by the General Plan COSE. Photo
source: hikespeak.com
01758
5.0 ALTERNATIVES
5-46 Froom Ranch Specific Plan
Final EIR
Impact VIS-3, associated with increased night lighting, would remain largely similar to the
Project as the levels of lighting would be similar under this alternative. However, avoiding
residential development within the Upper Terrace of Villaggio and northwestern portion
of the Project site would reduce the overall development footprint and adverse impacts
from nighttime lighting or glare, particularly adjacent to the Irish Hills Natural Reserve.
Accordingly, as under the Project, impacts would be considered less than significant under
Alternative 1.
Cumulative impacts on visual resources would be less than under the Project. Cumulative
development is anticipated in the General Plan LUE and would be consistent with impacts
associated with implementation of City General Plan policies. Alternative 1, in
combination with approved, pending, and proposed development in San Luis Obispo,
would contribute toward creating a transition from the rural environment along the City’s
perimeter to the urban environment. Consistent with long-term buildout under the General
Plan, Alternative 1 and cumulative projects would be required to adhere to the design
standards of the General Plan LUE and would be subject to discretionary review by the
Planning Commission and/or City Council, as well as final design review by the
Architectural Review Commission (with a recommendation to the final action hearing
body). As identified in the LUCE Update EIR, all development that adheres to the General
Plan LUE policies would result in less than significant impacts to aesthetic and visual
resources. Unlike the Project, Alternative 1 would not include urban development above
the 150-foot elevation line and would not be inconsistent with City policies designed to
preserve scenic resources including Policy LUE 6.4, Hillside Policies. Additionally, this
alternative would not include growth-inducing effects on adjacent parcels to create pressure
for development above the 150-foot elevation. Therefore, the potential for cumulative
impacts to aesthetic and visual resources would be less when compared to the Project and
would be considered less than significant with mitigation.
01759
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-47
Final EIR
KVA 1 – Project Compared to Alternative 1
KVA 1: Fleeting distant views of the Project site are available from U.S. 101. Under Alternative 1, the
Upper Terrace would not be developed and direct views to the Irish Hills, including ridgelines,
outcroppings, and natural vegetation, would be improved. Residential structures under this Alternative
would be up to 10 feet taller than under the Project, but since the view from U.S. 101 is distant and
channelized along Calle Joaquin, the increase in height is incremental and would not be noticed by viewers
compared to the Project. Commercial development and street trees up to approximately 20 to 30 feet high,
as well as telephone poles and wiring, would continue to impede views of the Project site.
Project
Alternative 1
01760
5.0 ALTERNATIVES
5-48 Froom Ranch Specific Plan
Final EIR
KVA 2 – Project Compared to Alternative 1
KVA 2: Under Alternative 1, multi-story development would eliminate most onsite scenic resources
visible from this portion of LOVR, similar to the Project. Residential structures in Villaggio are not highly
visible from this KVA, so even though these structures would be approximately 10 feet taller than under
the Project, visual differences between building heights compared to the Project would be incremental
with residential structures are set back from LOVR. As under the Project, dense willow riparian
vegetation of 15 to 20 feet in height along most of the LOVR frontage that currently obscures views of
the Project site would be removed. However, within the context of surrounding commercial development,
this alternative would remain consistent in character, size, and scale of nearby development.
Project
Alternative 1
01761
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-49
Final EIR
KVA 3 – Project Compared to Alternative 1
KVA 3: As under the Project, development of multi-story residential buildings would impede visibility of
aesthetic resources, including hillsides of the Irish Hills Natural Reserve, from the LOVR Overpass.
Residential buildings in Villaggio allowed under this alternative would be up to 10 feet taller than under
the Project, although views from this KVA would only be incrementalally different given intervening
distances. However, as no development would be permitted above the 150-foot elevation, views of the Irish
Hills and associated scenic natural features would be maintained.
Project
Alternative 1
01762
5.0 ALTERNATIVES
5-50 Froom Ranch Specific Plan
Final EIR
KVA 4 – Project Compared to Alternative 1
KVA 4: Under this alternative, the trailhead park would be developed in the northwestern portion of the
site bordering the Irish Hills Natural Reserve within the existing quarry area, allowing for smoother
visual transitions between proposed rural and urban land uses; although new development would be
visible from this KVA within Madonna Froom Ranch in the mid-range view and Villaggio structures in
the distant view, new structures would be clustered away from the Irish Hills Natural Reserve with other
buildings along the eastern portion of the Project site. The foreground view of this KVA would contain
park and open space with the relocated and rehabilitated Froom Ranch Dairy complex, which would also
maintain a more historically accurate visual context for this historic resource.
Project
Alternative 1
01763
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-51
Final EIR
KVA 5 – Project Compared to Alternative 1
KVA 5: Impacts to visual and scenic resources from this KVA would be less than under the Project, as
development of residential units within the Upper Terrace would be avoided, preserving views of natural
habitats and other scenic resources in this area. While remaining multi-story buildings on the Project
site would be up to 10 feet taller than under the Project, these changes would appear incremental from
this KVA given intervening distances and adjacent urban land uses to the north and east.
Project
Alternative 1
01764
5.0 ALTERNATIVES
5-52 Froom Ranch Specific Plan
Final EIR
Agricultural Resources
Similar to the Project, development of Villaggio and Madonna Froom Ranch and
associated urban infrastructure under this alternative would continue to result in permanent
conversion of prime soils if irrigated to urban development, along with disruption of
existing grazing activities on the site. Similar to the Project, development occurring under
Alternative 1 would convert the majority of agricultural soils onsite, which are considered
prime farmland if irrigated. Since the Upper Terrace of the Villaggio would not be
developed, loss of grazing land and Farmland of Local Potential occurring above the 150-
foot elevation would not occur under this alternative. Under Alternative 1, the Upper
Terrace would be designated as open space to preserve resource values in this area. In total,
Alternative 1 would include 66.8 acres of open space which include 59.7 acres of dedicated
open space and an existing 7.1-acre (minimum) agricultural and open space easement. In
total, Alternative 1 would result in dedication of approximately 61 percent of the site as
open space, approximately 13 percent greater than under the Project.
Impact AG-1, which addresses the development of land designated as Farmland of Local
Potential to non-agricultural uses, would be similar under Alternative 1. As under the
Project, this alternative would not result development of soils that are considered prime as
no prime soils exist onsite. Therefore, impacts would remain less than significant.
Impact AG-2, addressing potential agricultural zoning conflicts, would be reduced under
Alternative 1, although development of urban uses on agricultural land considered prime
if irrigated would continue to occur. Unlike the Project, residential land uses would not be
constructed in the Upper Terrace of Villaggio, thereby avoiding development on
agricultural lands within this area. As under the Project, Alternative 1 would be planned
for urban development with a Specific Plan (SP) land use designation under the General
Plan 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.
Therefore, similar to the Project, Impact AG-2 would be adverse, but less than significant.
Impact AG-3, associated with reduced viability of the existing agricultural easement within
the Project site, would be similar to the Project, since the agricultural easement overlies
areas within the Lower Area. However, realignment of the easement would support
conservation of habitat and biological resources, particularly the protection of existing
wetlands within this 1.6-acre portion east of Calle Joaquin, which is consistent with the
easement’s preservation intent. Thus, adjustment of the 7.1-acre easement would continue
01765
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-53
Final EIR
to meet the objectives and LAFCO requirements of the easement agreement and impacts,
like the Project, are considered less than significant.
As under the Project, this alternative would contribute incrementally to the loss of
agricultural land (Grazing Land and Farmland of Local Potential) to development within
the City. However, this alternative would not contribute to the loss of Important Farmland.
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. Therefore, this alternative would
not contribute to a cumulatively considerable loss of significant agricultural resources, and
cumulative impacts would remain less than significant.
Air Quality and GHG Emissions
As under the Project, this alternative would use the same construction equipment, contain
similar land uses, the same number of residential units, and would result in similar trip
generation and air quality emissions. CalEEMod modeling for this alternative identifies
impacts that would be slightly less compared to the Project (see Tables 5-8 through 5-12,
below; also see Appendix D) largely due to the reduced area of disturbance required to
construct the development by eliminating development above the 150-foot elevation on the
site.
Impact AQ-1, which addresses construction emissions, would be similar to the Project.
Alternative 1 would involve slightly more construction activities on site at the same time
and increased import of fill, as excess material would no longer be available from onsite
grading within the Upper Terrace of Villaggio. This would create a slightly higher
maximum daily emissions level from air emissions; Alternative 1 is estimated to generate
a maximum of 3.55 lbs/day more reactive organic gases (ROG) and nitrogen oxides (NOx)
compared to the Project, which is nominal, and daily maximum PM2.5 is estimated to
decrease by 0.57 lbs/day compared to the Project. This impact would be similar to the
Project and construction-related air quality impacts would still exceed the SLO County
APCD’s Tier 1 Quarterly thresholds for construction emissions of ROGs and NOx (Table
5-8 and 5-9). As under the Project, required implementation of a Construction Activity
Management Plan (CAMP) (MM AQ-1), use of low or no volatile organic compound-
emission paint (MM AQ-2), and use of an offsite mitigation strategy (MM AQ-3), would
bring DPM emissions below SLO County APCD Tier 2 and Tier 1 quarterly thresholds.
Implementation of these mitigation measures would reduce construction-related air quality
impacts to a less than significant level, consistent with SLO County APCD methodology.
01766
5.0 ALTERNATIVES
5-54 Froom Ranch Specific Plan
Final EIR
Therefore, residual impacts under this alternative would remain less than significant with
mitigation.
Table 5-8. Maximum Short-term Construction Emissions (Unmitigated)
ROG NOx ROG +
NOx CO SO2 PM10 DPM (Exhaust
PM2.5)
Overall Construction (Maximum Daily Emission)
Peak Daily Emissions
(lbs/day)
182.08 193.29 375.37 110.21 0.27 30.88 6.66
Peak Quarterly Emissions
(tons/qtr)1
1.16 5.52 8.242 3.17 <0.01 0.91 0.19
APCD Daily Thresholds
(lbs/day)
-- -- 137 -- -- -- 7
APCD Quarterly
Thresholds – Tier 1
(tons/qtr)
-- -- 2.5 -- -- 2.5 0.13
Above Threshold? -- -- YES -- -- NO YES
APCD Quarterly
Thresholds – Tier 2
(tons/qtr)
-- -- 6.3 -- -- -- 0.32
Above Threshold? -- -- YES -- -- NO NO
1 tons/qtr calculated based on maximum annual emissions divided by four (i.e., one quarter of a year).
2 tons/qtr for ROG + NOx emissions calculated in CalEEMod.
See Appendix D for CalEEMod worksheets.
Table 5-9. Maximum Short-term Construction Emissions (Mitigated)
ROG NOx ROG +
NOx CO SO2 PM10 DPM (Exhaust
PM2.5) CO2e
Overall Construction (Maximum Daily Emission)
(lbs/day) 60.71 122.86 183.57 129.39 0.27 19.24 4.36 27,336
(tons/qtr) includes
Fugitive Dust1
0.42 3.49 5.092 3.73 <0.01 0.52 0.13 698
APCD Daily
Thresholds (lbs/day)
-- -- 137 -- -- -- 7 --
APCD Quarterly
Thresholds – Tier 1
(tons/qtr)
-- -- 2.5 2.5 0.13 --
Above Threshold? -- -- YES -- -- NO NO --
APCD Quarterly
Thresholds – Tier 2
(tons/qtr)
-- -- 6.3 -- -- -- 0.32 --
Above Threshold? -- -- NO -- -- NO NO --
1 tons/qtr calculated based on maximum annual emissions divided by four (i.e., one quarter of a year).
2 tons/qtr for ROG + NOx emissions calculated in CalEEMod.
See Appendix D for CalEEMod worksheets.
01767
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-55
Final EIR
Impact AQ-2, addressing long-term impacts of operational air emissions, would be similar
to the Project. This Alternative has the same number of residential units and commercial
square footage, which would have similar trip generation, energy demand, and water
demand as the Project. Therefore, operational-related air quality impacts from onsite
energy use, water demand, and mobile emissions would be the same as the Project. Like
the Project, while this alternative would not exceed annual emissions thresholds, projected
maximum daily emissions would be above the established APCD daily thresholds for
operational emissions of ROG + NOx (see Table 5-10). Like the Project, implementation
of MM AQ-4, which requires implementation of all feasible measures within Table 3-5 of
the APCD CEQA Air Quality Handbook (see Table 3.3-9), would also apply to reduce
adverse operational effects. However, many of the measures listed in MM AQ-4 do not
include quantifiable air quality emissions reductions. As a result, the CalEEMod results for
Alternative 1 demonstrate that Alternative 1 operational emissions would exceed
SLOAPCD’s maximum daily thresholds for ROG and NOx. Therefore, like the Project,
long-term operational impacts would continue to be significant and unavoidable.
Table 5-10. Maximum Long-term Operational Emissions (Unmitigated)
ROG NOx ROG +
NOx CO SO2 PM10
DPM
(Exhaust
PM10)
CO2e
Overall Operational (Maximum Daily Emission)
Area (lbs/day) 24.27 0.60 24.87 51.96 <0.01 0.29 0.29 96
Energy (lbs/day) 0.38 3.35 3.73 2.16 0.02 0.26 0.26 4,169
Mobile (lbs/day) 6.70 23.10 29.80 65.53 0.21 20.47 0.17 21,212
Total (lbs/day) 31.35 27.05 58.4 119.65 0.24 21.00 0.72 25,477
Threshold
(lbs/day)
- - 25 550 - 25 1.25 -
Significance? - - YES NO - NO NO -
Overall Operational (Annual Emission)
Area (tons/year) 4.40 0.10 4.50 8.57 <0.01 0.05 0.05 14
Energy
(tons/year)
0.07 0.61 0.68 0.39 <0.01 0.05 0.05 2,235
Mobile
(tons/year)
1.05 3.99 5.04 11.06 0.03 3.35 0.03 3,129
Waste
(tons/year)
- - - - - - - 253
Water
(tons/year)
- - - - - - - 142
Total
(tons/year)
5.52 4.7 10.22 20.02 0.05 3.45 0.13 5,773
Threshold
(tons/year)
- - 25 - - 25 - -
Significant? - - NO - - NO -
Note: Values in this table are rounded for reporting purposes.
See Appendix D for CalEEMod worksheets.
01768
5.0 ALTERNATIVES
5-56 Froom Ranch Specific Plan
Final EIR
Impact AQ-3, addressing toxic air contaminants (TAC) or naturally occurring asbestos
(NOA), would be less than under the Project. There are no existing sensitive receptors on
the Project site or vicinity that would be exposed to significant Project construction
emissions. Unlike the Project, no occupation of the site would occur concurrent with heavy-
haul truck traffic, grading, and excavating, so the potential for exposure of residents to
TAC from diesel emissions during construction would be substantially reduced or avoided.
Further, areas within the Upper Terrace that potentially contain NOA would not be
excavated under Alternative 1 and any soil-disturbing excavation would occur prior to
occupancy of Villaggio or Madonna Froom Ranch. Similar to the Project, this alternative
is outside of recommended buffer zones of sources of potential TAC, such as congested
highways or intersections, and planned residential and commercial uses would not generate
substantial amounts of TACs. Therefore, this alternative is not expected to expose sensitive
receptors to substantial levels of TACs or NOA. Therefore, as under the Project, impacts
would continue to be considered less than significant.
Impact AQ-4, addressing global climate change from GHG emissions, would be similar to
the Project. While Alternative 1 would substantially reduce the area of disturbance and
onsite excavation and earthmoving, this alternative would need increased offsite import of
fill, since excavation of the Upper Terrace would not occur and would not provide an onsite
source of needed fill for Madonna Froom Ranch. These increased diesel haul truck trips
would slightly increase construction-related GHG emissions based on CalEEMod
estimates, by approximately 6.6 metric tons of carbon dioxide equivalent (MT CO2e) more
than the Project’s total GHG emissions, which is within the margin of error for such
projections. Construction activities under this alternative would generate an estimated
7,859 MT CO2e (see Tables 5-11 and 5-12). Amortized over a 25-year period (consistent
with SLO County APCD methodology), construction of Alternative 1 would result in
approximately 314 MT CO2e per year (MT CO2e/yr). Unmitigated operational GHG
emissions generated by Alternative 1 would be approximately 5,773 MT CO2e. Combined
with construction emissions amortized over a 25-year period (314 MT CO2e), total
unmitigated GHG emissions would be approximately 6,087 MT CO2e. Similar to the
Project, Alternative 1 would need to consider the goals of SB 32 and statewide goals for
GHG reduction by 2030. With application of MM AQ-4 through -6 to include site-specific
and communitywide GHG reduction strategies in the FRSP to attain as close to 0 MT
CO2e/yr as feasible for stationary source emissions; however, mobile source emissions
have potential to result in continued inconsistency with GHG reduction targets. Impact
AQ-4 would remain significant and unavoidable.
01769
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-57
Final EIR
Table 5-11. Estimated Construction GHG Emissions (Unmitigated)
Year Annual Emissions MT CO2e
2020 2,791
2021 1,560
2022 1,689
2023 1,020
2024 799
Total 7,859
Amortized over 25 years 314
Table 5-12. Estimated Operational GHG Emissions (Unmitigated)
Emission Source Annual Emissions MT CO2e
Area 14
Energy Use 2,235
Mobile 3,129
Water Use 253
Solid Waste 142
Total 5,773
Amortized Construction Emissions 314
Total Project GHG Emissions 6,087
Under Alternative 1, Impact AQ-5 would be similar to the Project with regards to potential
inconsistencies with the Clean Air Plan. Population increases under Alternative 1 would be
similar to the Project, as would total added average daily trips (ADT). As a result, similar to
the Project, the rate of increase in population would continue to exceed the allowable rate of
increase in vehicle trips and miles traveled, and would therefore remain inconsistent with the
Clean Air Plan. As under the Project, Alternative 1 would install one new bus stop along
southbound LOVR during Phase 1, ensuring transit services would be available in the Project
vicinity prior to occupancy of the first unit. Despite implementation of MM AQ-2, MM
TRANS-5, and MM TRANS-8 through -10 requiring reductions in Project VMTs, this
alternative would remain inconsistent with the City’s Clean Air Plan due to continued
exceedance of population growth, vehicle trip, and VMT projections for the region. Similar
to the Project, impacts would be significant and unavoidable.
Cumulative air quality impacts would be similar to the Project. This alternative would also
result in significant and unavoidable long-term operational air quality impacts within an Air
Basin that is in non-attainment and would, therefore, contribute to cumulatively considerable
01770
5.0 ALTERNATIVES
5-58 Froom Ranch Specific Plan
Final EIR
impacts to air quality emissions in the region. In addition, the LUCE Update Final EIR also
determined that full buildout under the General Plan would be potentially inconsistent with
the Clean Air Plan, and that cumulative impacts related to the increase in air quality
emissions resulting from implementation of this alternative would be significant and
unavoidable.
This alternative would contribute incrementally to GHG emissions regionally and
statewide, but MM AQ-4 through MM AQ-6 would reduce construction and operational
emissions to as close to 0 MT CO2e/yr as feasible, consistent with SB 32 and emerging
City regulation requiring net-zero GHG emissions by 2035. Therefore, this alternative
would not contribute to a cumulatively considerable contribution of GHGs, and cumulative
impacts would be less than significant with mitigation, similar to the Project.
Biological Resources
Under this alternative, biological resource impacts related to loss of wetland, riparian, and
upland habitats and potential effects on sensitive, threatened, and endangered species
would be substantially reduced compared to the Project. Residences and related
infrastructure would not be constructed within the Upper Terrace of Villaggio, which
would substantially reduce impacts to serpentine native bunchgrass grassland habitats and
minimize impacts to springs, seeps, and wetland habitats along Drainages 1, 2, and 3, as
well as associated impacts to 12 special status plant species in the Upper Terrace. Impacts
to wildlife movement and wildlife corridors would also be substantially reduced and
consistency with the policies of the City General Plan would be substantially increased. In
particular, consistency with LUE Policies 1.8.6, Wildlife Habitats, and 6.4.7, Hillside
Planning Areas, and COSE Policies 7.3.1, Protect Listed Species, 7.3.2, Protect Species of
Local Concern, 7.3.3, Wildlife Habitat and Corridors, and 7.7.7, Preserve Ecotones, would
be improved.
01771
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-59
Final EIR
However, development in the
southwest corner of the lower portion
of Villaggio, consisting of up to 12
Villas along Froom Creek and within
a cul-de-sac at the confluence of
Drainages 1, 2 and 3 and adjacent to
a large serpentine outcrop, would
continue to impact sensitive
biological resources and create
potential inconsistencies with City
General Plan policies. The residential
cul-de-sac with Villas would be
located immediately adjacent to wetlands along Drainages 1, 2, and 3 and potential special
status plants on an adjacent serpentine rock outcrop. The development would also be
located proximate to California bay woodland and may generate the need for fire buffer
clearance within this woodland. Although reduced when compared to the Project, the Villas
would continue to isolate the restored Froom Creek and sensitive natural communities such
as the Calle Joaquin wetlands and LOVR ditch riparian habitat from high quality grassland
and other habitats in the southern portion of the Project site above the 150-foot elevation
line and the Irish Hills Natural Reserve. While these natural communities would continue
to have a connection to the Irish Hills along the portion of the restored Froom Creek located
between Villaggio and Madonna Froom Ranch, the broad existing ecotones with grasslands
would be eliminated. While this alternative would substantially reduce impacts and
improve consistency with City General Plan Polices, these units and associated
infrastructure would continue to interrupt habitat continuity, wildlife habitat and corridors,
and potentially impact special status plant species and thus would remain potentially
inconsistent with the intent of multiple City General Plan policies, particularly COSE
Policies 7.3.2, 7.3.3 and 7.7.7. Similar to the Project, this impact would require mitigation
for targeted site redesign to reduce and/or avoid, as further described below.
Impact BIO-1, addressing construction impacts on sensitive riparian, wetland, and native
grassland habitats, identified as sensitive natural communities under state and City policy,
would be less severe than under the Project, as residential development above the 150-foot
elevation would not occur, thereby preserving the highest-quality habitat within the site.
Avoiding development in the Upper Terrace of Villaggio would preserve approximately
3.9 acres of native serpentine bunchgrass grassland habitat that would be impacted under
Potential impacts to approximately 3.9 acres of native
serpentine bunchgrass grassland habitat and associated
special status plant species would be avoided under
Alternative 1.
01772
5.0 ALTERNATIVES
5-60 Froom Ranch Specific Plan
Final EIR
the Project. This bunchgrass is a designated sensitive natural community considered
biologically important by the California Department of Fish and Wildlife (CDFW). By
avoiding development in the Upper Terrace of Villaggio, this alternative would reduce the
perimeter length of residential development abutting open space by approximately 3,904
feet, equating to a 49 percent reduction of the wildland-urban interface. This would reduce
habitat disturbance related to construction and maintenance of on- and offsite wildfire
buffers by approximately 9.0 acres, including impacts to serpentine rock outcroppings and
native serpentine bunchgrass grassland habitat.
Due to a reduced amount of development and required vegetation clearance for wildfire
protection, 3.23 acres of coast live oak/California bay woodland habitat and 6.85 acres of
coastal shrub/chaparral habitat would no longer be impacted. In addition, sensitive habitats
within the Upper Terrace would not be subject to gradual degradation over time through
trampling, landscape maintenance, introduction of non-native species, or other activities of
new residents. Additionally, this alternative would not result in grading, vegetation
clearance and management, or culvert-headwall installation along the majority of
Drainages 1, 2, or 3, reducing Project impacts to creek, stream, and wetland habitat, as well
as associated endangered species.
Impacts of Alternative 1 on riparian
habitat areas would be similar to the
Project. Permanent direct loss of 1.13
acres of riparian scrub would result from
construction of the proposed stormwater
detention basin, realignment of the Froom
Creek corridor, widening of LOVR, and
construction of a new Project entrance
road. Similar to the Project, major
changes to the hydrology of the Calle
Joaquin wetlands could result in adverse
effects to the long-term biological
productivity or functions of these wetlands, as well as impacts to water quality and sensitive
habitat from potential introduction of sediment runoff, siltation, and accidental spillage of
fuel and lubricants.
Unlike the Project, this alternative would also include construction of two additional
emergency access roads that could impact native riparian habitats. The first emergency
Avoidance of impacts to Drainages 1, 2, and 3 under
Alternative 1 would also reduce impacts to the Calle
Joaquin wetlands, which provides high-quality
habitat for several plant and annual species
(Appendix E).
01773
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-61
Final EIR
access road would cross the proposed Froom Creek realignment and the LOVR ditch to
provide access to LOVR approximately 800 feet southeast from the primary Project access
road at Auto Park Way. Although Applicant-prepared conceptual plans do not provide
specific details, this road would require construction of a second free-span bridge of
approximately 24 feet in width across the 60-foot-wide realigned Froom Creek channel
and a new box culvert of 24 to 48 inches across the LOVR ditch. This new emergency
access road would lead to additional habitat loss and fragmentation and would further
decrease the hydrologic and habitat connectivity within Froom Creek and the LOVR ditch
as compared to the Project. Under this alternative, an additional emergency access road
would also be constructed along the southwest edge of the proposed stormwater detention
basin on the Mountainbrook Church property easement. This emergency access would
connect to Calle Joaquin and would cross the confluence of the three drainages near Froom
Creek, as well as cross Drainage 4 near Calle Joaquin, an intermittent, willow-lined
roadside conveyance. While conceptual plans are not currently available, this access road
would also likely be 24 feet in width and would require installation of a box culvert across
Drainage 4, impacting willow riparian vegetation.
Similar to the Project, the following mitigation measures would be required to minimize
potential impacts:
MM BIO-1: implementation of a Biological Mitigation Plan
MM BIO-2: ensures a qualified Environmental Monitor will oversee compliance of
construction activities with the Biological Mitigation Plan.
MM BIO-3: requirement that the Biological Mitigation Plan include a Habitat
Mitigation and Monitoring Plan.
MM BIO-4: requirement that the Biological Mitigation Plan include avoidance and
replacement of sensitive natural communities outside approved development
footprints.
MM BIO-5: mitigates temporary and permanent impacts to wetlands, grasslands,
and riparian habitat.
MM BIO-6: timing and implementation requirements for habitat restoration.
MM BIO-13: requires relocation of buildings along the confluence of Drainages 1,
2, and 3 and Froom Creek outside of a buffer from the water courses to increase
ecologic and hydrologic connectivity.
MM HAZ-1: a Community Fire Protection Plan that protects sensitive habitats and
species to the maximum extent possible.
01774
5.0 ALTERNATIVES
5-62 Froom Ranch Specific Plan
Final EIR
The potential impacts to biological resources from Alternative 1 would be substantially
lessened with inclusion of the Project’s mitigation measures listed above. Policy
consistency with the General Plan would also be greatly improved. However, since the
emergency access roadways connecting Villaggio to Calle Joaquin and LOVR have not
been designed or engineered yet, it is possible that these features may have significant
impacts on riparian communities along the LOVR ditch and realigned Froom Creek and
on Drainage 4. For this reason, an additional mitigation measure MM BIO-Alt. 1 is
identified to ensure these alternative features are specifically mitigated.
MM BIO-Alt. 1 The additional emergency access roadway across Froom Creek and
the LOVR ditch and the southern emergency access route entering
the site from Calle Joaquin shall be reviewed by the City’s Public
Works Department, Community Development Department, Natural
Resources Manager, and Fire Department prior to adoption of the
Final FRSP and approval of the Vesting Tentative Tract Map to
ensure that design is adequate for City emergency ingress/egress
standards and minimizes impacts to riparian vegetation and wildlife
passage, and that adequate on- and offsite mitigation of impacted
riparian and wetland vegetation is provided. The City shall ensure
review and approval of these features as part of the Final FRSP
considers the siting, alignment, width, materials, and access
controls.
Alternative 1 Plan Requirements and Timing. The Applicant is
required to implement the above mitigation measures prior to FRSP
and Vesting Tentative Tract Map (VTTM) approval. The access
roads shall be integrated into the VTTM preliminary grading plan.
City staff shall ensure the above measures are incorporated into the
FRSP and VTTM prior to acceptance of the final FRSP.
Monitoring. The City shall ensure the above measure is
incorporated into the Final FRSP and VTTM prior to Project
approval.
Implementation of MM BIO-Alt. 1 under Alternative 1 would further reduce impacts to
riparian and wetland habitats as compared to the Project. Potential alignment of the
southern emergency access route under MM BIO-Alt. 1 would be designed to reduce
impacts of crossing the confluence of Drainages 1, 2, and 3 and Drainage 4.
01775
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-63
Final EIR
Alternative 1 would substantially reduce impacts to sensitive habitats and species and
wildlife corridors as compared to the Project, particularly those associated with habitats in
the Upper Terrace. This alternative as modified by the above mitigation measures would
improve consistency with several policies within the City General Plan adopted to protect
important natural resources, including LUE Policies 1.8.6, Wildlife Habitats, and 6.4.7,
Hillside Planning Areas, and COSE Policies 7.3.1, Protect Listed Species, 7.3.2, Protect
Species of Local Concern, 7.3.3, Wildlife Habitat and Corridors, and 7.7.7, Preserve
Ecotones. Because Alternative 1 would not develop the Upper Terrace and would be
required to implement additional mitigation measures to avoid disturbance, alteration, or
removal of high value habitats, Impact BIO-1 would be substantially less than under the
Project and would be considered less than significant with mitigation.
Impact BIO-2, which addresses direct and indirect adverse impacts on candidate, sensitive,
or special status species that are known to or may occur on the Project site, would also be
substantially reduced under Alternative 1. Unlike the Project, Alternative 1 would
substantially reduce impacts to sensitive habitats in the Upper Terrace that support 12
known special status plant species, as well as the potential occurrence of several other
species. Woodland areas and other habitats in the Upper Terrace would not be impacted by
fire clearance, protecting foraging, roosting, and nesting habitat for several Species of
Special Concern, including bats and birds. Additionally, avoidance of development within
the Upper Terrace would protect the majority of Drainages 1, 2, and 3 where these
drainages support a federally endangered species and provide water to sensitive plant and
animal species.
Although the development footprint for Alternative 1 would be considerably smaller than
the Project, direct and indirect impacts to species on- and offsite could continue similar to
the Project, including those resulting from construction noise, increased human presence,
and potential exposure to pollutants and hazardous materials. Riparian and wetland habitats
and associated species would also continue to be impacted.
01776
5.0 ALTERNATIVES
5-64 Froom Ranch Specific Plan
Final EIR
Mitigation measures proposed under
the Project would also be
implemented to reduce potential
impacts. These would include
implementation of MM HAZ-2, MM
BIO-1, as well as MM BIO-9,
ensuring access to riparian habitat
for special status species would not
be interrupted during construction.
MM BIO-10, minimizing impacts to
Chorro Creek Bog Thistle, MM BIO-
11, ensuring the Biological
Mitigation Plan addresses special
status wildlife species management,
and MM BIO-12, ensuring the Biological Mitigation Plan includes bat colony and
migratory and nesting bird management, would also apply. MM BIO-13 would also further
reduce impacts to creek, stream, and wetland habitat and increase habitat connectivity
between the realigned Froom Creek corridor and the high quality habitats in the Upper
Terrace area of Villaggio and the Irish Hills Natural Reserve through relocation of
residential development and associated road infrastructure outside an adequate buffer
around the confluence of Drainages 1, 2, and 3, which flow to Froom Creek. Given that
development within the Upper Terrace would not occur and all applicable mitigation
measures would be implemented under Alternative 1 as under the Project, Alternative 1
would have substantially reduced impacts on candidate, sensitive, or endangered species
known to exist on the Project site and impacts would be less than significant with
mitigation.
Impact BIO-3, addressing Project impacts to federally-protected wetlands, would be
decreased as compared to the Project. Unlike the Project, this alternative would not include
installation of culvert-headwalls or otherwise disturb Drainages 1, 2, or 3 except near the
convergence of these drainages, and would avoid approximately 0.25 acres of rare seep
wetlands in the Upper Terrace, as well as water sources for adjacent and downstream
riparian and wetland habitat. However, CDFW and USACE jurisdictional wetlands,
including the LOVR ditch and Calle Joaquin wetlands, would continue to be impacted as
a result of LOVR frontage improvements, emergency access road construction, and Froom
Creek realignment. As under the Project, implementation of MM BIO-4 would preserve
Avoidance of residential development along the
Upper Terrace under Alternative 1 would reduce
impacts to Blochman’s dudleya, a highly endangered
perennial herb that is known to exist in rocky outcrops
of the Upper Terrace area of the Project site.
(Photo: CalPhotos; photograph by Keir Morse 2016)
Alternative 1 would preserve approximately 0.25 acres of
rare seep wetlands in the Upper Terrace and ensure
hydrologic connectivity between Drainages 1, 2, and 3 and
downstream wetlands, including the Calle Joaquin
wetlands.
01777
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-65
Final EIR
open space at the confluence of Drainages 1, 2, and 3 and would greatly enhance hydrologic
connectivity between the Upper Terrace and downstream wetlands. Additionally,
geotechnical recommendations required in MM BIO-7 to reduce potential for horizontal
directional drilling operations to adversely affect Calle Joaquin wetlands would still be
required.
However, interruption or redirection of ground and surface water sources for these
wetlands from realignment of Froom Creek and adjacent development could still result in
changes in wetland habitats and characteristics. While implementation of MM BIO-1
through -3, MM BIO-5 through -7, and MM BIO-13 would partially reduce impacts to
USFWS and CDFW jurisdictional wetland areas through avoidance to the maximum extent
feasible of on- or offsite wetlands, full replacement of equivalent wetland values if
wetlands are affected would be challenging. Although impacts to wetlands in the Upper
Terrace area of Villaggio would be less than under the Project, direct and indirect impacts
to jurisdictional wetlands would continue, and impacts would remain significant and
unavoidable.
Impact BIO-4 addressing impacts on the
movement of resident or migratory
wildlife species or resident and
migratory wildlife corridors would be
substantially reduced under Alternative
1. Unlike the Project, Alternative 1
would avoid all development in the
Upper Terrace and would allow wildlife
movement across the Upper Terrace and
along Drainages 1, 2, and 3, which link
Froom Creek through the Project site to
the Irish Hills. By avoiding extensive site
alteration and construction of new
homes, roadways, trails, fences, and utility and drainage infrastructure within the Upper
Terrace, Alternative 1 would reduce noise, lighting, and glare that would disrupt wildlife
movement across the Project site. Implementation MM BIO-13 through -14 and MM BIO
Alt. 1 would further reduce such impacts. As under the Project, Calle Joaquin wetlands and
the restored Froom Creek channel could be isolated from wildlife and habitats in the Upper
Terrace and Irish Hills Natural Reserve, replacing existing broad open grassland ecotones
that currently link these habitats with intensive development, particularly near the
Alternative 1 would ensure realigned Froom Creek
would connect to high quality habitats in the Upper
Terrace and Irish Hills Natural Reserve, allowing
for safe passage between these habitats by resident
and migratory wildlife.
01778
5.0 ALTERNATIVES
5-66 Froom Ranch Specific Plan
Final EIR
confluence of Drainages 1, 2, and 3. While the realigned and restored Froom Creek corridor
is proposed to provide enhanced riparian habitat, it would be an urban creek corridor
bordered by relatively intensive development that would limit movement of terrestrial and
avian species. Long-term impacts to migrating species would be similar to the Project due
to the increase in human presence onsite, including lighting located on buildings and in
parking areas, increased noise from automobiles, and other human activities. These long-
term impacts could cause these species to be killed, to flee the area, or could disrupt
breeding and nesting efforts.
As under the Project, implementation of MM BIO-1 through -2, BIO-5 through -6, BIO-9,
BIO-11 through -12, and MM BIO-13 would reduce potential impacts to resident or
migratory wildlife and resident or migratory corridors. By ensuring the ability of resident
or migratory wildlife to access high quality habitats, Impact BIO-4 would be substantially
less severe when compared to the Project and would be considered less than significant
with mitigation.
Impact BIO-5, related to the potential
disturbance, trimming, or removal of up
to 75 mature trees, would be less severe
when compared to the Project. On the
northwestern side of the site, potentially
affected trees are located in the
developed/disturbed area adjacent to the
existing quarry and construction business.
Mature trees in the Upper Terrace in the
southwest portion of the Project site adjacent to Drainages 1, 2, and 3 would also be
potentially affected. The land use map for Alternative 1 would designate residential and
commercial areas to avoid direct and indirect disturbance to much of the woodland areas
that would be developed by the Project in the Upper Terrace, reducing indirect fire
clearance impacts to coast live oak and California bay woodlands in particular. Similar to
the Project, trimming or work within the rootzone of mature trees for construction or
wildfire buffering could indirectly impact these trees. As under the Project, MM BIO-15
would ensure avoidance of trees, and MM BIO-Alt. 1 would protect additional coast live
oak/California bay woodlands from development or associated fire management processes.
As under the Project, impacts would be less than significant with mitigation.
Alternative 1 would reduce impacts to mature trees,
including coast live oak/ California bay woodland,
and eucalyptus.
01779
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-67
Final EIR
Impacts to biological resources under this alternative would be substantially less than those
resulting from the Project. However, as under the Project, following incorporation of all
mitigation measures described above, Alternative 1’s contribution to regional cumulative
impacts to biological resources would be cumulatively considerable and significant and
unavoidable. Additionally, as discussed in the 2014 LUCE Update EIR, implementation of
General Plan LUE policies and compliance with state and federal regulations would ensure
cumulative impacts resulting from development under the General Plan LUE would be less
than significant.
Cultural and Tribal Cultural Resources
Under Alternative 1, impacts to cultural resources and tribal cultural resources would be
less when compared to the Project. Soil disturbance would still occur within areas
considered to be sensitive for cultural resources but required grading and excavation would
avoid the Upper Terrace, which has a high potential for discovery of buried archeological
resources. Similar to the Project, proposed relocation of historic structures within the
Froom Ranch Dairy complex would adversely affect significant historic resources,
including a potential historic district. Mitigation measures would continue to be
implemented to minimize potential impacts of development and operation on
archaeological and prehistoric resources, as well as historic resources.
Impact CR-1 addressing potential to impact subsurface cultural resources would be less
severe when compared to the Project. Per the technical studies completed for the FRSP
(Appendix F) and the City’s Archeological Resource Preservation Program Guidelines,
there are two known prehistoric sites and archaeologically sensitive areas within the Project
site that may contain undiscovered cultural resources that would be impacted by
construction under this alternative, including within the Upper Terrace and a 200-foot area
around the top of banks of the existing Froom Creek. Similar to the Project, mitigation
measures would be implemented that would reduce potential impacts. These would include
requiring a subsurface archaeological resource evaluation in areas of disturbance within
200 feet of identified sites (MM CR-1), identification of Environmentally Sensitive Areas
(MM CR-2), requiring preparation and implementation of an Archaeological Monitoring
Plan (MM CR-3 and MM CR-4), ensuring cessation of construction activities following
discovery of prehistoric or historic-period archaeological resources and/or human remains
(MM CR-5 and MM CR-7), and ensuring construction personnel receive cultural resources
training (MM CR-6). Unlike the Project, no development would occur within the Upper
Terrace, an area which supports several recorded archaeological sites and resources.
01780
5.0 ALTERNATIVES
5-68 Froom Ranch Specific Plan
Final EIR
Therefore, Impact CR-1 would be less than under the Project and considered less than
significant with mitigation.
Impact CR-2, which addresses potential indirect impacts to archaeological resources
resulting from recreational activities of future residents, would be substantially less than
under the Project. By avoiding development in the Upper Terrace, proposed residential
development would be located more than 100 feet from known archaeological resources
and, therefore, less subject to potential indirect disturbance by future residents. Similar to
the Project, the nearest residential structures in Villaggio would be enclosed by a security
fence under Alternative 1 that would substantially limit incidental access to these cultural
resources with the open space area. The archaeologically sensitive areas in the Upper
Terrace would be preserved as protected open space under Alternative 1, further protecting
them from risks associated with future development within the Specific Plan area. MM
CR-8 requiring that recreational facilities and roadways are not located within 50 feet of
known resources would also continue to apply. Impact CR-2 would, therefore, be less than
under the Project and would be considered less than significant with mitigation.
Impact CR-3, addressing impacts to historic resources onsite, would remain similar to the
Project, as Alternative 1 would relocate and/or adaptively reuse four Froom Ranch Dairy
complex buildings (i.e., main residence, creamery, dairy barn, and granary) within the
proposed trailhead park. These structures are eligible for listing on the National Register,
California Register, and City Master List of Historic Resources as a historic district.
Additionally, several structures onsite that contribute to the potential Froom Ranch Dairy
historic district (i.e., the shed, bunkhouse, and old barn) would be demolished similar to
the Project.
As under the Project, the following mitigation measures would apply to minimize potential
impacts to historic resources:
MM CR-9: ensures retention of a qualified historic architect to review and comment
on construction drawings as well as conduct construction monitoring
MM CR-10: ensures photo documentation of existing historic buildings
MM CR-11: requires production of an educational pamphlet regarding cultural and
architectural heritage of the site
MM CR-12: requires the Applicant to maximize reuse of original building material
MM CR-13: requires preparation of design guidelines and review for construction
proximate to the Main Residence
01781
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-69
Final EIR
MM CR-14: requires a preservation plan to protect historic buildings during
construction
Relocation and reconstruction of the Froom Ranch Dairy complex, including
implementation of the above mitigation measures, would retain sufficient integrity to
convey the buildings’ significant association with the dairy industry and the Froom family.
Retaining the four historic structures that contribute to the potential historic district within
the trailhead park and in a natural setting more reminiscent of their historic past than the
Project (i.e., set atop a rise against the natural hillside of the Irish Hills rather than set
amongst multi-family housing units and commercial buildings) would lessen the potential
impact to historic resources as well. However, as under the Project, the loss of three
contributors to the potential historic district would also occur under Alternative 1, and,
therefore, Impact CR-3 would remain significant and unavoidable.
Similar to the Project, Alternative 1 would contribute to the potential loss of significant
archaeological and tribal cultural resources, though its contribution would be less than
significant with mitigation identified above. As under the Project, significant and
unavoidable impacts associated with the removal, relocation, and reconstruction of features
associated with the historic Froom Ranch Dairy complex could occur and would be
cumulatively considerable when combined with overall loss of historic resources in the
City and surrounding areas for pending and future projects. As such, Alternative 1 would
contribute to the cumulative loss of historic resources in the City and result in significant
and unavoidable cumulative impacts.
Geology and Soils
Under this alternative, impacts related to geologic and soil resources would be similar when
compared to the Project due to similar construction activities, geologic hazards, and
minimal impacts. As under the Project, design and construction of proposed land uses
would be subject to several requirements and regulations to ensure structural integrity in
seismically active areas. By locating development outside of fault setbacks and
implementing the most current industry standards for structural design, impacts of
structural failure and risks to life and property due to seismic shaking and seismic-related
ground failure would be avoided or reduced.
Impact GEO-1, addressing exposure of people or structures to adverse effects from
earthquakes and seismically induced hazards, would be similar when compared to the
Project. Development would be required to be sited to avoid existing fault lines, and to
01782
5.0 ALTERNATIVES
5-70 Froom Ranch Specific Plan
Final EIR
adhere to the California Building Code (CBC) and the City Municipal Code. Similar to the
Project, the Los Osos Fault would cross Madonna Froom Ranch and Alternative 1 would
include a development setback from the potentially active Los Osos Fault segments onsite.
As under the Project, compliance with state and local building regulations for site
preparation and structural design would ensure that seismically induced hazards would
remain less than significant.
Impact GEO-2, addressing potential for soil hazards, would remain the same as the Project.
Potential for subsidence to occur onsite is low and development would not cause or
exacerbate subsidence. Grading under Alternative 1 would require approximately 94,000
cubic yards (cy) less fill as compared to the Project. Implementation of recommendations
outlined in the Project Soils Engineering Report and the geotechnical recommendations
included therein would continue be implemented under Alternative 1 and would reduce
impacts related to construction on loose, saturated, or expansive soils. Additionally,
compliance with federal, state, and local regulations (i.e., CBC, the City’s Safety Element
[SE], and the City Municipal Code) would reduce direct impacts associated with expansive
soils, differential settlement, and subsidence. As under the Project, impacts from
Alternative 1 would be less than significant.
Impact GEO-3, which addresses the potential for erosion and landslides, would be less
severe when compared to the Project since grading within areas above the 150-foot
elevation would not occur. In the lower portions of the site and Madonna Froom Ranch,
grading for site development has the potential to expose undocumented fill and existing
soft alluvium, which may erode or slide. While there is the potential for limited slope
instability to occur during excavation and construction activities, implementation of the
CBC and compliance with federal, state, and local regulations would reduce the potential
for erosion and long-term impacts during construction, similar to the Project. While
potential for landslides to occur at the Project site is considered low, potential impacts
would be reduced by removing private access roadways and medium-high density
residential uses that are proposed under the Project in the Upper Terrace that would be
located within a potential rockfall hazard area. Removal of development from the Upper
Terrance under this alternative would also reduce hazards associated with development on
steeper slopes. Compliance with applicable regulations and recommendations outlined in
the Preliminary Soils Engineering Report and Preliminary Engineering Geology
Investigation would further reduce impacts related to erosion or landslides, and impacts
would be less than significant.
01783
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-71
Final EIR
Impact GEO-4, addressing potential groundwater dewatering impacts, would result in
impacts similar to those under the Project. Subsurface parking structures constructed in
Villaggio adjacent to the realigned Froom Creek could require dewatering. Construction of
these structures could require excavation up to 12 feet below ground surface (bgs),
potentially intercepting shallow groundwater observed at a depth of 1.5 to 4.0 feet bgs. As
under the Project, compliance with the Preliminary Engineering Geology Investigation
recommendations, as well as Occupational Safety and Health Administration regulations,
would reduce impacts to less than significant.
Impact GEO-5, addressing the potential to uncover and impact paleontological resources
in geologic deposits, would be similar to the Project. If paleontological resources were
uncovered during construction and were then improperly handled, such unknown
paleontological resources could be damaged or destroyed. As under the Project,
incorporation of MM GEO-1 would ensure the protection of potential paleontological
resources, and impacts would be considered less than significant with mitigation.
Cumulative impacts related to geology and soils would result if impacts under Alternative
1, when combined with other past, present, and future projects, would cumulatively
increase the potential for geologic hazards, such as ground-shaking, or increased soil
impacts, such as erosion. The City Municipal Code and the General Plan SE require all
discretionary development within the City to undergo analysis of each site’s geological and
soil conditions prior to construction. Because all projects would be required to undergo an
analysis of site-specific geological and soil conditions, and because restrictions on
development would be applied in the event that geological or soil conditions pose a risk to
safety, this alternative’s contribution to cumulative impacts associated with seismic
activity, soil instability, subsidence, collapse, and/or expansive soil would be the same as
under the Project and would be considered less than significant.
Hazards, Hazardous Materials, and Wildfire
Under Alternative 1, impacts related to wildfire hazards would be substantially reduced
due to reconfiguration of proposed habitable structures to more defensible locations within
the site and provision of additional emergency access options for emergency responders.
Impacts related to hazardous materials and contamination from spills would be similar to
the Project due to extended construction activities. Airport safety hazards would also be
similar to the Project.
01784
5.0 ALTERNATIVES
5-72 Froom Ranch Specific Plan
Final EIR
Impact HAZ-1, addressing exposure of wildfire hazards and emergency response access,
would be substantially reduced. The Project site is located in an area with moderate to very
high fire hazards due to flammable vegetation onsite and within the adjacent Irish Hills
Natural Reserve, as well as due to winds that periodically blow southeast downslope
toward the Project site. As under the Project, adherence to applicable requirements to
minimize the risk from accidental construction- and operation-related wildfires, including
clearance or management of flammable vegetation within 100 feet of residential
development, including within the Irish Hills Natural Reserve, would mitigate this impact.
Unlike the Project, all residential development within the Upper Terrace and in the
northwestern portion of the site within Madonna Froom Ranch would be retained as open
space, reducing wildland-urban interface by approximately 4,750 feet (50 percent of
wildland-urban interface under the Project). This increased clustering within lower hazard
areas in the lower portion of the site and Madonna Froom Ranch would increase the buffer
between new development and very high fire hazard areas.
Impacts resulting from impaired emergency evacuation and exposure of residents and
visitors to wildfire hazards would be reduced. Unlike the Project, this alternative would
include emergency ingress to the Project site from a new emergency access road and bridge
across LOVR ditch to LOVR approximately 800 feet southeast of the main Project entrance
and a new emergency access road to Calle Joaquin located along the western edge of the
proposed stormwater detention basin (see Figure 5-1). Emergency access through the Irish
Hills Plaza would also be included. Therefore, a total of four access routes, including the
primary entrance, would provide for evacuation and less congested access to the site for
emergency respondents in the case of an emergency.
Under Alternative 1, security fencing, retaining walls, and closely spaced residential units
in Villaggio would continue to limit access for firefighters to attack fires threatening
residential units adjacent to the Irish Hills Natural Reserve. As under the Project,
implementation of several mitigation measures would avoid or reduce impacts. MM HAZ-
1, requiring construction measures to reduce the potential for brush or grass fires, MM
HAZ-2, requiring preparation of a Community Fire Protection Plan, and MM HAZ-3,
requiring designation of smoking areas away from onsite fire hazards would all reduce
these impacts. MM HAZ-4, requiring preparation and implementation of an Evacuation
Plan, and MM HAZ-5, requiring that design of the Lower Area provides direct access for
emergency response vehicles to the Irish Hills Natural Reserve bordering the Project site
to the west, would further reduce impacts. Despite these measures, Alternative 1 would
01785
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-73
Final EIR
continue to be located in an area highly susceptible to potential fire hazards, and Impact
HAZ-1 would remain significant and unavoidable.
Impact HAZ-2, addressing accidental releases of hazardous materials, would remain the
same as under the Project. The routine transport, use, or disposal of hazardous materials
would be unchanged. As under the Project, hazardous materials encountered during
demolition or construction activities would be disposed of in compliance with all pertinent
regulations for the handling of such waste, including requirements of the SLO County
APCD and California Code of Regulations. Additionally, this alternative would not
substantially increase the risk from hazardous materials to the public within the Project site
or within the surrounding area. Minimal safety risks from the storage, handling, and use of
hazardous materials in the Project site would be reduced through compliance with any
applicable standards and regulations. Compliance with the existing Surface Mining and
Reclamation Act (SMARA) permit for the red rock quarry, and by extension the State
Water Resources Control Board (SWRCB) regulations governing disposal of mine waste,
would ensure the existing red quarry is closed and maintained in a manner such that there
would be no significant increase in the concentration of waste constituents in the ground
or surface water prior to construction of the Project. Therefore, Impact HAZ-2 would
continue to be less than significant.
Impact HAZ-3 related to airport hazards would be similar to the Project. Although portions
of the Project site lie within Safety Sub-Areas S-1b and S-1c of the 2005 Airport Land Use
Plan, the Project site falls outside of the Aviation Safety Areas according to criteria in the
Caltrans Airport Land Use Planning Handbook (Johnson Aviation 2014). Accordingly, as
under the Project, no substantial physical airport-related safety hazard is expected to occur.
Therefore, aviation-related safety impacts to residents and commercial employees or
patrons would be less than significant.
Cumulative hazards from wildfire would be exacerbated by additional construction and
operation of urban uses within the City and region along the urban-wildland interface.
Projects along the City’s wildland-urban interface would introduce additional fire hazard-
related risks from typical residential operations and increased human activity (e.g.,
smoking, introduction of ignition sources, landscape equipment) and would place
additional people and structures at risk of injury or damage in the event of a wildfire.
Further, the heightened potential for future fire hazards from the influence of climate
change and warmer conditions, as discussed in Section 3.7.1.1, would contribute to the
potential for a higher frequency, intensity, and size of fires that may occur in such areas.
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5-74 Froom Ranch Specific Plan
Final EIR
As under the Project, adherence to mitigation measures MM HAZ-1 through -5, as well as
the California Fire Code, City Municipal Code, policies within the SE, and review of
discretionary projects by the SLOFD would reduce impact severity. While these measures
would reduce potential wildfire hazards, given the high potential for wildfire along the
City’s wildland-urban interface, the potential for cumulative development to exacerbate
wildfire hazards would be similar to the Project and impacts would be considered
significant and unavoidable.
Cumulative projects within the City and the Project vicinity would have the potential to
expose future area residents, employees, and visitors to chemical hazards through
development of sites and structures that may be contaminated from either historic or
ongoing uses. The severity of potential hazards for individual projects would depend upon
the location, type, and size of development and the specific hazards associated with
individual sites. Discretionary projects proposed in the City would be required to undergo
individual environmental review, including review of potential impacts related to hazards
and hazardous materials that are applicable to that particular development site and
proposed use. Additionally, projects would also be subject to the local, state, and federal
standards which require the safe removal of potentially hazardous building materials and
the cleanup of contaminated properties, thus reducing the level of risk on a particular site.
Because development standards or remediation requirements would be applied if hazards
or hazardous materials posed a risk to safety, contribution to cumulative impacts associated
with exposure to hazards or hazardous materials would be similar to those of the Project
and would be considered less than significant.
Hydrology and Water Quality
Impacts related to hydrology and water quality would be substantially similar to the Project
due to similar types of development and similar realignment of Froom Creek paired with
the proposed stormwater detention basin. Increases in impervious surfaces under this
alternative would decrease as compared to the Project due to the reduction in developed
area on the site (approximately 18 percent decrease), and continued compliance with
applicable local, regional, state, and federal requirements would further reduce the
potential for significant impacts.
Impact HYD-1 addressing construction impacts to water quality would be reduced as
compared to the Project. Unlike the Project, no construction would occur in the Upper
Terrace of Villaggio, substantially reducing the potential for spill of oil, gasoline, hydraulic
fluids, and other contaminants into Drainages 1, 2, or 3. In addition, soil erosion impacts
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5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-75
Final EIR
to the drainages within the Upper Terrace would be reduced compared to the Project.
Grading under Alternative 1 would require approximately 94,000 cy less fill as compared
to the Project. As under the Project, construction in the lower portion of the site and
Madonna Froom Ranch would present a potential for polluted construction related surface
runoff to flow into onsite wetlands and Froom Creek.
Discharge of pollutants from construction equipment, including accidental spillage of fuels
and lubricants, could also occur. Implementation of MM HYD-1, MM HYD-2, and MM
HYD-3, requiring stormwater permitting and management actions, would be implemented.
As under the Project, these mitigation measures would reduce the potential for erosion and
construction runoff to flow downstream to San Luis Obispo Creek or to the Calle Joaquin
wetlands, and potential impacts would remain less than significant with mitigation.
Impact HYD-2, addressing potential onsite flooding and erosion hazards, would be similar
when compared to the Project since the proposed stormwater system for Alternative 1
would involve the same components. Froom Creek realignment would be similar to the
design under the Project. Preliminary calculations prepared by the Applicant and peer-
reviewed by the City’s EIR consultant, indicate the stormwater management system would
be capable of accommodating a 100-year storm event. Development under Alternative 1
would be clustered, so the acreage of impervious surfaces would be less severe when
compared to the Project. Replacement of approximately 8.2 acres of residential
development with open space in the Upper Terrace would decrease potential stormwater
surface flows. Implementation of MM HYD-4 requiring creek bank and channel bottom
stability and avoidance or reduction of further erosion would continue to apply, and
impacts would be less than significant with mitigation.
Impact HYD-3, addressing water quality impacts to Froom Creek and San Luis Obispo
Creek due to polluted urban runoff and sedimentation, would be the same as under the
Project. While development of the site increases the possibility of runoff, similar to the
Project inclusion of a comprehensive stormwater management system with approximately
four stormwater retention and treatment areas onsite would reduce impacts. As under the
Project, this alternative would be subject to the Central Coast Regional Water Quality
Control Board’s (RWQCB’s) Post Construction Requirements and National Pollutant
Discharge Elimination System discharge permits. Implementation of proposed BMP
strategies of the FRSP would also reduce impacts from urban runoff. Further, upon
compliance with the City’s Storm Water Management Plan, Engineering Standards,
General Plan, and City Municipal Code requirements, adverse effects to water quality from
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5.0 ALTERNATIVES
5-76 Froom Ranch Specific Plan
Final EIR
operation of this alternative would be reduced. Impacts would be similar to the Project and
less than significant.
Impact HYD-4, involving impacts to groundwater, would be lessened compared to the
Project. Unlike the Project, the Upper Terrace would remain undeveloped, allowing
continued natural percolation and reduced opportunities for pollutants to be carried into
adjacent waterways as a result of stormwater flows. The City no longer relies on local
groundwater as of April 2015, and the San Luis Obispo Groundwater Basin is not in
overdraft and recharges quickly following normal rainfall years. Additionally, as under the
Project, implementation of BMPs would be required consistent with City and RWQCB
standards. Similar to the Project, groundwater resources would not be depleted or degraded,
and groundwater recharge would not be impeded. Groundwater impacts would be similar
to the Project and would be considered less than significant.
Cumulative impacts to water quality would be incrementally reduced compared to the
Project, including potential contribution to cumulative trends of increased urban pollutant
discharge to the San Luis Obispo Creek system. As under the Project, mitigation of these
impacts would be required through compliance with water quality requirements and State
Water Resources Control Board (SWRCB) regulations, and potentially significant
cumulative impacts would therefore be less than significant with mitigation.
Land Use and Planning
Under this alternative, the layout, acreage, and placement of residential and commercial
development, as well as parkland and roadways, within the Project site would substantially
differ from the Project. While the total number of residential units and square footage of
commercial land uses would remain the same as the Project, Alternative 1 would be
consistent with policies within the General Plan LUE that prohibit development above the
150-foot elevation line. This aspect of Alternative 1 would relocate residential
development in upper elevations of Villaggio and Madonna Froom Ranch to lower
elevations of the site and relocate the proposed trailhead park to the portion of Madonna
Froom Ranch above the 150-foot elevation. Residential and commercial development
would be tightly clustered within approximately 30 percent of the site (e.g., 36 acres), with
over 60 acres of contiguous open space provided on the Upper Terrace and upper reaches
of Madonna Froom Ranch within a public park. Overall, impacts identified within Section
3.8, Land Use and Planning, would be substantially less than under the Project.
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5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-77
Final EIR
Impact LU-1, regarding conflicts with City General Plan policies for visual, biological, and
cultural resources and wildfire hazards, would be substantially reduced compared to the
Project. Unlike the Project, urban development above the 150-foot elevation would not be
permitted, consistent with the City General Plan. This alternative would be substantially
more consistent with the General Plan LUE and COSE policies that protect sensitive
biological, cultural, open space, and visual resources. These policies include LUE Policies
1.8.6, Wildlife Habitats, and 6.4.7, Hillside Planning Areas, and COSE Policies 7.3.1,
Protect Listed Species, 7.3.2, Protect Species of Local Concern, and 9.2.1, Views to and
from public places, including scenic roadways. However, development of 12 Villas in the
southwest corner of Villaggio’s Lower Area would continue to substantially impact onsite
biological habitat connectivity between the Froom Creek corridor and grassland within the
Upper Terrace, and would be potentially inconsistent with COSE Policies, including 7.3.3,
Wildlife Habitat and Corridors, and 7.7.7, Preserve Ecotones.
Full compliance with the General Plan LUE and COSE would protect sensitive biological,
open space, and visual resources, and reduce potential fire hazards. Avoidance of
development within the Upper Terrace would protect biological resources, including
federal jurisdiction wetlands and 12 special status plant species. Required implementation
of MM BIO-4 would result in relocation of residential uses in the southwest portion of
Villaggio to maintain a buffer on the centerline of the confluence of Drainages 1, 2, and 3,
and would reduce potential inconsistencies with General Plan policies designed to protect
wildlife corridors and ecotones, as discussed above. Further, relocation of the proposed
trailhead park to the existing quarry location in the northwest portion of the Project site and
moving residential uses eastward would ensure consistency with General Plan LUE
policies to protect the Froom Creek watershed and trailhead. By relocating residential
structures in the northwestern portion of the Project site and Upper Terrace of Villaggio,
the visual transition between the Irish Hills Natural Reserve and the Project site would be
improved, substantially reducing visual impacts (refer to KVA-4 and -5, above). Removing
urban development above the 150-foot elevation line would also greatly increase open
space buffers between development in Madonna Froom Ranch and Villaggio, improving
safety from potential wildfire hazards onsite. Additionally, implementation of MM BIO-1
through -7 and -10 through -12 and MM HAZ-1 through -5 would further reduce potential
impacts to biological resources and wildfire hazards. In contrast with the Project,
Alternative 1 would avoid the significant land use and planning impacts related to General
Plan policy consistency by eliminating urban development above the 150-foot elevation
line onsite.
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5.0 ALTERNATIVES
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Final EIR
However, the Project site also supports the historic Froom Ranch Dairy complex, including
seven existing structures associated with the historic dairy and Froom family. These
structures could constitute a potential historic district under the City’s Historic Preservation
Ordinance and the CRHR. As under the Project, retention and relocation of four structures
(i.e., main residence, creamery, dairy barn, and granary) and demolition of three
contributors to the potential Froom Ranch Dairy historic district (i.e., the shed, bunkhouse,
and old barn) would impact historic resources. While implementation of MM CR-7 through
-14 would reduce potential impacts, the permanent loss of the historic integrity and
contributing structures of the potential historic district would result in significant and
unavoidable impacts and potentially conflict with City policies for historic resource
protection.
Impact LU-2, addressing potential inconsistencies with City setback requirements and the
existing onsite agricultural easement, would be less than under the Project. Realignment of
the open space and agricultural easement would support conservation of habitat and
biological resources, particularly the protection of existing wetlands within this 1.6-acre
portion east of Calle Joaquin, which is consistent with the easement’s preservation intent.
Further, because development would not be permitted within the Upper Terrace, Drainages
1, 2, and 3 would remain protected from the impacts of development. Therefore, impacts
under this alternative would be less than under the Project and would be remain less than
significant.
Significant cumulative land use and planning impacts could occur as the result of many
planned and/or proposed residential developments in undeveloped open or agricultural
lands along edges of the City. As under the Project, this alternative’s incremental
contributions to conversion of agricultural and rural land along the perimeter of the City to
developed urban uses would result in loss of open space and habitat, increases in
impervious surfaces, night lighting, noise, and traffic that accompany such development.
However, as with the Project, development under this alternative would be generally
consistent with adjacent development uses along LOVR and all pending/future projects
would be required to comply with development standards and General Plan policies of the
City, and potential impacts would be assessed and mitigated in accordance with CEQA and
applicable City policies prior to approval. Design and implementation of mitigation
measures under this alternative would ensure consistency with General Plan policies,
design standards and Zoning Ordinance regulations, and cumulative impacts related to land
use and planning would continue to be less than significant.
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5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-79
Final EIR
Noise
Construction and operational noise impacts would be similar to the Project as overall
residential and commercial development would be comparable in size and scale.
Development of residential and commercial land uses would result in construction noise
impacts. The location of those noise sources under Alternative 1 would be confined to the
lower portion of the site and Madonna Froom Ranch, as well as the proposed stormwater
management system. Operationally, this alternative would have a similar amount of traffic
generation as the Project, resulting in minimal increases in mobile noise from increased
vehicular traffic on area roads. As with the Project, noise sensitive residential uses would
be developed adjacent to existing commercial uses that could exceed acceptable noise
levels under City standards.
Impact NO-1, addressing construction noise, would be less severe when compared to the
Project. Similar to the Project, short-term increases in noise from the use of heavy-duty
construction equipment would exceed applicable standards in the City Noise Ordinance.
Also, similar to the Project, noise impacts from grading and construction would exceed
City and County standards for nearby sensitive receptors, including hotels along Calle
Joaquin and recreational users within the Irish Hills Natural Reserve, but would be limited
to a smaller footprint on the site away from natural areas in the Irish Hills and
Mountainbrook Church. Unlike the Project, development would not include the Upper
Terrace of the Villaggio, thereby reducing construction noise impacts to sensitive receptors
within occupied units within the Lower Area, as well as recreational users along trails
within the Irish Hills Natural Reserve. As under the Project, noise impacts to sensitive
receptors would be minimized to the maximum extent feasible through compliance with
the City’s Noise Ordinance and implementation of MM NO-1, limiting construction
activities during evenings, Sundays, or holidays, MM NO-2, requiring noise attenuation
measures, and MM NO-3 ensuring neighbors are informed regarding allowed construction
timelines and noise complaint procedures. Noise generated from construction of this
alternative would be less severe when compared to the Project, and implementation of
mitigation would ensure noise levels under this alternative would not exceed City noise
thresholds periodically over the construction period. Residual impacts would continue to
be considered less than significant with mitigation.
Impact NO-2, related to ground-borne vibration, would be similar to the Project, as short-
term construction activities could expose people to excessive ground-borne vibration.
Construction would follow a similar progression of development within the Project site
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5-80 Froom Ranch Specific Plan
Final EIR
and vibrations would be temporary and intermittent during the hours of construction.
Because residential units would not be developed within the Upper Terrace of Villaggio,
heavy construction equipment would not pass through occupied units in the lower area and
potential impacts from construction-related vibration on this population would be less than
under the Project. While Villaggio would be occupied during construction of Madonna
Froom Ranch, vibration would be attenuated with the intervening distance and would be at
an imperceptible level at the location of proximate sensitive receptors. Therefore, vibration
impacts from construction under this alternative would be less severe when compared to
the Project and would be less than significant.
Impact NO-3, considering exposure of future residents to noise from nearby roadways,
would be similar to the Project, as residential units in Madonna Froom Ranch and the lower
portions of the site would remain located in an area that exceeds City noise limits for
roadway noise. Maximum allowable noise exposure resulting from transportation sources
for residences, hotels, and office buildings within the City is 60 decibel average (dBA)
outdoor and 45 dBA within interior spaces (see Table 3.10-5 within Section 3.10, Noise).
As under the Project, areas could be exposed to outdoor noise levels above 60 dBA.
However, the Acoustics Assessment prepared for the Project site modeled the 60 dBA
noise contour to be outside of these residential areas and estimates that noise levels for
residential land uses would be approximately 45 to 57 dBA (Appendix I). Traffic generated
under this alternative would increase ADT on LOVR by roughly the same amount as the
Project, although these increases would be negligible compared to existing levels and
would not result in a perceptible increase in noise levels. As under the Project, compliance
with the California Building Standards Code requirements would reduce noise levels for
outdoor activity areas and exterior living spaces do not exceed acceptable levels. Similar
to the Project, this impact would be less than significant.
Impact NO-4, addressing noise impacts from commercial uses to the north, would be
similar to the Project. The 2020 Acoustic Assessment prepared for the Project concluded
that existing Community Noise Equivalent Level of approximately 70 dBA may occur at
the northern boundary of the Project site during a 24-hour scenario with a maximum
amount of activity and noise from adjacent businesses such as Costco, Home Depot, TJ
Maxx, and Whole Foods. These levels would decrease to 60 dBA approximately 150 feet
into the Project site from its northern border with Irish Hills Plaza (Appendix I).
Approximately the same number of residential units would be developed adjacent to these
commercial uses as the Project, resulting in potential impacts from commercial deliveries
and other associated activities that would exceed allowed noise levels for residential areas.
01793
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-81
Final EIR
Similar to the Project, required implementation of MM NO-4 would reduce anticipated
noise levels through the use of noise reduction measures such as a planted earthen berm or
sound wall along the site boundary. As under the Project, residual impacts would be
considered less than significant with mitigation.
As under the Project, this alternative would contribute a marginal increase in stationary
and mobile noise sources, and the cumulative impact of noise levels resulting from
construction and operation of this alternative would remain less than significant with
mitigation.
Population and Housing
Population and housing impacts would be the same as under the Project, as Alternative 1
would facilitate similar levels of new residential development (578 units), and associated
population increase (1,231 persons) as the Project. In addition, the composition of
inclusionary affordable housing units offered by this alternative would be similar to the
Project as required for consistency with City Inclusionary Housing Requirements and
Specific Plan Area Expansion Area Inclusionary Housing Requirements.
Impact PH-1, addressing population growth, would be the same as under the Project. The
increase in population would be well below projected population under the LUE by 2035.
As under the Project, this alternative would not exceed the adopted annual City growth rate
of one percent under General Plan Policy LU 1.11.2. and would be compliant with the
intent of the City’s growth management strategies relating to the annual average and overall
increases in housing units and population. Impacts would therefore remain less than
significant.
Impact PH-2, which addresses the City’s jobs-housing balance, would be similar to the
Project and would have beneficial impacts related to the City’s jobs-to-housing balance
and assist in achieving the target jobs-to-housing ratios of 1.5 to 1. The proposed
construction of 174 new housing units would provide additional housing for the existing
and growing labor force within a community that currently has a 1.6 to 1 jobs-to-housing
ratio. Therefore, this impact would be less than significant.
Impact PH-3, which addresses construction of affordable housing within the City, would
be similar to the Project. This alternative would adhere to the same requirements of the
Specific Plan area and HE Policies as the Project, including the requirement to build a
minimum of five percent low- and ten percent moderate-income affordable dwelling units.
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5.0 ALTERNATIVES
5-82 Froom Ranch Specific Plan
Final EIR
Because the same number of units, including low- and moderate-income affordable units,
would be constructed as under the Project, impacts would remain less than significant.
Cumulative impacts would be similar to the Project. Cumulative development and
associated growth in population and housing is anticipated in the General Plan LUE and
would be consistent with City General Plan policies. This alternative, in combination with
pending/future developments, would align with the City’s plans for buildout as projected
by the General Plan. This alternative would be consistent with the residential unit growth
requirements specified by General Plan LUE Policy 1.11.2 and Table 3.11-17 within
Section 3.11, Population and Housing, though there may be pressure to exceed the annual
one percent rate allowed under General Plan LUE Policy 1.11.2. However, the contribution
under this alternative would remain consistent with LUE and HE policies and would not
result in significant cumulative contribution. Further, existing LUE policies requiring that
the City manage its housing supply so that it does not exceed a growth rate of one percent
per year, on average, would help to ensure population growth does not exceed planned
growth or result in significant cumulative impacts associated with increases in population
and housing within the City. Therefore, cumulative impacts would remain less than
significant.
Public Services and Recreation
Under Alternative 1, the quantity of residential units introduced to the Project site would
be the same as the Project, potentially resulting in an estimated 1,231 new residents. The
new residents would increase demand for police protection, fire protection, parks, and
schools, with impacts similar to the Project. The amount of parkland supplied under
Alternative 1 would be incrementally greater than the Project (an additional 0.4 acre),
which would directly benefit new residents and generally comply with the City’s parkland
requirements, although mitigation for provision of additional parkland would be required
to fully comply with applicable requirements.
Impact PS-1, relating to police services, would be similar to the Project, as development
would not require or result in the provision of new or physically altered facilities.
Development under Alternative 1 would result in the same number of residential units and
square footage of commercial area as under the Project, and therefore place a similar
demand on police services. As under the Project, the anticipated population increase may
require the hiring of an additional police officer to maintain the current ratio of 1.17 police
officers per 1,000 residents. However, this increase would be funded through property,
01795
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-83
Final EIR
sales, and transient occupancy taxes throughout the City, including those resulting from
Alternative 1, and would not necessitate police station expansion or construction beyond
that already approved by the City. As under the Project, this alternative would be required
to implement measures to decrease demand for police protection, including consistency
with SLOPD’s Crime Prevention Through Environmental Design Principles. Accordingly,
impacts to police protection services would remain less than significant.
Impact PS-2, relating to fire protection services, would be similar to the Project. Population
increases would be the same as under the Project, including estimated increases in seniors.
Development would continue to be subject to SLOFD standards and the California Fire
Code and would be located within the four-minute safe response (travel) time required by
the SE of the City General Plan. While the number of firefighters required under
Alternative 1 would increase, Alternative 1 would not require construction of new
firefighting facilities that would adversely impact the physical environment and Impact PS-
2 would continue to be less than significant.
Impact PS-3, relating to public schools, would be similar to the Project, as 404 of the 578
proposed residential units would be for seniors who are not expected to generate school-
aged populations. As under the Project, the remaining 174 multi-family units would be
anticipated to generate approximately 37 school-age children. Schools that are closest to
the Project site have the capacity to accommodate the estimated increase in the student
population. As under the Project, required payment of development fees would offset
potential impacts of increased enrollment on school facilities. Given school district-wide
capacity and the payment of impact fees for school facilities, anticipated impacts to school
facilities would be similar to the Project and would be less than significant.
Impact PS-4, relating to parkland availability, would be slightly less significant than the
Project. Approximately 12.31 acres of parkland would be required to meet the City’s
standard of 10 acres of parkland per 1,000 residents, as described in Parks and Recreation
Element (PRE) Policy 3.13.1. Alternative 1 would include 3.3 acres of public parkland
within the Project site, which is 0.4 acre greater than under the proposed Project and 9.01
acres less than required under the City General Plan. As under the Project, implementation
of MM PS-1 and MM PS-2, would require additional parkland dedication or payment of
in-lieu fees to satisfy City requirements for 10 acres of parkland per 1,000 residents,
including five acres of neighborhood parks. As under the Project, implementation of these
measures would result in impacts to park and recreation resources that would be considered
less than significant with mitigation.
01796
5.0 ALTERNATIVES
5-84 Froom Ranch Specific Plan
Final EIR
Alternative 1, in conjunction with approved, pending, or proposed development projects in
the City, proposed land use changes under the General Plan LUE, along with associated
population growth, would incrementally increase overall demand for public services,
including fire protection, police protection, schools, and parks. However, as under the
Project, projects would be required to address potential contribution to cumulative impacts
through fair share payments, as well as other standard mitigation measures. Similar to the
Project, Alternative 1 would not result in cumulatively considerable deterioration of
existing public facilities or service levels and cumulative impacts would be less than
significant with mitigation.
Transportation and Traffic
Impacts related to transportation and traffic would not substantially vary in comparison to
the Project due to identical levels of residential and commercial development and is
anticipated to also generate 2,700 daily vehicle trips. Additionally, emergency access
points will be altered as compared to the Project, lessening potential evacuation impacts.
Alternative 1 would include similar road and transportation improvements to the Project:
1) A signalized intersection with LOVR that would provide four-way pedestrian
crosswalks and access to a new two-lane road (Collector “A”) that would serve as
the primary access to the Specific Plan area;
2) Widening of LOVR along a portion of the Project site’s frontage;
3) Proposed internal roadway network consisting of public and private roads;
4) Proposed bicycle and pedestrian facilities throughout the Specific Plan area;
5) Parking facilities to accommodate residents, employees, and visitors within the
Specific Plan area; and
6) A new bus stop that would be integrated into the regional public transportation
system.
Emergency access roads from Mountainbrook Church would not be included in this
Alternative. Emergency access roads would instead be provided via three different
connections: 1) from the Irish Hills Plaza into Madonna Froom Ranch; 2) from LOVR to
Villaggio; and 3) from Calle Joaquin to Villaggio through the proposed stormwater
detention basin area. Following incorporation of these roadway and transportation
improvements and mitigation measures discussed below, residual impacts for Alternative
1 would be similar to those identified in the City-prepared Traffic Impact Study (TIS)
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5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-85
Final EIR
findings for Existing plus Project Conditions (see Tables 3.13-13 through 3.13-16 within
Section 3.13, Transportation and Traffic; see also Appendix J).
Impact TRANS-1, associated with construction traffic impacts, would be less severe when
compared to those associated with the Project because removal of development in the
Upper Terrace would eliminate the need for construction vehicles to travel along Calle
Joaquin and within proposed local roads within the Project site. Construction timing under
Alternative 1 would change to avoid overlap between occupancy of Villaggio and
construction activities in the Upper Terrace, as proposed by the Project. Alternative 1
would result in construction traffic being separated from occupied portions of the site in
Villaggio and Madonna Froom Ranch and would shorten the time in which construction
vehicles would interfere with regular roadway traffic. As under the Project, this Alternative
would implement MM TRANS-1 requiring preparation of a Construction Transportation
Management Plan for all phases of development, to be reviewed and approved by the City.
Given substantial reductions in development footprint and implementation of required
mitigation measures, this impact would be incrementally less severe when compared to the
Project and would be less than significant with mitigation.
Impact TRANS-2, regarding exacerbation of queuing and peak hour traffic for automobiles
and poor levels of service for pedestrians and bicycle modes of transportation under
Existing plus Alternative 1 conditions, would be similar to the Project. The anticipated
residential population of Alternative 1 is the same as the Project and roadway intersections
impacted by the Project would continue to be impacted by Alternative 1. Although internal
roadways would be lessened as a result of removal of residential uses in the Upper Terrace,
internal traffic would continue to be potentially significant at occupation of Madonna
Froom Ranch, although MM TRANS-11 requiring use of traffic calming measures on
Local Street “A” would reduce this impact to less than significant. Although required
implementation of MM TRANS-2 through -6a-5 and MM TRANS-7 through -11 would
reduce other impacts under Existing plus Alternative 1 conditions to less than significant,
MM TRANS-6b requiring payment of fair share costs for the completion of the Prado Road
Overpass/Interchange project would not mitigate potential impacts until this infrastructure
project is complete. Therefore, similar to the Project, if the Prado Road
Overpass/Interchange project is not in place by occupancy of Alternative 1, this impact
would remain significant and unavoidable.
Impact TRANS-3, which addresses exacerbation of existing queuing and peak hour traffic
for automobiles and poor levels of service for pedestrians and bicyclists under Near-Term
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5.0 ALTERNATIVES
5-86 Froom Ranch Specific Plan
Final EIR
plus Alternative 1 conditions, would be similar to the Project. As discussed above,
Alternative 1 would generate similar population increases and associated traffic as the
Project. Although required implementation of MM TRANS-2, -5, -6a, -7, -8, -9, and -12 ,
-13, and -15 through -18 would reduce impacts under Near-Term plus Alternative 1,
completion of MM TRANS-6b and MM TRANS-14 requires payment of fair-share fees
toward the completion of the Prado Road Overpass/Interchange project, which cannot be
ensured by this alternative. Therefore, if the Prado Road Overpass/Interchange project is
not in place by occupancy of Alternative 1, this impact would remain significant and
unavoidable.
Impact TRANS-4, addressing inadequate emergency access and evacuations in areas of
high and very high fire hazard, would be less severe when compared to the Project, as
additional emergency evacuation options would be provided under Alternative 1 and
development would be reduced to lower risk areas of the site. Similar to the Project, this
alternative would continue to provide an emergency access route between Madonna Froom
Ranch and Irish Hills Plaza. Unlike the Project, Alternative 1 would not provide an
emergency access route through the Mountainbrook Church private road and would instead
provide one emergency access route along the proposed stormwater basin and another
across the realigned Froom Creek channel to connect to LOVR, thereby improving options
for emergency access and evacuation. The access route adjacent to the stormwater basin
would allow evacuees located within the southwestern portion of Villaggio to evacuate
without further exacerbating potential congestion along LOVR, as well as provide
additional ingress and egress points for emergency responders. Additionally, Alternative 1
would require MM TRANS-2019, inclusion of an emergency access point from the Lower
Area to the existing dirt access road that connects to the utility power line structures at the
top of the ridgelines, and MM TRANS-2122, requiring provision of emergency respondent
access to Project site perimeters, which would increase emergency access to the site and
reduce potential impacts to less than significant with mitigation.
Impact TRANS-5, regarding pedestrian and bicycle circulation safety issues, would be
similar to the Project, as anticipated generation of internal roadway trips would be the
same. MM TRANS-2224 would continue to be required, ensuring Alternative 1 would
include Project concept designs and design guidance published by the National Association
of City Transportation Officials and the Federal Highway Administration, including
installation of American Disabilities Act-compliant sidewalks, Lead Pedestrian Intervals
and pedestrian refuges at the LOVR/Auto Park Way intersection, and Class IV bikeways
along LOVR approaching/departing this intersection. Implementation of this mitigation
01799
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-87
Final EIR
measure would ensure residual impacts to onsite circulation for pedestrians, and bicyclists
would be less than significant with mitigation.
Impact TRANS-6 regarding Cumulative plus Project conditions, would be similar when
compared to the Project. As under the Project, potentially significant impacts could occur
to 14 separate intersections and roadway segments due to increased automobile, pedestrian,
and bicycle traffic under Cumulative plus Project conditions (see Table 3.13-16 in Section
3.13, Transportation and Traffic). However, required implementation of MM TRANS-
2325 through -2530, as well as MM TRANS-2, -8, -9, -12, -13, -14, -16 and -18-13, would
reduce cumulative impacts to less than significant with mitigation.
Utilities and Energy Conservation
Under Alternative 1, similar activities involving installation of public utilities and
associated trenching would occur within a smaller area of development to support
residential and commercial development within the lower portions of the site. New
residential development (578 units) and associated population increase (1,231 persons)
would be similar to the Project. However, 130 units of medium-high density R-3 units
would be replaced with 130 high density R-4 units. This alternate range of unit types would
not change the demand for utilities and service systems except for solid waste. Based on
the below analysis, transitioning to multi-family units with incrementally higher density
units would generally result in a decrease of solid waste production compared to the
Project.
Impact UT-1, regarding potential environmental impacts resulting from expansion of
utility infrastructure, would be incrementally less adverse when compared to the Project.
Impacts would be less adverse when compared to the Project due to reductions in building
footprints and elimination of development in areas above the 150-foot elevation.
Anticipated levels of service to be provided would be similar as under the Project, as would
associated infrastructure requirements. Implementation of Alternative 1 would include
MM UT-1, ensuring Project utilities are engineered consistent with City standards. Similar
to the Project, residual impacts would continue to be less than significant with mitigation.
Impact UT-2, regarding demand increases to the City’s potable water supply, would remain
the same as under the Project. Residential and commercial development under Alternative
1 would be similar to the Project, and all landscaping would continue to be irrigated using
recycled water and augmented with a groundwater well. Although the number of residential
units in areas designated as R-3 and R-4 would change incrementally compared to the
01800
5.0 ALTERNATIVES
5-88 Froom Ranch Specific Plan
Final EIR
Project, units within these land use designations are similar and are anticipated to require
the same level of potable and recycled water. As under the Project, demand projections
indicate sufficient available supply of City potable and recycled water and impacts would
continue to be less than significant.
Impact UT-3, regarding demand for wastewater collection facilities, would be the same as
under the Project. Alternative 1 would result in construction of the same number of
residential units and the same amount of commercial development and therefore would not
result in greater demand for the City’s available wastewater services as compared to the
Project. As under the Project, the Applicant would comply with City standards, including
fused sewer lines and would not significantly contribute to existing exceedance in wet-
weather capacity of City facilities to process and treat wastewater; however, the City notes
that the Laguna lift station currently experiences capacity issues (Personal communication
with Jennifer Metz, City of San Luis Obispo Utilities Department, May 2019).
Implementation of Alternative 1 would therefore contribute to, or exacerbate existing
issues associated with capacity of the City’s wastewater collection and conveyance system.
Similar to the Project, implementation of MM UT-2 and payment of development impact
fees would also be required to offset any impacts to the City’s wastewater management
capacity. Impacts related to wastewater services would therefore continue to be less than
significant with mitigation.
Impact UT-4, regarding generation of solid waste, would be less severe when compared to
the Project. Alternative 1 would include development of 7.4 acres within the Madonna
Froom Ranch with high density residential uses, as opposed to 6.3 acres of medium density
residential and 1.8 acres of high density residential as proposed under the Project (see Table
5-1). Denser residential land uses typically generate lower levels of solid waste per unit;
therefore, the Madonna Froom Ranch development under Alternative 1 would generate
approximately 923.9 lbs/day from residential uses as compared to 1,351.6 lbs/day under
the Project (see Table 5-13). This difference in solid waste generation equates to a decrease
in 427.7 lbs/day or 76 tons/year, or an approximate 31.6 percent reduction. Based on the
daily solid waste projections and similar to the Project, Alternative 1 would contribute
approximately 0.3 percent of the potential daily waste capacity of Cold Canyon Landfill.
The waste produced would not substantially affect the landfill’s capacity or ability to
comply with federal, state, or local regulations. Therefore, impacts regarding the generation
of solid waste would remain less than significant.
01801
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-89
Final EIR
Table 5-13. Estimated Solid Waste Production Under Alternative 1
Waste Generation
Source Proposed Uses Quantity (#
of Units)
Waste
Generation
Factor
Waste
Generation
(lbs/day)
VILLAGGIO
Multi-family Independent Living
Units 366 units 8.6 lbs/day/unit 3,147.6
Nursing/Retirement
Home Assisted Living Units 38 units 5 lbs/person/day1 190
Hospital Health Care Units 51 beds 16 lbs/bed/day1 816
Office
Administration
Building and
Ancillary Uses
85,078 sf 0.006 lbs/sf/day 510.5
Commercial Sector
(Commercial Retail) Ancillary Uses 84,078 sf 0.046 lbs/sf/day 3,867.6
MADONNA FROOM RANCH
Multi-family High Density
Residential 174 units 5.31 lbs/day/unit4 923.9
Service Sector (Other
Services) Hotel with Restaurant 70,000 sf 3.12 lbs/100
sf/day 2,184
Commercial Sector
(Commercial Retail) Other Commercial 30,000 sf 0.046 lbs/sf/day 1,380
Estimated Total Waste Generation (lbs per day) 13,019.6
Estimated Total Waste Generation (lbs per year) 4,755,423.5
Estimated Total Waste Generation (tons per day) 6.5
Estimated Total Waste Generation (tons per year) 2377.7
Impact UT-5, regarding available energy resources and consumption rates, would remain
the same as under the Project. Estimated fuel consumption for construction would be
similar to estimated fuel consumption for construction under the Project. Consumption of
electricity, natural gas, and gasoline during operation under Alternative 1 would also be
the same as under the Project. As under the Project, compliance with federal, state, and
local regulations pertaining to renewable energy, improved energy efficiency, and
conservation in both construction and operation would be required. Further, though not
required to reduce impacts of this alternative, a number of mitigation measures identified
to reduce Project impacts to various resources would have the secondary effect of reducing
Project energy demands. The demand for energy under Alternative 1 is generally lower
than County and state averages, and potential direct impacts to energy resources and
conservation are considered less than significant.
Implementation of Alternative 1 and other proposed or current projects listed in Table 3.0-
1 within Section 3.0.3, Cumulative Impact Analysis, would increase the cumulative demand
on utilities; however, these projects would be required to comply with standards for
01802
5.0 ALTERNATIVES
5-90 Froom Ranch Specific Plan
Final EIR
adequate utilities set forth in the City General Plan, would be subject to City planning and
review requirements, and would be required to pay development impact fees to offset any
impacts from utility infrastructure needs and service capacities. As such, and as indicated
by the LUCE Update EIR, no significant or adverse cumulative effects are anticipated
related to the supply of water, waste water, solid waste, or energy utilities. Therefore,
cumulative impacts to utilities would be less than significant with mitigation.
Mineral Resources
Impacts related to mineral resources would not vary from the Project. As under the Project,
closure of the quarry under this alternative would nominally lower available acreage for
red rock extraction, and Impact MN-1 would remain less than significant. Additionally,
cumulative impacts to mineral resources or mineral resource recovery sites would continue
to be considered less than significant as the City does not allow mineral resource extraction
and there are no other proximate active mines identified for future annexation into the City.
Therefore, there are no projects within the City that are expected to further reduce currently
available supplies.
5.4.2.3 Alternative 2 – Residential Development Project Alternative
Similar to Alternative 1, Alternative 2 would include a major reconfiguration of the
proposed land use plan and redesign of key Project elements, including substantially
increased clustering of development within Madonna Froom Ranch and the Lower Area of
Villaggio to reduce environmental impacts identified in the EIR. Alternative 2 would
continue to provide a Life Plan Community and new multi-family neighborhood; however,
unlike the Project and Alternative 1, Alternative 2 would eliminate commercial uses on
site. Instead, Alternative 2 would support 178 multi-family residential units (four more
than proposed under the Project or Alternative 1), 404 senior independent living units, 51
beds in residential health care facilities, and 3.3 acres of public parkland. Four primary
features of this alternative are intended to substantially reduce identified Project impacts:
1) No commercial development (e.g., hotel, retail) would be included in the Madonna-
Froom Ranch portion of this alternative; commercial uses proposed under the
Project in Madonna Froom Ranch would be replaced with R-4-SP High Density
Residential Uses. Resident-serving commercial uses would continue to be
developed within Villaggio to serve Villaggio residents and would be similar to
those proposed under the Project (e.g., restaurants, theater);
01803
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-91
Final EIR
2) Consistent with the General Plan LUE, all development would be confined to areas
below the 150-foot elevation, removing all development from the Upper Terrace
and restricting new development to roughly 30 percent of the site within Villaggio’s
Lower Area and Madonna Froom Ranch;
3) Development of buildings within the Lower Area would be reconfigured, and some
building heights and sizes increased to accommodate the same capacity for
development as the Project of 404 units, 51 beds in health care units, and more than
160,000 sf of administrative and support facilities;
4) As with Alternative 1, emergency access would be provided via three different
connections: 1) from Irish Hills Plaza into Madonna Froom Ranch; 2) from LOVR
to Villaggio; and 3) from Calle Joaquin to Villaggio through the proposed
stormwater detention basin area on the Mountain Brook Church easement.
Required discretionary actions would be similar to the proposed Project, while the
construction phasing plan would be similar to Alternative 1 (see also Table 5-6).
As under the Project, this alternative would realign Froom Creek to improve site drainage
and make space for residential development, along with additional drainage improvements
as proposed under the Project (refer to Chapter 2, Project Description).
01804
CROSS SECTIONCROSS SECTION
LOCATIONLOCATION
(FIGURE 5-3)(FIGURE 5-3)
Drainage 4Drainage 4
150-FOOT E L EVATION CONTO
UR LIN
EProposed Froom Creek RealignmentF ro o m C r e e k *Prefumo CreekSan Luis Obispo Creek101
CALLE JOAQUINLOS OSOS VALLEY ROADLOS OSOS VALLEY ROADCALLE JOAQUINAUTO PARK WAYAUTO PARK WAYIRISH HILLSIRISH HILLS
NATURALNATURAL
RESERVERESERVE
VISITOR SERVING COMMERCIALVISITOR SERVING COMMERCIAL
(HOTELS)(HOTELS)
COSTCOCOSTCO
MOUNTAINBROOKMOUNTAINBROOK
CHURCHCHURCH CALLE JOAQUINCALLE JOAQUINLOS OSOS VALLEY ROADAUTO PARK WAYIRISH HILLS
NATURAL
RESERVE
VISITOR SERVING COMMERCIAL
(HOTELS)
COSTCO
MOUNTAINBROOK
CHURCH
F ro o m C r e e k *Prefumo CreekSan Luis Obispo CreekUNINCORPORATEDUNINCORPORATED
SAN LUIS OBISPOSAN LUIS OBISPO
COUNTYCOUNTY
UNINCORPORATED
SAN LUIS OBISPO
COUNTY Proposed Froom Creek RealignmentVILLAGGIOVILLAGGIO
LIFE PLANLIFE PLAN
COMMUNITYCOMMUNITY
MADONNA FROOMMADONNA FROOM
RANCHRANCH
VILLAGGIO
LIFE PLAN
COMMUNITY
MADONNA FROOM
RANCH
AUTOAUTO
DEALERSHIPSDEALERSHIPS
IRISH HILLSIRISH HILLS
PLAZAPLAZA
SHOPPINGSHOPPING
CENTERCENTER
IRISH HILLS
PLAZA
SHOPPING
CENTER
AUTO
DEALERSHIPS
CITY OFCITY OF
SAN LUIS OBISPOSAN LUIS OBISPO
CITY OFCITY OF
SAN LUISSAN LUIS
OBISPOOBISPO
CITY OF
SAN LUIS OBISPO
CITY OF
SAN LUIS
OBISPO
Drainage 3
Drainage 4
Drainage 2
Drainage 1
150-FOOT E L EVATION CONTO
UR LIN
EEMERGENCYEMERGENCY
ACCESSACCESS
POINTPOINT
EMERGENCY
ACCESS
POINT
EMERGENCYEMERGENCY
ACCESSACCESS
EMERGENCY
ACCESS
EMERGENCYEMERGENCY
ACCESSACCESS
EMERGENCY
ACCESS
LOWER
AREA
UPPER
TERRACE
CROSS SECTION
LOCATION
(FIGURE 5-3)
LEGEND
Proposed Specific Plan
Land Use
Project Site
Villaggio (Private)
Madonna Froom
Ranch
Public Site Access
Roadways: 3.7 acres
Easement for Relocated
Stormwater Basin: 7.1 acres
Reconfigured Open Space
and Agricultural Conservation
Easement
C/OS-SP – Conservation/
Open Space: 70.7 acres
PF-SP – Public Facilities:
3.0 acres
R-3-SP – Medium-High Density
Residential: 23.4 acres
R-4-SP – High Density Residential:
7.3 acres
*Notes: Roadways within Villaggio are private and are included as part
of the medium high density residential land use. Froom Creek
would be realigned.
Alternative 2 Land Use Plan 5-4
FIGURE
Aerial Source: Google 2018.
0 500
SCALE IN FEET
N
5-92 01805
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-93
Final EIR
Land Use Plan and Site Design
Alternative 2 would increase clustering of development compared to the Project, including
limiting residential and commercial land uses to areas of the site below the 150-foot
elevation (see Figure 5-4). As compared to the Project, overall developed area would
decrease by 8.2 acres and more than 6.1 additional acres of the Upper Terrace would remain
as contiguous open space, substantially reducing direct and indirect habitat disturbance.
The quarry on Madonna Froom Ranch adjacent to the Irish Hills Natural Reserve would
also become open space as a new trailhead park under this alternative. Alternative 2 would
allow for the development of a total of up to 582 residential units within medium-high and
high density residential zones, including 178 multi-family units, 404 independent and
assisted senior villas and apartments, and 51 beds in residential health care facilities, which
is four more multi-family units than the Project. However, no commercial space would be
provided in Madonna Froom Ranch (Table 5-14), which would reduce development
compared to the Project by 100,000 sf. More than 160,000 sf of administrative and ancillary
buildings would continue to be provided within Villaggio.
Table 5-14. Summary of Alternative 2 Zoning and Land Uses
Proposed Zones Acreage Housing Units/ sf
VILLAGGIO
R-3-SP Medium-High Density Residential 23.5 404 units/51 beds
Independent Living Units 366 units
Assisted Living Units 38 units
Health Care Units (Skilled Nursing & Memory Care) 51 beds
Health Care Administration Building 85,670 sf
Ancillary Uses (wellness center, restaurants, theater,
etc.)
76,509 sf
MADONNA FROOM RANCH
R-4-SP High Density Residential 7.4 178 multi-family units
PF-SP Public Facilities 3.2 --
ADDITIONAL USES
C/OS-SP Conservation/ Open Space 70.1 --
Designated Open Space 62.9 --
Reconfigured Agricultural Easement 7.1 --
Roadways 5.6 --
TOTAL 109.7 582 units/51 beds1
1 Total exceeds Maximum 350 units as allowed in Section 8.1.5 of the General Plan LUE due to transition of allowed
commercial land uses to residential land uses. This total assumes all units planned within residential land uses.
Alternative 2 would continue to provide a Life Plan Community within 23.4 acres
designated as R-3-SP in Lower Villaggio, with additional apartment units provided by
expanded and taller buildings in the central area of Lower Villaggio, similar to Alternative
01806
5.0 ALTERNATIVES
5-94 Froom Ranch Specific Plan
Final EIR
1. Madonna Froom Ranch would continue to provide multi-family housing within 7.4 acres
of R-4-SP, with a density of 24 units per acre. A majority of these multi-family homes
would be relocated eastward away from sensitive habitats and high fire hazards from the
Irish Hills Natural Reserve and would replace commercial uses proposed under the Project.
A trailhead park would be provided within 3.3 acres of Public Facilities (PF-SP) designated
area in the same location as under the Project. Areas proposed for Medium-High Density
Residential uses under the Project within the existing quarry above the 150-foot elevation
contour line adjacent to the Irish Hills Natural Reserve would be set aside as open space.
These changes would ensure the land use plan better aligns with the policies of the City
General Plan regarding development above the 150-foot elevation contour. The land use
plan for Alternative 2 would reserve over 63 percent of the site (70.1 acres) in C/OS-SP,
including preservation of almost 50 acres of contiguous open space on the Upper Terrace
above the 150-foot elevation.
Froom Creek would be realigned and restored similar to the Project and stormwater
management would be provided similar to the Project (see Section 2.5.4, Stormwater
Management System and Froom Creek Realignment). Since Alternative 2 would not
involve development above 150-foot elevation, this alternative would not require a General
Plan amendment to address this policy inconsistency associated with the Project. Grading,
retention walls, and fencing plans would be similar to Alternative 1.
Circulation and Site Access
Similar to the Project, circulation under Alternative 2 would entail provision of public
roadways within Madonna Froom Ranch (Collectors A and B) and private local roadways
in Villaggio. However, because all development would be restricted to below the 150-foot
elevation contour, the road system would be substantially reduced in length compared to
the Project, particularly local private roads. Emergency access via Mountainbrook Church
would not be part of this alternative. Similar to the Project, Alternative 2 would have a
primary entrance from LOVR at Auto Park Way. This public roadway would lead to the
trailhead park, Madonna Froom Ranch neighborhoods, and the private gated entrance to
Villaggio. Major components of the circulation system proposed under Alternative 2 are
similar to the Project and are summarized below (see also Section 2.0, Project Description,
for more details):
1. A signalized intersection with LOVR that would provide four-way pedestrian
crosswalks and access to a new two-lane road (Collector “A”) that would serve as
the primary access to the Specific Plan area;
01807
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-95
Final EIR
2. Widening of LOVR along a portion of the Project site’s frontage;
3. Internal roadway network consisting of public and private roads;
4. Bicycle and pedestrian facilities throughout the Specific Plan area;
5. Parking facilities to accommodate residents, employees, and visitors within the
Specific Plan area;
6. A new bus stop that would be integrated into the regional public transportation
system; and
7. Three separate emergency access points would be provided, similar to Alternative
1 (see Figure 5-4).
Proposed Housing and Population
Population and housing under Alternative 2 would be similar to the Project; allocation of
units between different allowable densities and product types (e.g., Life Plan Community,
multi-family units) would remain similar. Alternative 2 would alter the land use plan and
incrementally adjust dwelling unit allocation, replacing 130 R-3-SP units in Madonna
Froom Ranch with 134 R-4-SP units to allow for building clustering and greater densities
(see Table 5-15).
Similar to the Project, proposed housing components of Alternative 2 would include a mix
of single-family or duplex units in Villaggio and higher density multi-family
condominiums and apartments in both Madonna Froom Ranch and Villaggio. Residential
uses would have a similar mix of housing densities and average lot sizes as proposed for
the Project, with dispersed single-story Villas, two story Garden Terraces, and up to 4-story
buildings supporting Piazza Apartments and Community Village Apartment suites. Exact
unit layout and design is not currently known
Table 5-15. Summary and Comparison of Housing and Population
Residential Alternative 2 Project
Housing Type Alternative 2
Proposed Units
Estimated
Population1
Project Proposed
Units
Estimated
Population1
R-3-SP - Villaggio 404 units/51 beds 976 404 units/51 beds 976
R-3-SP – Madonna
Froom Ranch2
- - 130 units 298
R-4-SP -Madonna
Froom Ranch2
178 units 408 44 units 101
TOTAL 578 units/51 beds 1,3843 578 units/51 beds 1,3753
1 Population estimates are based on the number of units multiplied by the average number of persons per household. In
the City of San Luis Obispo, the average number of persons per household is 2.29 (City of San Luis Obispo 2015).
2Per the City’s zoning ordinance, R-3 and R-4 units are expressed as density units. The number of actual dwelling units
in the R-3 and R-4 zone may vary depending on the number of bedrooms.
3Differences in estimated populations are a result of rounding inaccuracies and estimated populations are assumed to be
the same.
01808
5.0 ALTERNATIVES
5-96 Froom Ranch Specific Plan
Final EIR
Analysis –Alternative 2 (Residential Development Project Alternative)
Impacts under this alternative would be considerably less than that of the Project. Primary
changes would consist of substantially increased clustering, improved protection of open
space, and removal of all commercial uses. However, four additional residential units
would be constructed in Madonna Froom Ranch under this alternative. Froom Creek would
continue to be realigned under this Project, resulting in continued potential adverse and
beneficial impacts. Avoidance of development above the 150-foot elevation line would
substantially reduce potential impacts relating to aesthetics, biological resources, and
wildfire hazards as compared to the Project.
Aesthetics and Visual Resources
Since development would not occur above the 150-foot elevation, within the Villaggio
Upper Terrace or Madonna Froom Ranch quarry, impacts to scenic resources would be
substantially decreased under this alternative. Avoiding development above the 150-foot
elevation line would protect existing onsite visual resources including natural habitats and
serpentine rock outcroppings and would ensure a more gradual transition from rural land
uses within the Irish Hills Natural Reserve to the urban land uses proposed under
Alternative 2. While inclusion of taller structures within Villaggio could incrementally
increase visibility of these buildings, substantially increased open space protection would
reduce overall impacts to key views. Impacts to key views would be similar to the Project
and Alternative 1. Implementation of mitigation measures as under the Project would
require vegetative screens for buildings and associated infrastructure and would ensure
potential impacts to aesthetic character would be mitigated to less than significant. Impacts
related to nighttime lighting and glare would also be reduced as a result of reduced building
construction. Therefore, impacts from Alternative 2 would be less than significant with
mitigation.
Agricultural Resources
Because the area impacted by development under this alternative is substantially less
severe when compared to the Project, including avoidance of development within the
Villaggio Upper Terrace and the existing quarry area, impacts to agricultural resources
would be reduced. Further, this alternative would not result in the loss of Important
Farmland. Impacts would therefore remain less than significant.
01809
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-97
Final EIR
Air Quality and GHG Emissions
Under Alternative 2, vehicle trip generation would be slightly reduced due to removal of
commercial development from Madonna Froom Ranch, decreasing potential air quality
and GHG emission impacts compared to the Project. Elimination of development above
150-foot elevation would substantially reduce grading needs for this alternative and would
limit use of heavy construction equipment and associated emissions. Although residential
units would be approximately the same as under the Project, this alternative would greatly
decrease onsite commercial development, substantially reducing vehicle trips and GHGs
and other air pollutant emissions associated with operations of commercial development.
Additionally, the Project would continue to be required to implement mitigation measures
to further reduce potential impacts to air quality. Despite substantial reductions as
compared to the Project, impacts to air quality from implementation of this alternative
remain significant due to inability to feasibly predict reductions in long-term operational
(particularly mobile-source) emissions from required mitigation. Additionally, as a result
of exceedance of population growth projections from the 2001 Clean Air Plan, the
alternative would continue to be inconsistent with the 2001 Clean Air Plan, resulting in
significant and unavoidable impacts.
Biological Resources
Impacts to biological resources under Alternative 2 would be substantially reduced as
compared to the Project and would be similar to Alternative 1. This alternative would not
include residential development (Villaggio or Madonna Froom Ranch) above the 150-foot
elevation line and would substantially reduce the building footprint and required onsite
construction and grading within areas supporting sensitive natural habitats, thereby greatly
reducing potential impacts to sensitive habitats and species onsite. This alternative would
completely remove development within the Upper Terrace and impacts to sensitive species,
drainages, and onsite wetlands within this area would be substantially avoided and/or
reduced. Alternative 2 would reserve the existing quarry area as open space, which may
support enhanced biological productivity over time in this currently degraded area adjacent
to Froom Creek. Secondary impacts of fire clearance on native habitats would also be
greatly reduced as the urban-wildland interface would be decreased by approximately 50
percent due to building clustering and removal of development above the 150-foot
elevation line. However, Froom Creek would continue to be realigned and restored under
this alternative and major clearing of riparian vegetation along LOVR ditch would
continue, which could result in potential impacts to sensitive riparian habitats and species.
01810
5.0 ALTERNATIVES
5-98 Froom Ranch Specific Plan
Final EIR
Additionally, residential units in the southwestern area of Lower Villaggio developed
under this alternative would continue to impact habitat connectivity between Froom Creek
and grassland within the Upper Terrace, as well as impacts to sensitive riparian and wetland
species at the confluence of Drainages 1, 2, and 3. Implementation of mitigation measures
described under Section 3.4, Biological Resources, as well as MM BIO-Alt. 1 would
substantially reduce potential impacts to sensitive and protected species, onsite natural
habitats, and ecotone connectivity. However, potentially impacts to the Calle Joaquin
wetlands would continue to occur as a result of creek realignment and LOVR drainage
frontage improvements. Therefore, impacts would remain significant and unavoidable.
Cultural and Tribal Cultural Resources
Impacts to cultural and tribal cultural resources under this alternative would be reduced, as
avoidance of development within the Upper Terrace area of the Villaggio would decrease
potential for impacts to known or potential archaeological sites. Site preparation and
grading would still occur within areas containing sensitive cultural resources with potential
for associated impacts, though required implementation of mitigation measures would
reduce potential impacts during operation and construction of this alternative. Although
appropriate mitigation measures would be required, relocation of dairy structures within
Froom Ranch would continue to have significant and unavoidable impacts on potentially
significant historic resources. Overall impacts would be similar but slightly reduced as
compared to the Project.
Geology and Soils
Under this alternative, impacts related to geology and soils would be similar to the Project
due to similar construction activities and geologic hazards onsite. As under the Project,
design and construction of proposed land uses under this alternative would be subject to
the requirements and regulations of the CBC and the City Municipal Code to ensure
structural integrity in seismically active areas. By locating development outside of fault
setbacks and implementing the most current regulatory standards for structural design,
impacts of structural failure and risks to life and property due to seismic shaking, seismic-
related ground failure, and soil constraints or hazards under this alternative would be the
same as compared to the Project, and potential impacts would remain less than significant.
Hazards, Hazardous Materials, and Wildfire
Under this alternative, impacts related to fire hazards, hazardous materials, and airport
operations would be less than under the Project because of reduced construction activities
01811
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-99
Final EIR
due to substantial development clustering and smaller building footprints. Avoidance of
development above the 150-foot elevation line within the Villaggio Upper Terrace and the
northwestern portion of Madonna Froom Ranch would reduce urban-wildland interface by
approximately 50 percent, reducing defensible space requirements and increasing the
distance between proposed residential units and wildfires originating from western upland
areas with very high fire hazard potential. Additionally, similar to the Project, this
alternative would also be required to implement required mitigation measures that would
decrease likelihood of wildfires, improve fire response evacuation, and ensure firefighters
can attack fires encroaching on the Project site from the Irish Hills Natural Reserve.
Potential impacts from hazardous materials and aircraft would not substantially vary from
the Project due to similar construction activities and the amount and layout of development
in relation to aircraft hazard areas. Impacts from hazardous materials and contamination
during construction would be similar to the Project, and no new hazards due to use of
hazardous materials or exposure to airport safety hazards would result from this alternative.
However, as under the Project, Alternative 2 would be located in an area highly susceptible
to potential fire hazards and impacts would remain significant and unavoidable.
Hydrology and Water Quality
Under this alternative, impacts related to hydrology and water quality would not
substantially vary from the Project due to similar drainage improvements, including
realignment and restoration of Froom Creek and installation of a new stormwater detention
basin, as well as onsite retention features for water treatment. Development would be
substantially more clustered than the Project and areas of impervious surfaces would
decrease under this alternative (approximate 62.1 percent reduction compared to the
Project). Further, this alternative would better retain natural watershed processes,
particularly in the higher elevation areas of the watershed onsite due to lack of development
within these areas compared to the Project. This alternative would continue to be required
to comply with applicable local, regional, state, and federal water quality protection and
stormwater management requirements, further reducing the potential for significant
impacts. Similar to the Project, required mitigation measures would minimize potential
impacts to hydrologic resources during construction and reduce potential erosion of the
realigned Froom Creek that could result from storm events. Additionally, avoidance of
development within the Upper Terrace would prevent impacts to Drainages 1, 2, and 3, as
well as hydrologically connected habitats downstream including grasslands and federal
jurisdiction wetlands. Similar to the Project, impacts would be less than significant with
mitigation.
01812
5.0 ALTERNATIVES
5-100 Froom Ranch Specific Plan
Final EIR
Land Use and Planning
Impacts under this alternative would be less than under the Project because, consistent with
the requirements of the General Plan LUE, development would not occur above the 150-
foot elevation line. By avoiding development in these upper elevations on site, this
alternative would greatly improve consistency with adopted City policies. Required
implementation measures would further increase habitat connectivity and compliance with
Conservation and Open Space Policies 7.3.3, Wildlife Habitat and Corridors, and 7.7.7,
Preserve Ecotones. Avoiding residential development above the 150-foot elevation line,
including in the Upper Terrace of Villaggio and the northwestern portion of Madonna
Froom Ranch, would minimize aesthetic impacts, as well as fire hazards, and would be
consistent with the requirements of Hillside Planning Area policies in the City General
Plan. As under the Project, this alternative would be required to implement mitigation
measures to avoid significant impacts to the viability of the onsite agricultural easement.
However, this alternative would continue to relocate structures within the historic Froom
Ranch Dairy complex, resulting in the relocation and/or permanent loss of structures
composing a potential historic district despite implementation of mitigation measures and
causing potential inconsistencies with COSE Policies 3.3.1, Historic Preservation, 3.3.3,
Historical Documentation, and 3.3.4, Changes to Historic Buildings. Impacts would
remain significant and unavoidable.
Noise
Under this alternative, construction and operational noise impacts would be incrementally
less adverse when compared to the Project. Despite elimination of commercial land uses
in Madonna Froom Ranch and implementation of applicable mitigation measures,
development of residential units and realignment of Froom Creek would continue to cause
construction noise levels that exceed City noise thresholds for sensitive receptors adjacent
to the Project site. Required implementation of mitigation measures similar to those under
the Project would reduce exposure of proposed residential units to noise levels above City
thresholds, as would substantial reductions in commercial development. Impacts resulting
from operations of the Alternative would therefore be incrementally less than under the
Project and would remain less than significant with mitigation.
Population and Housing
Impacts to population and housing would be less than to the Project, as this alternative
would develop a similar number of units but would not develop onsite commercial land
01813
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-101
Final EIR
uses. Assuming Citywide household size of 2.29 persons per household, this alternative
would be expected to increase the City’s population by approximately 1,384 persons,
which is incrementally more than the Project. Assuming 550 square feet per job in planned
commercial uses, this alternative would result in 182 fewer jobs than the Project,
incrementally improving the City’s existing jobs/housing imbalance by providing more
housing compared to jobs onsite. Although this alternative would replace medium- high
density units in Madonna Froom Ranch with high density units, potentially improving
provision of workforce housing, this alternative would not result in additional affordable
housing units as compared to the Project. As under the Project, impacts would be
considered less than significant.
Public Services and Recreation
This alternative would result in decreased impacts to public services due to elimination of
commercial land uses that would be developed under the Project. Population increases
resulting from the alternative are expected to be similar, and corresponding increases in
demand and associated potential for impacts on police, fire protection, and education
services and facilities would also be similar to the Project. Elimination of commercial land
uses on site would also incrementally decrease demand on these services due to elimination
of uses which generate greater demands for service. While dedicated parkland within the
Project site would continue to be deficient to serve the anticipated increase in population,
this alternative would be required to implement mitigation measures to ensure appropriate
recreational facilities would be maintained within the City’s Sphere of Influence, and
impacts would continue to be less than significant with mitigation.
Transportation and Traffic
Alternative 2 would have slightly fewer traffic and transportation impacts compared to the
Project. Although additional residential units would be anticipated to increase traffic,
Alternative 2 would not develop commercial units within Madonna Froom Ranch (e.g.
hotel, retail) that would also contribute to increased daily trips. This alternative would be
required to comply with applicable local, regional, state, and federal transportation
requirements, and would require implementation of applicable mitigation measures to
further reduce potential impacts. However, as trip generation and demand for multi-modal
transportation facilities is expected to be approximately similar to the Project, impacts to
area roadways would continue to be considered significant and unavoidable under
Alternative 2 in the near-term while the Prado Road Overpass is constructed. As under the
01814
5.0 ALTERNATIVES
5-102 Froom Ranch Specific Plan
Final EIR
Project, cumulative impacts would be considered less than significant with mitigation once
the Prado Road Overpass is complete.
Utilities and Energy Conservation
Impacts to utilities would be less severe when compared to the Project, due to the
elimination of onsite commercial land uses and reduction in the development footprint.
Elimination of commercial land uses would also reduce impacts to utility services such as
solid waste disposal and electricity. In addition, similar to the Project, this alternative
would continue to comply with applicable design, engineering, and installation
requirements and guidelines to increase energy efficiency and minimize environmental
impacts to the maximum extent feasible. Applicable mitigation measures would also be
required under this alternative, and impacts would continue to be considered less than
significant with mitigation.
Mineral Resources
Impacts to mineral resources would be incrementally reduced under this alternative as
under the Project. This alternative would designate the existing red rock quarry for Open
Space/Conservation, theoretically retaining available acreage for extraction of this resource
within the County. However, mineral resource extraction is prohibited in the City’s General
Plan and would not be allowed following adoption of the FRSP. Therefore, impacts to
mineral resources within the City would continue to be less than significant.
5.4.2.4 Alternative 3 – Minimum LUE-Compliant Project Alternative
Alternative 3 would be a low-build alternative with the most restricted area for
development and a major redesign of key Project elements. Alternative 3 would
substantially reduce the development capacity of the Project site to the minimum
development allowed by the General Plan LUE. This alternative would be most closely
aligned with the existing General Plan LUE performance standards and minimum
development policy framework for the Project site with regard to the land use mix and
allowable development levels. Alternative 3 would support 200 multiple family residential
units, 50,000 sf of commercial uses and 3.0 acres of public facilities, but would not support
development of a Life Plan Community. This development would be clustered in already-
disturbed areas of the Project site on the northern side and below the 150-foot elevation
line, which would avoid or minimize a range of environmental impacts identified in this
EIR. Alternative 3 would reduce or change Project impacts through:
01815
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-103
Final EIR
1. Residential development would be reduced to 200 units consistent with the
minimum development performance standards of the LUE SP-3, Madonna on
LOVR Specific Plan Area, from 582 units and 51 beds under the Project (an
approximately 65.6 percent reduction). Residential uses would be confined to 10
acres that would be developed under R-3-SP Medium-High Density zoning at a
maximum density of 20 units/acre;
2. Commercial development would be reduced to 50,000 sf consistent with the
minimum development performance standards of the LUE SP-3, a reduction of 50
percent from the Project, with commercial uses limited to 2.5 acres compared to
3.1 acres under the Project;
3. The Villaggio Life Plan Community would no longer be developed, thereby
avoiding a range of impacts associated with biological and cultural resources
(particularly in the Upper Terrace), hydrology and water quality, and fire hazards
but also not maximizing housing production to address jobs housing balance issues,
particularly for senior housing, consistent with City Housing goals;
4. Froom Creek would not be realigned, thereby avoiding the potential impacts and
benefits associated with this major element of the Project. The existing Irish Hills
stormwater detention basin system would be retained and expanded or modified to
accommodate any increases in runoff under this alternative. Internal drainage and
stormwater improvements to slow and infiltrate runoff into the soil within
developed areas would remain similar to the Project;
5. Road improvements, including Commercial Collectors A and B would remain
similar to the Project, along with required widening of LOVR, with associated
impacts to riparian and wetland habitats along LOVR ditch, but no local or private
roads would be needed to serve Alternative 3;
6. Consistent with the City’s General Plan, all development would be confined to
areas below 150-foot elevation;
7. Emergency access would be provided at only two different connections: 1) from
the Irish Hills Plaza into Madonna Froom Ranch; and 2) from LOVR to the
southern area of Madonna Froom Ranch.
8. Required discretionary actions would be similar to the proposed Project, while the
construction phasing plan would be accelerated.
01816
5.0 ALTERNATIVES
5-104 Froom Ranch Specific Plan
Final EIR
Land Use Plan and Site Design
Alternative 3 would maximize clustering of development compared to the Project and
Alternatives 1 and 2, limiting residential and commercial land uses and associated roads
and infrastructure to less than a 20-acre area of the Project site below 150-foot elevation
(see Figure 5-5). Overall developed area would decrease by roughly 30 acres, compared to
the Project, with 89 acres of the Project Site (81 percent) retained as Conservation/Open
Space. Both the Upper Terrace and the majority of the lower area of Villaggio would
remain as contiguous open space, substantially reducing direct and indirect habitat
disturbance. The quarry on Madonna Froom Ranch adjacent to the Irish Hills Natural
Reserve would also become open space under this alternative.
Madonna Froom Ranch would continue to provide multi-family housing, but development
would be contained within 10 acres of Medium-High Density Residential (R-3-SP) zoning
designation, with a density of 20 units per acre under Alternative 3. A majority of these
multi-family homes would be located away from the habitats and high fire hazards of the
Irish Hills Natural Reserve. Approximately four acres would be located in an area along
the northern bank of Froom Creek, which would provide somewhat of a fire buffer between
this area and high fire hazards within the Irish Hills Natural Reserve.
01817
Drainage 4Drainage 4
150-FOOT E L EVATION CONTO
UR LIN
EF ro o m C r e e k Prefumo CreekSan Luis Obispo Creek101
CALLE JOAQUINLOS OSOS VALLEY ROADLOS OSOS VALLEY ROADCALLE JOAQUINAUTO PARK WAYAUTO PARK WAYIRISH HILLSIRISH HILLS
NATURALNATURAL
RESERVERESERVE
VISITOR SERVING COMMERCIALVISITOR SERVING COMMERCIAL
(HOTELS)(HOTELS)
COSTCOCOSTCO
MOUNTAINBROOKMOUNTAINBROOK
CHURCHCHURCH CALLE JOAQUINCALLE JOAQUINLOS OSOS VALLEY ROADAUTO PARK WAYIRISH HILLS
NATURAL
RESERVE
VISITOR SERVING COMMERCIAL
(HOTELS)
COSTCO
MOUNTAINBROOK
CHURCH
F ro o m C r e e k Prefumo CreekSan Luis Obispo CreekUNINCORPORATEDUNINCORPORATED
SAN LUIS OBISPOSAN LUIS OBISPO
COUNTYCOUNTY
UNINCORPORATED
SAN LUIS OBISPO
COUNTY
AUTOAUTO
DEALERSHIPSDEALERSHIPS
IRISH HILLSIRISH HILLS
PLAZAPLAZA
SHOPPINGSHOPPING
CENTERCENTER
IRISH HILLS
PLAZA
SHOPPING
CENTER
AUTO
DEALERSHIPS
CITY OFCITY OF
SAN LUIS OBISPOSAN LUIS OBISPO
CITY OFCITY OF
SAN LUISSAN LUIS
OBISPOOBISPO
CITY OF
SAN LUIS OBISPO
CITY OF
SAN LUIS
OBISPO
Drainage 3
Drainage 4
Drainage 2
Drainage 1
150-FOOT E L EVATION CONTO
UR LIN
EEMERGENCYEMERGENCY
ACCESSACCESS
POINTPOINT
EMERGENCY
ACCESS
POINT
EMERGENCYEMERGENCY
ACCESSACCESS
EMERGENCY
ACCESS
LOWER
AREA
UPPER
TERRACE
LEGEND
Proposed Specific Plan Land Use
Project Site
Existing 3.2-Acre Stormwater Basin
Public Site Access Roadways: 3.8 acres
Reconfigured Open Space and
Agricultural Conservation Easement
C-R-SP – Retail Commercial/ General Commercial:
2.5 acres
C/OS-SP – Conservation/Open Space: 89.0 acres
PF-SP – Public Facilities: 3.0 acres
R-3-SP – Medium-High Density Residential:
10.0 acres
Alternative 3 Land Use Plan 5-5
FIGURE
Aerial Source: Google 2018.
0 500
SCALE IN FEET
N
5-10501818
5.0 ALTERNATIVES
5-106 Froom Ranch Specific Plan
Final EIR
Table 5-16. Summary of Alternative 3 Zoning and Land Uses
Proposed Zones Acreage Housing Units/ sf
R-3-SP Medium-High Density Residential 10 200 multi-family
units
C-R-SP Retail-Commercial 2.5 50,000 sf
PF-SP Public Facilities 3.0 --
ADDITIONAL USES
C/OS-SP Conservation/ Open Space 88.9 --
Designated Open Space 81.8 --
Reconfigured Agricultural Easement 7.1 --
Roadways 5.6 --
TOTAL 109.7
200 units1
50,000 sf
commercial
1 Total matches minimum performance standards as allowed in Section 8.1.5 of the General Plan LUE. This total
assumes all units planned within residential land uses.
Areas proposed for Medium-High Density Residential (R-3-SP) uses under Alternative 3
would be limited to existing disturbed areas on the northeastern portion of the site and
outside of the existing onsite stormwater detention basin. Similar to the Project, the
northwestern corner of the site would be designated for Retail-Commercial (C-R-SP) uses,
but would only accommodate up to 50,000 sf. This alternative includes a trailhead park
within 3.0 acres of Public Facilities (PF-SP) designated area in the same location as under
the Project, but under the 150-foot elevation line. Areas within the quarry above the 150-
foot elevation contour line adjacent to the Irish Hills Natural Reserve would be set aside as
open space. These changes would ensure the land use plan better aligns with the policies
of the City’s General Plan regarding development above the 150-foot elevation contour.
Since Alternative 3 would not involve development above the 150-foot elevation, this
alternative would not require a General Plan amendment to address this policy
inconsistency associated with the Project.
Froom Creek would not be realigned and restored under Alternative 3 and stormwater
management would be supported partially by existing onsite infrastructure, which may
require upgrades or modifications to accommodate site development. The need for grading,
retaining walls, and fencing would be substantially less severe when compared to the
Project. Site disturbance would be limited to approximately 21.1 acres of relatively level
terrain that would not require substantial excavations, barring potential low-lying retaining
01819
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-107
Final EIR
walls along Froom Creek, which is currently perched behind a manmade berm along the
central portions of the site.
Circulation and Site Access
Similar to the Project, circulation under Alternative 3 would entail provision of public
roadways within Madonna Froom Ranch (Collectors A and B). All development would be
restricted to below the 150-foot elevation contour and would not extend substantially into
the lower area of Villaggio; therefore, the road system would be reduced in length
compared to the Project. Similar to the Project, Alternative 3 would have a primary
entrance from LOVR at Auto Park Way. Public roadways would lead to the trailhead park
and Madonna Froom Ranch neighborhoods. Major components of the Alternative 3
circulation system are similar to the Project and are summarized below:
1. A proposed signalized intersection with LOVR and proposed roadway to serve as
the primary access to the Specific Plan area;
2. Widening of LOVR along a portion of the Project site’s frontage;
3. Proposed internal roadway network consisting of public roads;
4. Proposed bicycle and pedestrian facilities on public roads;
5. Parking facilities to accommodate residents, employees, and visitors within the
Specific Plan area; and
6. A new bus stop that would be integrated into the regional public transportation
system.
7. Two separate emergency access points would be provided (see Figure 5-5) while
the Mountainbrook Church emergency access road would be deleted.
Proposed Housing and Population
Alternative 3 would provide substantially fewer units than the Project. Under this
alternative, 200 multi-family units would accommodate approximately 458 new residents,
assuming 2.29 persons per household.
Analysis – Alternative 3 (Minimum LUE-Compliant Alternative)
Impacts under this alternative would be considerably less than that of the Project. Primary
tradeoffs would consist of lower intensity buildout of both residential and commercial land
uses under this alternative, as well as elimination of development above the 150-foot
elevation line. Residential units would decrease by 378 units (65 percent) and commercial
development area would decrease by 50,000 square feet (50 percent). Additionally, senior
01820
5.0 ALTERNATIVES
5-108 Froom Ranch Specific Plan
Final EIR
housing units would not be provided within a Life Plan Community. Froom Creek would
not be realigned under this project, reducing potential impacts to noise and other affected
resources; however, lack of realignment of the creek would not support restoration or
improvement of the creek corridor to provide improved steelhead habitat or alleviate flood
capacity constraints downstream at U.S. 101. Retaining the majority of the site as open
space, including avoiding development above the 150-foot elevation line, would greatly
decrease potential environmental impacts, including impacts to biology, aesthetics, and
wildfire hazards.
Aesthetics and Visual Resources
Impacts to scenic resources onsite would be greatly decreased under this alternative as a
result of reduced development, particularly in areas of higher elevation. Avoiding
development above the 150-foot elevation would protect onsite scenic resources, including
natural habitats, open grazing land, and serpentine rock outcroppings. Designation of the
majority of the site as Conservation/Open Space would smooth visual transitions from rural
landscapes to commercial and residential development, substantially reducing impacts to
visual character of the Project site and surrounding area for viewers within the Irish Hills
Natural Reserve as compared to the Project. Implementation of MM VIS-1, requiring
vegetative screens for buildings and associated infrastructure, would ensure potential
impacts to aesthetic character would be less than significant. Impacts to nighttime lighting
and glare would also be reduced as compared to the project due to substantial reduction in
development area and associated exterior lighting.
Agricultural Resources
The area impacted by development under this alternative would be substantially less severe
when compared to the Project; this alternative would avoid development within the Upper
Terrace and the majority of the lower portion of Villaggio. This alternative would result in
greater protection of agricultural land currently used for grazing as open space, therefore,
impacts to agricultural resources would be reduced compared to the Project. Impacts would
remain less than significant.
Air Quality and GHG Emissions
Impacts to air quality and GHG emissions would be substantially reduced under this
alternative, as overall commercial development would be reduced by half and residential
development would be reduced by 378 units as compared to the Project. Grading required
for building construction would be substantially lessened under this alternative, which
01821
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-109
Final EIR
would greatly decrease emissions from heavy construction equipment. This alternative
would also reduce anticipated population increases by more than half, and corresponding
reductions in vehicle trips associated with reductions in residential, commercial, and senior
residential land uses. These reductions in development would also result in a decrease in
emissions generated onsite. Additionally, this alternative would be required to implement
applicable mitigation measures to further reduce potential impacts to air quality. As a
result, impacts to air quality from construction and operation of this alternative are
estimated to be lower than APCD thresholds and would no longer be considered
significant. Similar to the determination in the LUCE Update EIR, implementation of the
City’s General Plan would not be consistent with the assumptions contained in the Clean
Air Plan. Therefore, specific to consistency with the Clean Air Plan and potential impacts
related to GHG emissions from mobile sources, it is expected Alternative 3 would result in
significant and unavoidable impacts. All other air quality and GHG impacts are anticipated
to be less than significant with mitigation.
Biological Resources
Impacts under this alternative would substantially reduce potential impacts to biological
resources as compared to the Project. This alternative would not include development
above the 150-foot elevation line or realignment of Froom Creek, and would substantially
reduce the development area and required onsite construction grading as compared to the
Project. Reduced development onsite would minimize impacts to sensitive species,
drainages, and onsite wetlands that would occur under the Project, although there is
potential for sensitive-species to occur within the development footprint of Alternative 3.
Development of areas below the 150-foot elevation line would be greatly limited west of
Froom Creek, and habitat connectivity and ecotone protection would be substantially
increased as compared to the Project. Additionally, this alternative would develop 14.7
acres of residential units within the lower area of Villaggio, as compared to 23.4 acres
under the Project, preserving an additional 8.7 acres of sensitive grasslands onsite,
including serpentine bunchgrass. Continued required implementation of mitigation
measures as described under Section 3.4, Biological Resources, would further reduce
potential impacts to sensitive and protected species and natural habitats onsite. However,
although Froom Creek would not be realigned under this alternative, roadway
improvements along LOVR would continue to result in significant impacts to a federal
jurisdiction wetlands mapped within the LOVR ditch. Lack of realignment of Froom Creek
01822
5.0 ALTERNATIVES
5-110 Froom Ranch Specific Plan
Final EIR
would also not support improved steelhead habitat, as is proposed under the Project. With
restoration requirements, impacts would be less than significant with mitigation.
Cultural and Tribal Cultural Resources
Impacts to cultural and tribal cultural resources under this alternative would be reduced, as
the reduction in developed area within the Project site and a 278-unit reduction of
residential units would decrease potential for incidental discovery and impacts. Site
preparation and grading would still occur within areas containing sensitive cultural
resources, though mitigation measures would be implemented to reduce potential impacts
to less than significant during operation and construction of this alternative. Although
mitigation measures would be implemented, relocation of dairy structures on the Froom
Ranch to avoid fault lines would continue to have significant and unavoidable impacts on
potentially significant historic resources.
Geology and Soils
Under this alternative, impacts related to geologic and soil resources would be less severe
when compared to the Project due to reduced commercial and residential development and
minimal geologic hazards onsite. As under the Project, design and construction of proposed
land uses under this alternative would be subject to several requirements and regulations
to ensure structural integrity in seismically active areas. Additionally, residential
development would be reduced by 278 units and commercial land uses would be reduced
by 50,000 square feet, lessening potential impacts to residents, employees, and consumers
located onsite. By locating development outside of fault setbacks and implementing the
most current industry standards for structural design, impacts of structural failure and risks
to life and property due to seismic shaking and seismic-related ground failure under this
alternative would be reduced as compared to the Project, and potential impacts would
remain less than significant.
Hazards, Hazardous Materials, and Wildfire
Under this alternative, impacts related to fire hazards, hazardous materials, and airport
operations would be less than under the Project due to reduced construction activities
associated with substantial development reductions and smaller building footprints.
Reduction of development areas to already disturbed portions of the site in the northeast
corner would reduce urban-wildland interface by approximately 75 percent, reducing
defensible space requirements and increasing the distance between proposed residential
units and wildfires originating from western upland areas with very high fire hazard
01823
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-111
Final EIR
potential. Additionally, similar to the Project, this alternative would also be required to
implement required mitigation measures that would decrease likelihood of wildfires,
improve fire response evacuation, and ensure firefighters can attack fires encroaching on
the Project site from the Irish Hills Natural Reserve. Potential impacts from hazardous
materials and aircraft would not substantially vary from the Project due to similar
construction activities and the amount and layout of development in relation to aircraft
hazard areas. Impacts from hazardous materials and contamination during construction
would remain similar to the Project, and no new hazards due to use of hazardous materials
or exposure to airport safety hazards would result from this alternative. However, as under
the Project, Alternative 3 would be located in an area highly susceptible to potential fire
hazards, particularly at the base of the Froom Creek watershed where steep slopes and
prevailing winds increase potential for a fire in the Irish Hills to move towards the site, and
impacts would remain significant and unavoidable.
Hydrology and Water Quality
Under this alternative, impacts related to hydrology and water quality would be less than
those of the Project due to substantial reductions in development and retention of Froom
Creek in its existing alignment onsite. This alternative would result in 21.1 acres of
development, including 12.5 acres of residential and commercial uses, considerably
decreasing impervious surfaces as compared to the Project. Decreased construction of
pervious surfaces would increase groundwater recharge onsite and reduce the potential for
erosion, stormwater runoff, and onsite flooding as compared to the Project. The existing
onsite stormwater detention basin would continue to attenuate runoff from Irish Hills Plaza
and would be upgraded or modified under Alternative 3 to support limited additional
development on the Project site. However, impacts to flooding are likely to be increased
compared to the Project due to lack of proposed flood control improvements which would
alleviate capacity constraints at the U.S. 101 box culvert. Therefore, capacity constraints
would persist under this alternative, though this alternative would not contribute towards
those existing impacts. Mitigation measures implemented under this alternative would
continue to minimize potential impacts to hydrologic resources during construction.
Additionally, avoidance of development within the Upper Terrace would reduce the
potential for pollutants to enter Drainages 1, 2, or 3 and other hydrologically connected
sensitive habitats onsite. Therefore, impacts would be less than significant with mitigation.
01824
5.0 ALTERNATIVES
5-112 Froom Ranch Specific Plan
Final EIR
Land Use and Planning
Impacts under this alternative would be considerably less than under the Project, as
development would not occur above the 150-foot elevation line. By avoiding development
within the Upper Terrace and west of Froom Creek, this alternative would eliminate
impacts to serpentine native bunchgrass grassland habitats and minimize impacts to
springs, seeps, and wetlands along Drainages 1, 2 and 3, as well as associated impacts to
12 special status plant species. As a result, this alternative would comply with the General
Plan, including COSE Policies 7.3.1, Protect Listed Species, and 7.3.2, Protect Species of
Local Concern. Retaining the majority of the site as open space would minimize aesthetic
impacts and would be consistent with Hillside Planning Area policies in the City’s General
Plan. However, this alternative would continue to relocate the historic Froom Ranch Dairy
complex to preserve onsite historic structures and remove them from identified fault hazard
areas, resulting in permanent loss of structures composing a potential historic district
despite implementation of mitigation measures and causing potential inconsistencies with
COSE Policies 3.3.1, Historic Preservation, 3.3.3, Historical Documentation, and 3.3.4,
Changes to Historic Buildings. Impacts would remain significant and unavoidable due to
inconsistency with City policies and regulations.
Noise
Under this alternative, construction and operational noise impacts would be substantially
less severe when compared to the Project. Construction duration would be much shorter
than the Project and there would be no overlap in phases. All construction equipment would
be isolated on the northern side of the site, well away from sensitive receptors in the
adjacent hotel properties and Mountainbrook Church to the south. This alternative would
substantially reduce overall commercial and residential land uses as compared to the
Project and would continue to implement all applicable mitigation measures. Noise impacts
would be less than significant with mitigation.
Population and Housing
Impacts to population and housing would be less severe when compared to the Project, as
the alternative would develop 378 less residential units and 50,000 square feet less
commercial land uses. Assuming Citywide household size of 2.29 persons per household,
this alternative would result in housing for approximately 458 people, or 866 less people
than under the Project. This alternative would locate all residences within medium-high
density residential land uses, and senior living units would not be produced. Additionally,
01825
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-113
Final EIR
this alternative would be expected to result in 91 less jobs than under the Project. Given
this alternative does not proposed a Life Community Plan, the development of 200
residential units would result in an increase in housing that would count towards the City’s
housing supply. In compliance with City requirements, the additional 26 multi-family
residential units counting towards City housing supply would result in provision of
additional affordable housing units that would be constructed under inclusionary housing
requirements. Impacts would continue to be considered less than significant.
Public Services and Recreation
This alternative would result in decreased impacts to public services due to substantial
reduction of commercial and residential land uses as compared to the Project. Residential
population resulting from the alternative would be substantially reduced for this alternative,
and corresponding increases in demand on police, fire protection, and education services
and facilities would also be reduced. Reduction of commercial land uses on site by 50
percent would further reduce onsite population and decreased demand on these services.
Given elimination of senior living units and associated recreational amenities, it would be
reasonable to anticipate increased per capita demand for parkland, although overall
population on the Project site would be substantially reduced compared to the Project.
While dedicated parkland within the Project site would continue to be deficient to serve
the expected increase in population and would require payment of in-lieu fees, this
alternative would continue to implement mitigation measures ensuring appropriate
recreational facilities would be maintained within the City’s Sphere of Influence, and
impacts would continue to be considered less than significant with mitigation.
Transportation and Traffic
Alternative 3 would have substantially reduced impacts to transportation as compared to
the Project, as the development footprint would be considerably minimized, and trips
would be reduced. This alternative would reduce residential units by 65 percent and
commercial square footage by 50 percent compared to the Project. This large reduction in
development footprint would be significantly lower anticipated addition of trips to internal
and area roadways. Additionally, this alternative is consistent with the General Plan LUE
and the environmental impact analysis conducted in the LUCE Update EIR (City of San
Luis Obispo 2014). Finally, this alternative would comply with all applicable local,
regional, state, and federal requirements, as well as applicable mitigation measures.
Therefore, impacts under this alternative would be considered less than significant.
01826
5.0 ALTERNATIVES
5-114 Froom Ranch Specific Plan
Final EIR
Utilities and Energy Conservation
Impacts to utilities would be less severe when compared to the Project, due to the overall
substantial reductions of onsite commercial and residential land uses and reduction in the
development footprint. By reducing urban development onsite, this alternative would
considerably reduce potential demands for water, wastewater treatment, solid waste
disposal, and energy. Reduction of commercial land uses by 50 percent and residential
units by 378 units would considerably reduce impacts to utility services. In addition to
utilization of appropriate mitigation measures, this alternative would continue to comply
with applicable design, engineering, and installation requirements and guidelines to
increase energy efficiency and minimize environmental impacts to the maximum extent
feasible. As a result, impacts would continue to be less than significant with mitigation
under this alternative.
Mineral Resources
Impacts to mineral resources would be incrementally reduced under this alternative as
under the Project. The Alternative would designate the existing red rock quarry for Open
Space/Conservation, theoretically retaining available acreage for extraction of this resource
within the County. However, mineral resource extraction is prohibited under the City and
would not be allowed following adoption of the FRSP. Therefore, impacts to mineral
resources within the City would continue to be considered less than significant.
5.5 IDENTIFICATION OF ENVIRONMENTALLY SUPERIOR ALTERNATIVE
Section 15126.6(e)(2) of the State CEQA Guidelines indicates that an analysis of
alternatives shall identify an environmentally superior alternative among the alternatives
evaluated in the EIR. In general, the environmentally superior alternative as defined by
CEQA should minimize adverse impacts to the Project site and its surrounding
environment. Table 5-17 summarizes the environmental advantages and disadvantages
associated with the proposed Project and the four analyzed alternatives. Although the No
Project Alternative would result in the least amount of impacts, CEQA Guidelines section
15126.6 states that if the environmentally superior alternative is the No Project Alternative,
the EIR shall also identify an environmentally superior alternative from among the other
alternatives.
Although the No Project Alternative would result in the least amount of impacts, this
alternative would not meet most Project objectives. Given this, Alternative 1 is considered
to be the environmentally superior alternative since impacts would be reduced for many
01827
5.0 ALTERNATIVES
Froom Ranch Specific Plan 5-115
Final EIR
issue areas and all Project objectives would be met, as described below. Alternative 1
would substantially reduce impacts as compared to the Project in the following resource
areas: aesthetics and visual resources; biological resources; cultural and tribal cultural
resources; hazards, hazardous materials, and wildfires; and land use and planning. For
instance, avoidance of development within the Upper Terrace area of Villaggio would
greatly eliminate impacts to biological resources, including serpentine native bunchgrass
grassland habitats, and would minimize impacts to springs, seeps, and wetland habitats
along Drainages 1, 2, and 3, as well as associated impacts to 12 special status plant species.
Despite substantial reductions to many impacts under Alternative 1 as compared to the
Project, Alternative 1 would continue to result in significant and unavoidable impacts to
air quality and greenhouse gases; biological resources; historic resources; hazards,
hazardous materials, and wildfires; land use and planning; noise; and transportation and
traffic.
Alternative 1 would also achieve all of the Project objectives. This alternative is largely
consistent with the General Plan LUE, and would develop a mix of commercial, residential,
and open space/recreation uses on the Project site. A variety of housing opportunities
would be available, including affordable housing as well as potentially more affordable,
higher density multi-family housing opportunities and 404 residential units for seniors in a
Life Plan Community. The Project site would provide additional opportunities to access
the Irish Hills Natural Reserve system, as well as new public parkland within the Project
site that would be located adjacent to the Irish Hills Natural Reserve. Avoidance of
development within the Upper Terrace area preserves sensitive plant and wildlife species,
including the state- and federally-endangered Chorro Creek bog thistle, as well as
important drainages and wetlands within this area. Additionally, realignment of Froom
Creek under Alternative 1 would improve stormwater conveyance and create riparian
habitat, enhancing fish habitat, and biological resource value. Alternative 1 would be
similar to the Project in its contribution to the regional transportation system and its
adherence to sustainable development practices and design features. Therefore, this
alternative is considered to be the environmentally superior alternative over other
alternatives, as shown in Table 5-17.
01828
5.0 ALTERNATIVES
5-116 Froom Ranch Specific Plan
Final EIR
Table 5-17. Impact Comparison of Alternatives to the Proposed Project
Issue Area No Project
Alternative 1 –
Clustered
Development
Below the 150-
Foot Elevation
Alternative
(Actionable
Alternative)
Alternative 2 –
Residential
Development
Project
Alternative
Alternative 3 –
Minimum LUE-
Compliant
Project
Alternative
Aesthetics and
Visual Resources Less Less Less Less
Agricultural
Resources Less Similar Similar Less
Air Quality and
GHG Emissions Less Similar Similar Less
Biological
Resources Less Less Less Less
Cultural and
Tribal Resources Greater Less Less Less
Geology and
Soils Less Similar Similar Similar
Hazards,
Hazardous
Materials, and
Wildfires
Less Less Less Less
Hydrology and
Water Quality Less Similar Similar Less
Land Use and
Planning Less Less Less Less
Noise Less Less Less Less
Population and
Housing Greater Similar Similar Less
Public Services Less Similar Similar Less
Transportation
and Traffic Less Similar Similar Less
Utilities and
Energy
Conservation
Less Similar Similar Less
Mineral
Resources Less Similar Similar Similar
Project
Objectives Met? No Yes Partially Partially
01829
6.0 LIST OF PREPARERS
Froom Ranch Specific Plan 6-1
Final EIR
6.0 LIST OF PREPARERS
City of San Luis Obispo
Michael Codron Director of Community Development
Doug Davidson Deputy Director
Tyler Corey Principal Planner
Robert Hill Natural Resources Manager
Shawna Scott Senior Planner
Luke Schwartz Transportation Planning/Engineering
Christopher Read Sustainability Manager
Emily Creel SWCA Environments Consultants, Contract
City Planner
Wood Environment & Infrastructure Solutions, Inc.
Dan Gira Project Principal
Erika Leachman Project Manager
Taylor Lane Deputy Project Manager
Julia Pujo Deputy Project Manager
Linn Zukor QA/QC
Doug McFarling QA/QC
Aaron Johnson GIS Specialist
Angie Harbin-Ireland Senior Biologist
David King Biologist
John Chestnut Botanist
Brian Cook Senior Noise Specialist
David Stone Cultural Resources Specialist
Keri Gannon Water Resources Specialist
Matthew Sauter Paleontologist
Taylor Lane CEQA Air Quality Specialist
Matt Buggert Lead Environmental Analyst
Aidan Patterson Environmental Analyst
Kaylan Lamb Environmental Analyst
Hannah Thomas Environmental Analyst
Rosann Malloch Project Administrator
Rita Samaniego Administrative Assistant
Janice Depew Word Processor
Applied Earthworks
Barry Price Principal
Graphics Consultant
Deirdre Stites Graphics Specialist
01830
7.0 LIST OF PREPARERS
6-2 Froom Ranch Specific Plan
Final EIR
TJKM Traffic Consultants
Ruta Jariwala Principal
VIZf/x
Robert Staehle Principal / Architect
01831
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-1
Final EIR
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
SECTION 1.0 INTRODUCTION
City of San Luis Obispo. 2014. Land Use and Circulation Elements Update EIR.
SECTION 3.1 AESTHETICS AND VISUAL RESOURCES
California Department of Transportation (Caltrans). 2017. Scenic Highways. Caltrans.
Accessed: 12 June 2018. Retrieved from:
http://www.dot.ca.gov/design/lap/livability/scenic-highways/
City of San Luis Obispo. 2006. General Plan - Conservation and Open Space Element.
——. 2010. Community Design Guidelines. Retrieved from:
http://www.slocity.org/home/showdocument?id=2104. Accessed: February 2016
——. 2014. General Plan - Circulation Element. City of San Luis Obispo - General Plan.
Accessed: 12 June 2018. Retrieved from:
http://www.slocity.org/home/showdocument?id=6637
——. 2015. Zoning Regulations. Available at:
http://www.slocity.org/home/showdocument?id=5861. Accessed: April 2016.
SECTION 3.2 AGRICULTURAL RESOURCES
California Department of Conservation. 1997. “California Agricultural Land Evaluation
and Site Assessment (LESA) Model.”
———. 2016. “FMMP- Important Farmland Map Categories.” 2016.
http://www.conservation.ca.gov/dlrp/fmmp/mccu/Pages/map_categories.aspx.
California Department of Conservation, Division of Land Resource Protection. 2012.
“Table A-31 San Luis Obispo County 2010-2012 Land Use Conversion.”
https://www.conservation.ca.gov/dlrp/fmmp/Pages/SanLuisObispo.aspx.
———. 2014. “Table A-31 San Luis Obispo County 2012-2014 Land Use Conversion.”
https://www.conservation.ca.gov/dlrp/fmmp/Pages/SanLuisObispo.aspx.
———. 2016. “Table A-31 San Luis Obispo County 2014-2016 Land Use Conversion.”
https://www.conservation.ca.gov/dlrp/fmmp/Pages/SanLuisObispo.aspx.
City of San Luis Obispo. 2014. “Land Use and Circulation Elements Update EIR.”
http://www.slocity.org/home/showdocument?id=6723.
County of San Luis Obispo. 2017. “2017 Annual Crop Report.”
https://www.slocounty.ca.gov/getattachment/597e9e60-dc50-4d7e-9fe0-
d2f8a80f8874/Crop-Report-2017.aspx.
01832
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-2 Froom Ranch Specific Plan
Final EIR
Natural Resources Conservation Service (NRCS). 2016. “Soil Classification in the
Online Web Soil Survey,” 2016.
———. 2018. “Natural Resources Conservation Service - Web Soil Survey - San Luis
Obispo County, California, Coastal Part (CA664).” 2018.
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.
SECTION 3.3 AIR QUALITY
Association of Environmental Professionals (AEP). 2016. “Final White Paper - Beyond
2020 and Newhall: A Field Guide to New CEQA Greenhouse Gas Thresholds and
Climate Action Plan Targets in California.” https://califaep.org/docs/AEP-
2016_Final_White_Paper.pdf.
Air Resources Board (ARB). 2007. “Press Release: 2007-12-06 Air Board Passes Two
Major Building Blocks in State’s Effort to Fight Global Warming.” 2007.
http://www.arb.ca.gov/newsrel/nr120607.htm.
———. 2008. “Climate Change Scoping Plan.”
California Department of Finance. 2018. “E-1 Population Estimates for Cities, Counties,
and the State — January 1, 2017 and 2018.” 2018.
http://dof.ca.gov/Forecasting/Demographics/Estimates/E-1/.
California Natural Resources Agency. 2009. “California Climate Adaptation Strategy.”
2009. http://resources.ca.gov/docs/climate/Statewide_Adaptation_Strategy.pdf.
———. 2018. “California’s Fourth Climate Change Assessment: Central Coast Region
Report.” http://www.climateassessment.ca.gov/about/.
California Air Resources Board (CARB). 2017. “The 2017 Climate Change Scoping Plan
Update.” 2017. https://www.arb.ca.gov/cc/scopingplan/2030sp_pp_final.pdf.
———. 2018. “Quality Assurance Air Monitoring Site Information - San Luis Obispo-
Higuera Street.” California Air Resources Board. 2018.
https://www.arb.ca.gov/qaweb/site.php?s_arb_code=40836.
———. 2019. “Air Quality Data (PST) Query Tool.” California Air Resources Board.
2019. https://www.arb.ca.gov/aqmis2/aqdselect.php.
City of San Luis Obispo. 2012. “Climate Action Plan.”
https://www.slocity.org/government/department-directory/city-
administration/office-of-sustainability/climate-action/climate-action-plan-1949.
———. 2014. “General Plan Ch1 - Land Use Element.”
———. 2018. “Council Agenda Report - September 18, 2018: Climate Action Plan
Update Status Report, Greenhouse Gas Emissions Inventory Update, and
01833
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-3
Final EIR
Direction on GHG Reduction Targets Study Session.”
http://opengov.slocity.org/weblink/DocView.aspx?dbid=1&id=83887&page=1&c
r=1.
San Luis Obispo County Air Pollution Control District (SLO County APCD). 2012.
“CEQA Air Quality Handbook.” 12.10.2015.
———. 2001. “Clean Air Plan.” https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/business/pdf/CAP.pdf
———. 2012. “CEQA Air Quality Handbook - A Guide for Assessing the Air Quality
Impacts for Projects Subject to CEQA Review.”
https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/CEQA_Handbook_2012_v2%20%28Updated%20N
ovember%202018%29_LinkedwithMemo.pdf.
———. 2019. “San Luis Obispo County Attainment Status.” 2019.
https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/AttainmentStatus29January2019.pdf.
San Luis Obispo Council of Governments (SLOCOG). 2017. “2050 Regional Growth
Forecast for San Luis Obispo County.” SLOCOG - Regional Growth Forecasts.
2017.
https://www.dropbox.com/s/5tl8ia0j8zixrry/2050RegionalGrowthForecast_01Full
Report_RevDec2017.pdf?dl=0.
United States Energy Information Administration (U.S. EIA). 2017. “U.S. Energy
Information Administration (EIA) - State Carbon Dioxide Emissions Data
Summary - Data for 2015 - Released October 2017.” 2017.
https://www.eia.gov/environment/emissions/state/.
———. 2018. “Draft Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-
2016 Full Report.” 2018. https://www.epa.gov/ghgemissions/draft-inventory-us-
greenhouse-gas-emissions-and-sinks-1990-2016.
Western Regional Climate Center. 2016. “Monthly Climate Summary - San Luis
Obispo.” 2016. https://wrcc.dri.edu/cgi-bin/cliMAIN.pl?ca7851.
SECTION 3.4 BIOLOGICAL RESOURCES
California Department of Fish and Wildlife (CDFW). 2014. California Natural Diversity
Database (CNDDB) Rarefinder (version 5).
City of San Luis Obispo. 2006. “General Plan - Conservation and Open Space Element.”
———. 2019. “Conservation Efforts Lead to the Discovery of a New Plant Species.”
April 23, 2019. https://www.slocity.org/Home/Components/News/News/6698/17.
01834
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-4 Froom Ranch Specific Plan
Final EIR
California Native Plant Society (CNPS). 2018a. “CNPS Rare Plant Ranks | California
Native Plant Society.” California Native Plant Society. 2018.
https://www.cnps.org/rare-plants/cnps-rare-plant-ranks.
———. 2018b. “Inventory of Rare and Endangered Plants of California (Online Edition,
v8-03 0.39).” 2018. http://www.rareplants.cnps.org/.
County of San Luis Obispo Fire Department. 2018. “Historic Fire Map - California.”
http://slocountyfire.org/firehistory/.
National Marine Fisheries Service (NMFS). 2007. “2007 Federal Recovery Outline for
the Distinct Population Segment of Southern California Coast Steelhead.” 2007.
http://friendsofventurariver.org/wp-content/themes/client-
sites/venturariver/docs/fed-recovery-outline-so-cal-coast-steelhead-2007-
final.pdf.
U.S. Fish and Wildlife Service (USFWS). 2018. “Environmental Conservation Online
System - Online Mapper.” U.S. Fish and Wildlife Service - Environmental
Conservation Online System. 2018.
https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad
4fe09893cf75b8dbfb77.
SECTION 3.5 CULTURAL AND TRIBAL RESOURCES
City of San Luis Obispo. 2009. Archaeological Resource Preservation Program
Guidelines. Community Development Department. October.
Chattel, Inc. 2018. Froom Ranch, 12165 Los Osos Valley Road, San Luis Obispo,
California Linear Rock Features Historical Resource Evaluation.
Condor Country Consulting, Inc. 2018. Froom Ranch Limited Phase II Cultural
Resources Assessment, Froom Ranch Storm Water Basin, County of San Luis
Obispo, , California. Prepared for FirstCarbon Solutions and John Madonna
Construction Company. September 17.
FirstCarbon Solutions. 2015. Froom Ranch Specific Plan Cultural Resource Assessment,
San Luis Obispo, San Luis Obispo County, California. Prepared for John
Madonna Construction Company. February 20. Revised July 21, 2017.
———. 2017. Froom Ranch Specific Plan Historic Resource Assessment, San Luis
Obispo, San Luis Obispo County, California. Prepared for John Madonna
Construction Company. February 20. Revised July 21, 2017.
———. 2018. Froom Ranch Retention Basin and Land Exchange Areas Supplemental
Phase 1 Cultural Resources Report, San Luis Obispo County, California. Prepared
for John Madonna Construction Company. August 10.
01835
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-5
Final EIR
United States Department of the Interior. 1991. National Register Bulletin 15.
How to Apply the National Register Criteria for Evaluation.
U.S. Government Printing Office: Washington, D.C.
Weeks, Kay D. and Grimmer, Anne E. 1995. The Secretary of the Interior’s Standards for
the Treatment of Historic Properties with Guidelines for Preserving,
Rehabilitating, Restoring & Reconstructing Historic Buildings. U.S. Department
of the Interior National Parks Service, Technical Preservation Services.
Wiegers, M.O. and C.I. Gutierrez. 2010. Geologic Map of the San Luis Obispo 7.5’
Quadrangle, San Luis Obispo County, California: A Digital Database. California
Department of Conservation – California Geological Survey.
SECTION 3.6 GEOLOGY AND SOILS
California Department of Conservation. 2010. “Geologic Map of the San Luis Obispo
7.5’ Quadrangle.”
file:///C:/Users/taylor.lane/Downloads/SanLuisObispo24k_preliminary.pdf.
City of San Luis Obispo. 2000. “General Plan - Safety Element.”
Dibblee, Thomas W., Jr. 2004. “Geologic Map of the San Luis Obispo Quadrangle.”
Earthquake Track. 2018. “Recent Earthquakes Near San Luis Obispo, California, United
States.” 2018. https://earthquaketrack.com/us-ca-san-luis-
obispo/recent?mag_filter=5.
Federal Emergency Management Agency (FEMA). 2011. "Possible Explanations for
'Extent' for Expansive Soils. "
GeoSolutions, Inc. 2017. “Preliminary Engineering Geology Investigation - Froom/El
Villaggio Specific Plan APNs: 067-241-030 and -031 Project SL09734-1 April
14, 2017.”
Jefferson, G.T., H.L. Fierstine, J.R. Wesling, and T.L. Ku. 1992. Pleistocene Terrestrial
Vertebrates from near Point San Luis, and Other Localities in San Luis Obispo
County, California. Bulletin of the Southern California Academy of Sciences Vol
9, No. 1, pp. 26-38.
National Aeronautics and Space Administration (NASA). 2016. “San Joaquin Valley Is
Still Sinking.” 2016. https://earthobservatory.nasa.gov/IOTD/view.php?id=89761.
NRCS. 2018. “Natural Resources Conservation Service - Web Soil Survey - San Luis
Obispo County, California, Coastal Part (CA664).” 2018.
https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx.
San Luis Obispo County Department of Public Works (SLO County DPW). 2016. “San
Luis Obispo County Department of Public Works & Transportation - Interactive
01836
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-6 Froom Ranch Specific Plan
Final EIR
Data Viewer.” 2016.
http://gis.slocounty.ca.gov/Html5Viewer/Index.html?configBase=/Geocortex/Ess
entials/REST/sites/PW_SGMA/viewers/PW_Viewer/virtualdirectory/Resources/
Config/Default&LayerTheme=3.
Scott, E., and K. Springer. 2003. “CEQA and Fossil Preservation in Southern California.”
Society of Vertebrate Paleontology. 2010. “Standard Procedures For the Assessment and
Mitigation of Adverse Impacts to Paleontological Resources.” 2010.
http://vertpaleo.org/The-Society/Governance-
Documents/SVP_Impact_Mitigation_Guidelines.aspx.
University of California Museum of Paleontology (UCMP). 2018. Vertebrate
Paleontology Collections Database. Retrieved April 20 and May 1, 2018.
SECTION 3.7 HAZARDS, HAZARDOUS MATERIALS, AND WILDFIRE
Barros, Ana M.G., Jose M.C. Pereira, Max A. Moritz, and Scott L. Stephens. 2013.
“Spatial Characterization of Wildfire Orientation Patterns in California. Forests
2013, 4; Pp 197-217.” 2013.
http://nature.berkeley.edu/moritzlab/docs/Barros_etal_Forests_2013.pdf.
California Department of Forestry and Fire Protection (CALFIRE). 2007. “Draft Fire
Hazard Severity Zones in Local Responsibility Areas.”
http://frap.fire.ca.gov/webdata/maps/san_luis_obispo/fhszl06_1_map.40.pdf.
California Department of Conservation. 2016. “Office of Mine Reclamation - Mines On
Line (MOL).” 2016. https://maps.conservation.ca.gov/mol/index.html.
City of San Luis Obispo. 2014. “City of San Luis Obispo General Plan - Chapter 5
Safety.” 2014. http://www.slocity.org/home/showdocument?id=6645.
Cohen, J.D. 1999. “Reducing the Wildland Fire Threat to Homes: Where and How
Much.”
County of Los Angeles. 2011. “Final Environmental Impact Report for the Pepperdine
University Campus Life Project. Pepperdine University, Malibu, CA.” 2011.
http://planning.lacounty.gov/assets/upl/case/project_r2007-03064_feir.pdf.
County of San Luis Obispo Fire Department. 2018. “Historic Fire Map - California.”
http://slocountyfire.org/firehistory/.
Department of Toxic Substances Control (DTSC). 2018. “EnviroStor.” Department of
Toxic Substances Control EnviroStor. 2018.
https://www.envirostor.dtsc.ca.gov/public/.
Fire Resource and Assessment Program. 2017. “Fire Perimeters - CAL FIRE; USFW;
NPS; BLM.” 2017. http://slocountyfire.org/firehistory/.
01837
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-7
Final EIR
Grisanti & & Associates. 2011. “Preliminary Site Assessment - Avila Ranch Property.”
Hubbard, T.W. 1986. “Stand Age and Growth Dynamics in Chamise Chaparral. Master’s
Thesis. San Diego State University, San Diego, California.”
Johnson Aviation. 2014. “Airport Land Use Compatibility Report.”
Keeley, Jon, and Mark Borchert. 2005. “Rapid Assessment Reference Condition Model -
California Chaparral.”
Larigauderie, A., T.W. Hubbard, and H.D. Stafford. 1990. “Growth Dynamics of Two
Chaparral Shrub Species with Time After Fire. Madrono 37: p. 225-236.”
Los Angeles County Fire Department. 2012. “County of Los Angeles Fire Department
Strategic Fire Plan.” 2012.
http://cdfdata.fire.ca.gov/fire_er/fpp_planning_plans_details?plan_id=150.
San Luis Obispo County Airport Land Use Commission (SLO County ALUC). 2005.
“Airport Land Use Plan for the San Luis Obispo County Regional Airport.” San
Luis Obispo County Regional Airport - Airport Land Use Commission. 2005.
https://www.sloairport.com/wp-content/uploads/2016/10/ALUP_TXT.pdf.
State Water Resources Control Board (SWRCB). 2018. “GeoTracker.” State Water
Resources Control Board GeoTracker. 2018.
https://geotracker.waterboards.ca.gov/.
U.S. Forest Service. 2000. “Mangan, R.J. Improving Firefighter Safety in the Wildland-
Urban Intermix.”
———. 2012. “Effects of Climatic Variability and Change on Forest Ecosystems: A
Comprehensive Science Synthesis for the U.S. Forest Sector - Risk Assessment
for Wildfire in the Western United States | Publications | SRS
Https://Www.fs.fed.us/Pnw/Pubs/pnw_gtr870/pnw_gtr870_011.pdf.” 2012.
https://www.srs.fs.usda.gov/pubs/42610.
Western Regional Climate Center. 2018. “Prevailing Wind Direction.” 2018.
https://wrcc.dri.edu/Climate/comp_table_show.php?stype=wind_dir_avg.
SECTION 3.8 HYDROLOGY AND WATER QUALITY
Balance Hydrologics, Inc. 2005. Hydrologic Monitoring Plan for Sustaining a Separated
Wetland Near Calle Joaquin, San Luis Obispo, California.
Central Coast Regional Water Quality Control Board (Central Coast RWQCB). 2017.
Water Quality Control Plan for the Central Coast Basin, September 2017 Edition.
California Water Boards.
https://www.waterboards.ca.gov/centralcoast/publications_forms/publications/bas
in_plan/docs2017/2017_basin_plan_r3_complete.pdf, accessed May 29, 2018.
01838
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-8 Froom Ranch Specific Plan
Final EIR
City of San Luis Obispo. 2003. Waterway Management Plan - San Luis Obispo Creek
Watershed. http://www.slocity.org/government/department-directory/public-
works/documents-online/waterway-management-plan, accessed April 21, 2016.
Land Conservancy of San Luis Obispo County. 2002. San Luis Obispo Creek Watershed
Enhancement Plan.
http://www.coastalrcd.org/images/cms/files/SLO%20Creek%20Watershed%20En
hancement%20Plan.pdf, accessed May 29, 2018.
San Luis Obispo Watershed Project (SLO Watershed Project). 2014. San Luis Obispo
Creek Watershed. SLO Watershed Project.
http://www.slowatershedproject.org/reports/snapshots/Snapshot-South-County-
San-Luis-Obispo-Creek-Watershed.pdf, accessed May 29, 2018.
SWRCB. 2018. Geotracker.
https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress=san+lui
s+obispo, accessed June 8, 2018.
Wood. 2019. Email communication with Tyler Marley, Water Resources Engineer. April
10.
SECTION 3.9 LAND USE
City of San Luis Obispo. 1996. “General Plan - Noise Element.”
http://www.slocity.org/home/showdocument?id=6643.
———. 2006. “General Plan - Conservation and Open Space Element.”
———. 2014a. “General Plan - Circulation Element.” City of San Luis Obispo - General
Plan. 2014. http://www.slocity.org/home/showdocument?id=6637.
———. 2014b. “General Plan - Land Use Element.”
http://www.slocity.org/home/showdocument?id=6635.
———. 2014c. “General Plan - Safety.” 2014.
http://www.slocity.org/home/showdocument?id=6645.
———. 2015. “General Plan - Housing Element.” 2015.
http://www.slocity.org/home/showdocument?id=5204.
———. 2018. “General Plan - Water and Wastewater Management Element.” 2018.
https://www.slocity.org/home/showdocument?id=22356.
City of San Luis Obispo, and County of San Luis Obispo. 2013. Tank Farm EIR.
County of San Luis Obispo. 2019. “San Luis Obispo County General Plan - Land Use
Ordinance.” https://www.slocounty.ca.gov/getattachment/6d93f812-df15-4203-
b033-7d802c5c9cf0/Inland-Land-Use-Ordinance-(Title-22).aspx.
01839
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-9
Final EIR
Johnson Aviation. 2014. “Airport Land Use Compatibility Report.”
SLO County ALUC. 2005. “Airport Land Use Plan for the San Luis Obispo County
Regional Airport.” San Luis Obispo County Regional Airport - Airport Land Use
Commission. 2005. https://www.sloairport.com/wp-
content/uploads/2016/10/ALUP_TXT.pdf.
SECTION 3.10 NOISE
Caltrans. 1998. “Technical Noise Supplement.”
http://www.dot.ca.gov/hq/env/noise/pub/Technical%20Noise%20Supplement.pdf.
———. 2013. “Transportation and Construction Vibration Guidance Manual.”
http://www.dot.ca.gov/hq/env/noise/pub/TCVGM_Sep13_FINAL.pdf.
———. 2017. "2017 Traffic Volumes: Route 101." https://dot.ca.gov/programs/traffic-
operations/census/traffic-volumes/2017/route-101.
City of San Luis Obispo. 1996. “General Plan Ch4 - Noise Element.”
———. 2008. “City of San Luis Obispo Municipal Code, Title 9, Chapter 9.12.060.”
http://www.codepublishing.com/CA/SanLuisObispo/#!/SanLuisObispo09/SanLui
sObispo0912.html#9.12.060.
———. 2014. “Land Use and Circulation Elements Update EIR.”
http://www.slocity.org/home/showdocument?id=6723.
Harris Miller & Hanson Inc. 2006. “Transit Noise and Vibration Impact Assessment.”
May 2006.
http://www.fta.dot.gov/documents/FTA_Noise_and_Vibration_Manual.pdf.
Holzman, David C. 2011. “Vehicle Motion Alarms: Necessity, Noise Pollution, or
Both?” Environmental Health Perspectives 119 (1): A30–33.
Lord and Taubitz. 2017. “Acoustics Assessment for Froom Ranch Project.” 45 dB
Acoustics Consulting.
———. 2020. “Acoustic Assessment: Froom Ranch Specific Plan” 45 dB Acoustics
Consulting.
Personal communication with Manager. 2019a. “Phone Call with TJ Maxx Manager.”
———. 2019b. “Phone Call with Home Depot Manager.”
Personal communication with Receiving Department employee. 2019. “Phone Call with
Whole Foods Receiving Department Employee.”
01840
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-10 Froom Ranch Specific Plan
Final EIR
SLO County ALUC. 2005. “Airport Land Use Plan for the San Luis Obispo County
Regional Airport.” https://www.sloairport.com/airport-land-use-commission-
aluc/.
U.S. Department of Transportation. 2006. "Roadway Construction Noise Model - RCNM
Version 1.1."
———.2012. “High-Speed Ground Transportation Noise and Vibration Impact
Assessment, Final Report.”
———. 2013. “Construction Noise Handbook.”
https://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/hand
book09.cfm.
SECTION 3.11 POPULATION AND HOUSING
California Department of Finance. 2019. “E-1 Population Estimates for Cities, Counties,
and the State - January 1, 2018 and 2019.”
http://www.dof.ca.gov/Forecasting/Demographics/Estimates/e-1/.
California Employment Development Department. 2018a. “Labor Force and
Unemployment Rate for Cities and Census Designated Places.” July 2018.
https://www.labormarketinfo.edd.ca.gov/data/labor-force-and-unemployment-for-
cities-and-census-areas.html.
———. 2018b. “Unemployment Data in California.” September 2018.
https://www.labormarketinfo.edd.ca.gov/data/unemployment-and-labor-
force.html.
City of San Luis Obispo. 2014a. “General Plan Ch1 - Land Use Element.”
———. 2014b. “Land Use and Circulation Elements Update EIR.”
http://www.slocity.org/home/showdocument?id=6723.
———. 2015. “General Plan - Housing Element.” 2015.
http://www.slocity.org/home/showdocument?id=5204.
———. 2018. “General Plan Annual Report 2018.”
https://www.slocity.org/home/showdocument?id=22768.
———. 2019. “2019 Affordable Housing Standards - Effective July 1, 2019.” 2019.
https://www.slocity.org/home/showdocument?id=23428.
San Luis Obispo Chamber of Commerce. 2018. “San Luis Obispo Chamber of
Commerce, Major Employers.” September 2018. https://slochamber.org/our-
community/community-profile/major-employers/.
01841
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-11
Final EIR
SLOCOG. 2011. “San Luis Obispo County 2040 Population, Housing, and Employment
Forecast.”
http://www.slocog.org/sites/default/files/San%20Luis%20Obispo%20County%20
2040%20Population%20Housing%20Employment%20Forecast.PDF.
———. 2017. “2050 Regional Growth Forecast for San Luis Obispo County.” SLOCOG
- Regional Growth Forecasts. 2017.
https://www.dropbox.com/s/5tl8ia0j8zixrry/2050RegionalGrowthForecast_01Full
Report_RevDec2017.pdf?dl=0.
U.S. Census Bureau. 2017. “San Luis Obispo County/City 2013-2017 American
Community Survey 5-Year Estimates.”
https://www.census.gov/acs/www/data/data-tables-and-tools/data-profiles/2017/.
U.S. Department of Housing and Urban Development. 2017. “FY 2017 LMISD Local
Governments by State, Based on 2006-2010 American Community Survey.”
2017. https://www.hudexchange.info/programs/acs-low-mod-summary-data/acs-
low-mod-summary-data-local-government/.
SECTION 3.11 PUBLIC SERVICES AND RECREATION
American Association of Retired Persons (AARP). 2016. “Age-Friendly Atlanta Action
Plan 2014-2016.” 2016. https://www.aarp.org/content/dam/aarp/livable-
communities/documents-2016/Age-Friendly%20Atlanta%20Action%20Plan.pdf.
California Department of Education. 2018. “Enrollment for Charter and Non-Charter
Schools - San Luis Coastal Unified District (CA Dept of Education).” 2018.
https://dq.cde.ca.gov/dataquest/dqcensus/EnrCharterLevels.aspx?cds=4068809&a
gglevel=district&year=2017-18.
Chief Keith Aggson. 2019. Froom Ranch Specific Plan ADEIR - Fire Protection Services
Section Email.
City of Buellton. 2013. “Meritage Senior Living Project Final Subsequent Environmental
Impact Report.” 2013.
https://www.cityofbuellton.com/files/Environmental%20Documents/0629B-
Meritage%20Senior%20Living%20Project%20FEIR%20Vol%20I.pdf.
City of Los Angeles. 2003. “Draft Master Environmental Impact Report for Corbin and
Nordhoff Redevelopment Project.” 2003.
https://planning.lacity.org/eir/Corbin_Nordhoff/MEIR/index.htm.
———. 2008. “La Cienega Eldercare Facility Project Draft Environmental Impact
Report.” 2008.
https://planning.lacity.org/eir/CienegaElderCare/DEIR/DEIR%20Sections/IV.L.
%20Recreation.pdf.
01842
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-12 Froom Ranch Specific Plan
Final EIR
City of Sacramento. 2016. “Sacramento Senior Living [P15-041].” 2016.
https://www.cityofsacramento.org/-
/media/Corporate/Files/CDD/Planning/Environmental-Impact-
Reports/RevisedSacSeniorLiving_DraftISMND_050416.pdf?la=en.
City of San Luis Obispo. 2018. “Fire Department Summary.” 2018.
http://www.slocity.org/government/department-directory/fire-department.
———. 2019. “San Luis Obispo Parks + Recreation Master Plan Community Needs
Assessment.”
City of San Luis Obispo Police Department (SLOPD). 2017. “San Luis Obispo Police
Annual Report 2016.” 2017.
http://www.slocity.org/home/showdocument?id=16481.
———. 2018. “About the Department | City of San Luis Obispo, CA.” 2018.
http://www.slocity.org/government/department-directory/police-
department/about-the-department.
County of Monterey. 2018. “Monterey County, CA : River View at Las Palmas Assisted
Living Senior Facility.” 2018.
http://www.co.monterey.ca.us/government/departments-i-z/resource-
management-agency-rma-/planning/current-major-projects/river-view-at-las-
palmas-assisted-living-senior-facility.
Governing. 2016. “FBI’s Uniform Crime Report Data.” 2016.
http://www.governing.com/gov-data/safety-justice/police-officers-per-capita-
rates-employment-for-city-departments.html.
Personal Communication With SLOFD Fire Chief. 2018. “Phone Call with SLOFD Fire
Chief Garret Olson.”
Personal Communication with SLOPD Watch Officer. 2018. “Phone Call with Jeff
Booth, Sergeant with the Police Department - August 1, 2018.”
San Luis Coastal Unified School District (SLCUSD). 2015. “San Luis Coastal Unified
School District Enrollment Projections Capacity Analysis 2014/15 Update.”
———. 2018. “Developer Fees.” 2018. http://www.slcusd.org/department-
page.php?id=38.
———. 2019. “San Luis Coastal USD School Site Locator.” School Site Locator. 2019.
http://apps.schoolsitelocator.com/?districtcode=00200.
Town of Windham. 2008. “Impact Fees for Public Facilities.”
http://www.nhctap.com/documents/ctap/products/Windham/Impact%20Fee%20St
udy%20for%20Safety%20Facilities.pdf.
01843
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-13
Final EIR
U.S. Department of Health and Human Services. 2018. “Healthy Aging.” 2018.
https://www.hhs.gov/aging/healthy-aging/index.html#active.
SECTION 3.13 TRANSPORTATION AND TRAFFIC
Caltrans. 2002. “Guide for Preparation of Traffic Impact Studies.”
https://nacto.org/docs/usdg/guide_preparation_traffic_impact_studies_caltrans.pd
f.
Transportation Research Board. 2010. “Highway Capacity Manual.”
SECTION 3.14 UTILITIES AND ENERGY CONSERVATION
Bureau of Transportation Statistics. 2016. “National Transportation Statistics | Bureau of
Transportation Statistics.” 2016.
https://www.rita.dot.gov/bts/sites/rita.dot.gov.bts/files/publications/national_trans
portation_statistics/index.html#chapter_4.
California Department of Resources Recycling and Recovery (CalRecycle). 2013a.
“Commercial Sector: Estimated Solid Waste Generation Rates.” 2013.
http://www.calrecycle.ca.gov/wastechar/wastegenrates/Commercial.htm.
———. 2013b. “Residential Developments: Estimated Solid Waste Generation Rates.”
2013. http://www.calrecycle.ca.gov/wastechar/wastegenrates/Residential.htm.
———. 2013c. “Service Sector: Estimated Solid Waste Generation Rates.” 2013.
http://www.calrecycle.ca.gov/wastechar/wastegenrates/Service.htm.
———. 2018. “Solid Waste Facility Listing/Details Page - Cold Canyon Landfill, Inc.
(40-AA-0004).” 2018. http://www.calrecycle.ca.gov/SWFacilities/Directory/40-
AA-0004/Detail/.
———. 2019a. “Countywide, Regionwide, and Statewide Jurisdiction Diversion /
Disposal Progress Report.” 2019.
https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/DiversionDisposal.
———. 2019b. “SWIS Facility/Site Search.” 2019.
https://www2.calrecycle.ca.gov/swfacilities/Directory/40-AA-0004/Index.
Caltrans. 2016. “San Luis Obispo County Transportation Quick Facts.”
———. 2017. “California Transportation Quick Facts - 2017.”
http://www.dot.ca.gov/drisi/library/qf/qf2017.pdf.
California Energy Commission (CEC). 2015. “California’s Major Sources of Energy.”
2015. http://energyalmanac.ca.gov/overview/energy_sources.html.
01844
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-14 Froom Ranch Specific Plan
Final EIR
———. 2018. “California Energy Consumption Database.” California Energy
Commission. 2018. http://ecdms.energy.ca.gov/.
———. 2019a. “California Gasoline Data, Facts, and Statistics.” 2019.
https://www.energy.ca.gov/almanac/transportation_data/gasoline/.
———. 2019b. “Energy Consumption Database - Electricity Consumption (GWh) and
Natural Gas Consumption (Millions of Therms).” 2019.
http://www.ecdms.energy.ca.gov/.
———. 2019c. “Total System Electric Generation.” 2019.
https://ww2.energy.ca.gov/almanac/electricity_data/total_system_power.html.
City of San Luis Obispo. 2010. “Urban Water Management Plan (UWMP).” 2010.
http://www.slocity.org/home/showdocument?id=6369.
———. 2012. “Climate Action Plan 2012 - Resolution No. 10388 - Community
Development Department.” 2012.
http://www.slocleanair.org/images/cms/upload/files/SLO_CAP_WEb.pdf.
———. 2014a. “Background Report: Circulation.”
https://www.slocity.org/home/showdocument?id=6737.
———. 2014b. “Land Use and Circulation Elements Update EIR.”
http://www.slocity.org/home/showdocument?id=6723.
———. 2014c. “Sewer System Management Plan Update.” 2014.
http://www.slocity.org/home/showdocument?id=6347.
———. 2015b. “Final WRRF Facilities Plan.” 2015.
http://opengov.slocity.org/weblink8/1/doc/43362/Page1.aspx.
———. 2015c. “Waste Resources Recovery Facility Project Final EIR.”
http://www.slocity.org/Home/ShowDocument?id=10532.
———. 2015d. “Water Master Plan.”
https://www.slocity.org/home/showdocument?id=6439.
———. 2016a. “2015 Urban Water Management Plan.” 2016.
https://www.slocity.org/home/showdocument?id=13618.
———. 2016b. “2015 Water Resources Status Report.”
———. 2016c. “Draft 2015 Urban Water Management Plan and 2016 Amendments to
Water and Wastewater Management Element.” 2016.
http://www.slocity.org/Home/ShowDocument?id=9995.
01845
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-15
Final EIR
———. 2017a. “2017 Water Resources Status Report - For the Time Period October 1,
2016 through September 30, 2017.” 2017.
https://www.slocity.org/Home/ShowDocument?id=17651.
———. 2017b. “Avila Ranch Final EIR.” 2017.
http://www.slocity.org/government/department-directory/community-
development/documents-online/environmental-review-documents/avila-ranch-
final-eir.
———. 2017c. “Recycled Water Master Plan.”
https://www.slocity.org/home/showdocument?id=14955.
———. 2018a. “2018 Water Resources Status Report.”
https://www.slocity.org/Home/ShowDocument?id=22442.
———. 2018b. “Garbage & Recycling - Solid Waste Disposal.” 2018.
http://www.slocity.org/government/department-directory/utilities-
department/garbage-recycling/solid-waste.
———. 2018c. “General Plan - Water and Wastewater Management Element.” 2018.
https://www.slocity.org/home/showdocument?id=22356.
———. 2018d. “Water Sources.” 2018. http://www.slocity.org/government/department-
directory/utilities-department/water/water-sources.
———. 2019a. “2019 Sewer System Management Plan Update.”
https://www.slocity.org/home/showdocument?id=6347.
———. 2019b. “Draft 2016 Community Greenhouse Gas Emissions Inventory Update.”
https://www.slocity.org/home/showdocument?id=23298.
———. 2019c. “Inflow and Infiltration.” 2019.
https://form.jotformpro.com/63327044468963.
———. 2019d. “Water Resource Recovery Facility (WRRF) Project.” May 8, 2019.
https://www.slocity.org/government/department-directory/utilities-
department/wastewater/wastewater-treatment/wrrf-upgrade-project.
Monterey Bay Community Power (MBCP). 2019. “Monterey Bay Community Power
2018 Power Content Label.” https://www.mbcommunitypower.org/wp-
content/uploads/2019/09/MBCP-2018-PCL_MBchoice-and-MBprime.pdf.
Personal Communication with Jennifer Metz, City of San Luis Obispo Utilities
Department. 2019. “Email communication with Jennifer Metz, City of San Luis
Obispo.”
Pacific Gas and Electric Company (PG&E). 2018a. “PG&E 2017 Power Content.”
01846
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
7-16 Froom Ranch Specific Plan
Final EIR
———. 2018b. “PG&E Overview.” Pacific Gas and Electric Company - PG&E
Overview. 2018.
http://www.pgecorp.com/corp_responsibility/reports/2015/bu01_pge_overview.js
p.
SLOCOG. 2010. “SB 375 Regional Greenhouse Gas Emissions Reductions Target-
Setting Report for the San Luis Obispo Region.”
https://www.arb.ca.gov/cc/sb375/mpo/slocog/slocogreport52110.pdf.
Southern California Gas Company (SoCalGas). 2019. “Company Profile | SoCalGas.”
Southern California Gas Company - Company Profile. 2019.
https://www.socalgas.com/about-us/company-profile.
U.S. Census Bureau. 2019a. “QuickFacts: California.” 2019.
https://www.census.gov/quickfacts/ca.
———. 2019b. “San Luis Obispo City California QuickFacts from the US Census
Bureau.” 2019. https://www.census.gov/quickfacts/CA.
Water Systems Consulting, Inc. 2015. “Wastewater Collection System Infrastructure
Renewal Strategy.” 2015. http://www.slocity.org/home/showdocument?id=6504.
SECTION 3.15 MINERAL RESOURCES
California Department of Conservation. 1989. “Special Report 162 - Mineral Land
Classification: Portland Cement Concrete Aggregate and Active Mines of All
Other Mineral Commodities in the San Luis Obispo-Santa Barbara Production-
Consumption Region.”
———. 2017a. “2017 Mining Operation Annual Report for CA Mine ID # 91-40-0024.”
———. 2017. “Mines Online Interactive Web Map.”
https://maps.conservation.ca.gov/mol/index.html.
———. 2017b. “SMGB Designation Report No. 15 - State Mining and Geology Board
Designation of Regionally Significant Aggregate Resources in the San Luis
Obispo-Santa Barbara Production-Consumption Region.”
https://www.conservation.ca.gov/smgb/reports/Documents/Designation_Reports/
Designation-Report-15-SLO-SB.pdf.
California Geological Survey. 2011. “Update of Mineral Land Classification: Concrete
Aggregate in the San Luis Obispo-Santa Barbara Production-Consumption
Region, California.”
City of San Luis Obispo. 2006. “General Plan - Conservation and Open Space Element.”
Cody Scheel, San Luis Obispo County Planner. 2019. Phone Call with Cody Scheel, San
Luis Obispo County Planner County Planner.
01847
7.0 REFERENCES AND PERSONS OR ORGANIZATIONS CONTACTED
Froom Ranch Specific Plan 7-17
Final EIR
County of San Luis Obispo. 2010. “Conservation and Open Space Element.”
FirstCarbon Solutions, and Chattel, Inc. 2017. “Froom Ranch Specific Plan Historic
Resource Assessment. Revised.”
SECTION 4.0 OTHER CEQA ISSUES
RRM Design Group. 2019. Applicant’s Responses to Froom Ranch Specific Plan Project
Draft Environmental Impact Report Dated November 2019. Accessed on March
24, 2020.
SECTION 5.0 ALTERNATIVES
SLO County ALUC. 2005. Airport Land Use Plan for the San Luis Obispo County
Regional Airport.
——. 2014. Airport Land Use Commission Agenda Item 1 July 16, 2014.
Central Coast Transportation Consulting. 2016. Avila Ranch Draft Transportation Impact
Study.
SECTION 8.0 RESPONSE TO COMMENTS
California Department of Conservation. 1997. California Agricultural Land Evaluation
and Site Assessment (LESA) Model.
Economic & Planning Systems, Inc. 2019. Los Osos Valley Road Subarea
Transportation Impact Fee Nexus Study.
RRM Design Group. 2019. Applicant’s Responses to Froom Ranch Specific Plan Project
Draft Environmental Impact Report Dated November 2019. Accessed on March
24, 2020.
SLO County APCD. 2017. Clarification Memorandum for the San Luis Obispo County
Air Pollution Control District’s 2012 CEQA Air Quality Handbook.
https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/FINAL_Clarification%20Memorandum%2020172.p
df
USFWS. 2018. Environmental Conservation Online System - Online Mapper.” U.S. Fish
and Wildlife Service - Environmental Conservation Online System. 2018.
https://fws.maps.arcgis.com/home/webmap/viewer.html?webmap=9d8de5e265ad
4fe09893cf75b8dbfb77.
01848
01849
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.0 RESPONSE TO COMMENTS
8.1 INTRODUCTION
Comments received during the 45-day public comment period for the Draft EIR for the Froom
Ranch Specific Plan (Project), starting on November 8, 2019 and ending December 23, 2019
included written comments from 4 state agencies, 4 local agencies, 8 organizations, and 10
individuals. A total of 20 oral testimonies were received from individuals during the City Advisory
Committee and Planning Commission Hearings held on November 18, 2109, December 4, 2019,
December 10, 2019, and December 11, 2019. In accordance with the State Guidelines for the
Implementation of the California Environmental Quality Act (CEQA), this chapter provides a
written response to each of these comments and describes any revisions to the EIR made in
response to comments. These responses provide a reasoned analysis as to why no changes were
made to the EIR, or where changes to the EIR in response to comments were incorporated.
8.2 FORMAT OF THE RESPONSE TO COMMENTS
Comments received on the Draft EIR are organized by written comments, then oral testimonies.
Each comment letter or e-mail, and testimony is assigned a unique identification with each
comment individually numbered as well, in alphabetical order. Individual comments and issues
within each comment letter or e-mail are numbered individually along the margins in Section 8.3.
8.3 INDEX OF COMMENTS RECEIVED
Table 8-1 lists all agencies, organizations, and individuals that provided written and oral comments
on the Draft EIR. As described above, each comment letter was assigned a unique nomenclature
based on commenter name or organization, and each comment was assigned a number with a
corresponding letter signifying which commenter/organization the comment letter is associated
with, as detailed within the table.
8-1
01850
Table 8-1. Index of Comments Received on the Draft EIR
Comment Set/
Number of
Comments
Name of Commenter Date Received Response
Location
STATE AGENCIES
S.1 1-6 California Department of Fish and Wildlife December 23, 2019 8-15
S.2 1-11 California Department of Transportation December 20, 2019 8-28
S.3 1-3 California Wildlife Foundation December 16, 2019 8-33
S.4 1-7 Department of Toxic Substances Control December 18, 2019 8-38
LOCAL AGENCIES
L.1 1–5 Air Pollution Control District San Luis
Obispo County
December 23, 2019 8-50
L.2 1-4 County of San Luis Obispo Department of
Agriculture/ Weights & Measures
December 18, 2019 8-57
L.3 1-19 San Luis Obispo Council of Governments December 20, 2019 8-65
L.4 1-7 San Luis Obispo Local Agency Formation
Commission
December 16, 2019 8-72
ORGANIZATIONS
O.1 1-12 California Native Plant Society (1) December 11, 2019 8-85
O.2 1-14 California Native Plant Society (2) December 23, 2019 8-103
O.3 1-5 Friends of Bob Jones Trail December 22, 2019 8-114
O.4 1-4 Healthy Communities Work Group December 20, 2019 8-118
O.5 1-4 Los Verdes Park 1 December 11, 2019 8-123
O.6 1-3 Preserve the SLO Life December 10, 2019 8-127
O.7 1-8 Preserve the SLO Life and Los Verdes Park
Unit 1 Homeowners Association
December 23, 2019 8-133
O.8 1-5 Sierra Club Santa Lucia Chapter December 23, 2019 8-143
INDIVIDUALS
I.1 1-12 David Chipping December 22, 2019 8-152
I.2 1-5 Garrett Otto December 9, 2019 8-159
I.3 1-2 Jeff Whitener December 4, 2019 8-162
I.4 1-1 Judy Riener December 10, 2019 8-164
I.5 1-13 Kim Murry December 11, 2019 8-167
I.6 1-8 Lea Brooks December 24, 2019 8-176
I.7 1 Neil Havlik (1) November 18, 2019 8-176
I.8 1 Neil Havlik (2) December 2, 2019 8-181
I.9 1-5 Neil Havlik (3) December 4, 2019 8-183
APPLICANT
A.1 1-171 RRM Design Group December 23, 2019 8-236
8-2
01851
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Table 8-1. Index of Comments Received on the Draft EIR (Cont.)
Comment Set/
Number of
Comments
Name of Commenter Date Received Response
Location
ORAL TESTIMONIES
Cultural Heritage
Commission
Hearing
Commissioner Ulz
Commissioner Papp
Commissioner Matteson
Commission Haydu
Commissioner Larrabee
Commissioner Brajkovich
November 18, 2019 8-280
Parks and
Recreation
Commission
Hearing
Parks and Recreation Commission December 4, 2019 8-284
Active
Transportation
Hearing
Active Transportation Committee December 10, 2019 8-284
Planning
Commission
Hearing
Public Comments Sherry Eisenlen, David
Richards
Public Comment Gary Havas
Public Comments (Lisa Schott, Los Verdes)
Public Comment (Bill Waycott, CNPS)
Public Comment David Chipping
Public Comment Neil Havlik
Public Comment Brian Ackerman
Commissioner McKenzie
Commission McKenzie /Wulkan
Commissioner Stevenson
Commissioner Jorgensen
Commissioner Wulkan
Commissioner Kohn
Commissioner Jorgensen/Stevenson
December 11, 2019 8-287
8.4 RESPONSE TO COMMENTS
The following pages contain copies of the comment letters. Presented first is a copy of the
comment letter with vertical lines indicating the extent of specific numbered comments, and on
the subsequent pages are the corresponding numbered responses to individual comments.
8-3
01852
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.1 State Agencies
[Insert Comment Letter S.1, California Department of Fish and Wildlife, page 1 of 11]
8-4
01853
S.1-1
cont.
8-5
01854
S.1-1
cont
S.1-2
8-6
01855
S.1-2
S.1-3
8-7
01856
S.1-3
cont.
S.1-4
8-8
01857
S.1-4
cont.
8-9
01858
S.1-4
cont.
S.1-5
8-10
01859
S.1-5
cont.
S.1-6
8-11
01860
S.1-6
8-12
01861
8-13
01862
8-14
01863
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.1.1 Comment Letter S.1 – California Department of Fish and Wildlife
Comment Response S.1-1
Thank you for your comments regarding the FRSP and EIR. The EIR recognizes CDWF’s role
and jurisdiction, including but not limited to impacts occurring to California’s sensitive or
endangered species and habitats resulting from implementation of the Project. Comments
regarding recommendations as well as concerns of Project-related impacts will be included within
the public record and will be made available to the City decisionmakers for planning and policy
consideration. Detailed responses to the discrete comments made by the California Department of
Fish and Wildlife (CDFW) regarding the Project are provided below.
Comment Response S.1-2
The comment relates to potential impacts to sensitive resources, including Froom Creek, upland
grassland habitat, and the special-status species that utilize these habitats such as Chorro Creek
bog thistle, burrowing owl, western pond turtle, in and adjacent to the Project area, and the
potential for these resources to be affected by ground-disturbing activities and/or land use changes.
The comment recommends biological surveys to determine whether sensitive species may occur
onsite. The EIR provides analysis of the biological surveys for the Project site in 2015 and the
updated and verified findings through additional field surveys in 2019 to serve as a baseline of
existing site conditions of biological resources. These surveys assessed the potential for sensitive
species onsite. The EIR provides extensive and in-depth analysis and discussion of special-status
species and sensitive habitats in Section 3.4, Biological Resources. The EIR concludes that impacts
to special-status species and sensitive habitats are potentially significant and identifies a
comprehensive mitigation program to avoid and minimize adverse effects. Mitigation measure
(MM) BIO-1 requires the preparation of a Biological Mitigation and Monitoring Plan to manage
construction- and operational-related avoidance, reduction, and mitigation measures for impacts
to sensitive natural communities and the sensitive species that rely on them, including pre-
construction surveys. MM BIO-2 requires the Applicant to retain a qualified Environmental
Coordinator/Biologist, subject to review and approval of the City, to oversee compliance with the
Biological Mitigation and Monitoring Plan for the Project. MM BIO-11 addresses special-status
wildlife species management and protection during Project implementation, including avoidance
strategies, worker training, and pre-construction surveys. Prior to Project earth-moving activities,
the Project would fulfill required mitigation measures related to biological surveys. These would
include pre-construction habitat and special status species surveys to ensure avoidance, adjustment
of development envelopes in response and required habitat replacement and replanting. The EIR
8-15
01864
has also been updated to address western pond turtle and burrowing owl, both of which have
extremely low potential to occur onsite due to lack of suitable habitat.
Comment Response S.1-3
The comment expresses confusion regarding whether MM BIO-10, including the specified 50-foot
buffer, would be feasible for future Project implementation resulting in potential impacts to Chorro
Creek bog thistle, and recommends refinements to this mitigation measure. This mitigation
measure addresses the Chorro Creek bog thistle specifically as the only federally-listed special-
status species that may be affected by the Project; other special-status species are addressed by
other measures, including MM BIO-1 and MM BIO-9 through MM BIO-12, which would reduce
impacts to listed, candidate, or special-status wildlife species and partially assure compliance with
COSE Policies 7.3.1, Protect Listed Species, and 7.3.2, Species of Local Concern due to continued
loss of protected species and species of local concern which are observed onsite, including, but not
limited to: Chorro Creek bog thistle, Blochman’s dudleya, Congdon’s tarplant, San Luis mariposa
lily, and Brewer’s spineflower. The EIR analysis concludes that while required mitigation would
partially reduce impacts to special-status plants, including Chorro Creek bog thistle, Project
development is proposed in such proximity to individual special-status plants and high-quality
habitat for special-status species that complete avoidance of impacts to species may not be feasible;
therefore, Project impacts to special-status species would be significant and unavoidable after
mitigation. Specially, as described in the EIR, the Project’s proposed design has the potential to
impact the Chorro Creek bog thistle through construction and operational disturbance; such
impacts are described in the EIR under Impact BIO-2, discussing Project grading and construction
impacts both directly from new development and outside of planned building footprints, as well
as indirect impacts from site use during operation. MM BIO-10 requires construction activities
and disturbance to not take place within the mapped 50-foot setback from Chorro Creek bog thistle
and habitat areas that may support Chorro Creek bog thistle, including drainages and wetlands.
The required implementation of fencing and signage during construction activities would protect
sensitive species habitat, and, if a site survey identifies the Chorro Creek bog thistle has the
potential to be disturbed by Project construction, the Project would redesign construction to ensure
a minimum 50-foot buffer is maintained throughout to the extent feasible. Based on the
commenter’s recommendations, MM BIO-10- has been revised to clarify setback requirements
from special-status plant individuals and the edge of suitable habitat areas and require CDFW
consultation if a potential take of a special-status species would occur, including Chorro Creek
bog thistle. Construction-related impacts to the Chorro Creek bog thistle and special-status plant
species would remain significant and unavoidable because it cannot be foreseen or guaranteed that
Project redesign would be feasible to avoid a take.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
As described in Section 3.4, Biological Resources, long-term operational impacts to the Chorro
Creek bog thistle have the potential to occur due to potential human-related activities at the Project
via onsite residences in the vicinity. MM BIO-10 requires the Applicant to demonstrate to the City
that Drainages 1, 2, and 3 and associated wetlands are maintained and managed to protect the
Chorro Creek bog thistle habitat value to the extent feasible into perpetuity. However, because it
would not be feasible to control future operational impacts to the Chorro Creek bog thistle from
human activity during these habitat areas, impacts would remain significant and unavoidable.
There are no feasible mitigation measures short of major Project redesign that would ensure all
damage to this species would be avoided or reduced to a less than significant level. Please refer to
Section 3.4, Biological Resources for further discussion on this matter.
Comment Response S.1-4
The comment recommends additional evaluation of onsite impacts to burrowing owls, noting that
the Project site contains grasslands that could support burrowing owls. In response, the EIR has
been updated to include site-specific information about burrowing owls from the Project-specific
biological resources inventory, which indicates a very low potential for occurrence onsite. As
discussed in Section 3.4, Biological Resources, Project design and operation considers potential
for sensitive species to occur onsite based on a site-specific Biological Resources Inventory
provided in 2018 by Kevin Merk Associates (KMA) and JM Development Group, Inc. (which was
peer-reviewed by the City’s EIR consultant Wood as part of the EIR preparation process), as well
as pedestrian field surveys conducted by Wood EI&S to determine sensitive habitat on the site and
in the site vicinity. While the Project site includes grasslands, extensive burrowing mammal
activity was not observed under the Inventory, which is typically required by the burrowing owl
for habitat; based on the site survey, Project biologists concluded that conditions for suitable
habitat for burrowing owls are not present. The Inventory concluded the burrowing owl are not
anticipated to breed nor occur onsite; therefore, no mitigation was required. Language from the
Biological Resources Inventory on the burrowing owl has been added to Section 3.4.1.5, Special
Status Species to further the EIR’s conclusion that suitable habitat for burrowing owl does not exist
onsite, indicating that there would not be a significant impact to this species during Project
implementation.
However, in the unlikely event a burrowing owl is discovered onsite during pre-construction
surveys, MM BIO-12 has been updated to require pre-construction surveys for active nests to
include burrows and habitation by burrowing owls be completed prior to construction activities
and restricts construction activities in the vicinity of any identified active nests or burrows. In the
unlikely event that nesting burrowing owls are discovered, a 500-foot setback from all construction
8-17
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activities would be required for burrowing owls as well as raptors. Please refer to BIO MM-12 for
further discussion and specifics on mitigation requirements for potential occurrence of nesting
birds.
Comment Response S.1-5
The comment relates to ground-disturbing activities in the vicinity of Froom Creek and their
potential to impact the western pond turtle. As discussed in Section 3.4, Biological Resources, the
Project provides consideration of potential sensitive species to occur onsite based on a site-specific
Biological Resources Inventory provided in 2018 by KMA and JM Development Group, Inc.,
(which was peer reviewed by the City’s EIR consultant Wood EI&S as part of the EIR preparation
process), as well as sensitive habitat on the site and in the site vicinity. Language from the
Biological Resources Inventory on the burrowing owl has been added to Section 3.4.1.5, Special
Status Species to further the EIR’s conclusion that western pond turtle does not exist onsite,
indicating that there would not be a significant impact to this species during Project
implementation. These revisions clarify that while the Project site includes Froom Creek, no
western pond turtle was observed during site surveys conducted for the initial Biological Resources
Inventory or supplementary studies, and access to the site by western pond turtle from existing
known habitat is hindered by existing development, the U.S. 101 box culvert, and the distance of
the Project site from known suitable habitat. Further, under current conditions, the creek is an
ephemeral wash, which typically lacks pools, standing water or suitable habitat for the western
pond turtle. Thus, the EIR concluded western pond turtle are not anticipated to occur onsite nor be
impacted.
Comment Response S.1-6
The EIR recognizes CDWF’s role and jurisdiction over the Project as a responsible agency under
CEQA. The Project will comply with all relevant CDFW and USFWS regulations, including the
Federal Endangered Species Act (FESA), California Endangered Species Act (CESA), and CDFW
Lake or Streambed Alteration Program. This would include coordination with CDFW and USFWS
as needed on various mitigation measures identified in this EIR and acquisition of necessary
permits, including a Lake and Streambed Alteration Agreement (see Section 2.5, Required
Approvals). Specifically, MM BIO-11 requires that necessary permits shall be obtained from the
state (CDFW) and federal [U.S. Army Corps of Engineers (USACE) and USFWS) regulatory
agencies with jurisdiction and/or permitting authority over a portion of the Project. Pursuant to
Public Resources Code Section 21003, occurrences of any special-status species, critical habitat,
and natural communities noted during all Project surveys conducted in support of the Project, this
EIR, and subsequent mitigation shall be reported to the California Natural Diversity Database. In
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
addition, the Applicant would be required to submit payment of all appropriate CDFW filing fees
upon filing of the CEQA Notice of Determination.
8-19
01868
S.2-1
8-20
01869
S.2-1
cont.
8-21
01870
S.2-2
S.2-3
8-22
01871
S.2-3
cont.
S.2-4
S.2-5
8-23
01872
S.2-5
cont.
S.2-6
S.2-7
8-24
01873
S.2-7
cont.
S.2-8
8-25
01874
S.2-8
cont.
S.2-9
S.2-10
8-26
01875
S.2-11
8-27
01876
8.4.1.2 Comment Letter S.2 – California Department of Transportation
Comment Response S.2-1
Thank you for your comments regarding the Froom Ranch Specific Plan (FRSP) and EIR.
Comments regarding your concerns on the analysis and mitigations of the EIR and associated
Transportation Impact Study will be included within the public record and will be made available
to the City decisionmakers for planning and policy consideration. Detailed responses to the
discrete comments made by Caltrans regarding the Project are provided below.
Comment Response S.2-2
This comment expresses concern regarding inconsistency in Project trip generation estimates and
the trip generation values included in the City’s AB 1600 Impact Study Program for the LOVR
Subarea. The trip generation totals, utilized in the AB 1600 Program, often represent preliminary
trip generation estimates for future development projects that have not yet been fully vetted or
approved. These estimates do not preclude development of more detailed trip generation
calculations for use in a focused, comprehensive transportation impact study. The trip generation
values presented in the Draft EIR and traffic study prepared by TJKM for the FRSP reflect a more
detailed understanding of the final proposed land use plan for the development and are a more
accurate estimate of the anticipated traffic generation associated with the Project. As mentioned
on pg. 6 of the LOVR Subarea Transportation Impact Fee Nexus Study report (Economic &
Planning Systems, Inc., June 2019):
“Over time, it may become apparent that the development assumptions require refinement.
Business and real estate market cycles, growth management policies, and changes in land use
designations could all affect the expected/ potential level of growth and development. Consistent
with other development impact fee programs, these changes are captured in the periodic updates
to fee programs that support a re-calibration of fee program assumptions.”
The City’s AB1600 Impact Fee Programs are updated regularly to reflect changes to land use
assumptions, traffic generation, and estimated improvement project costs. Future updates to the
AB1600 Program will include revisions to the trip generation assumptions for the Project.
Comment Response S.2-3
Please see Comment Response S.2-2 above.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response S.2-4
This comment requests additional documentation of transportation analysis results with
implementation of proposed mitigation measures, including confirmation of signal timing
assumptions. The Final EIR and appended Transportation Impact Study (Appendix J) include
additional documentation showing quantitative analysis results for “with mitigation” conditions to
provide verification that the proposed mitigation strategies sufficiently reduce the Project’s
impacts to less than significant levels. Detailed Synchro traffic analysis model output worksheets
are provided in the technical appendix to the Transportation Impact Study, which identify signal
timing assumptions for each analysis scenario. Analysis worksheets and Synchro model files are
also available upon request to the City Transportation Division.
Comment Response S.2-5
As noted in Comment Response S.2-4, the Final EIR and appended Transportation Impact Study
(Appendix J) have been updated to include quantitative analysis results for “with mitigation”
conditions to verify that proposed mitigation sufficiently reduces the Project’s impacts to less than
significant levels. To further address concerns expressed by Caltrans regarding impacts to traffic
operations at the Los Osos Valley Road (LOVR) interchange, additional focused traffic analysis
has been conducted using more recent (2020) traffic count data and microsimulation tools to verify
that the final proposed mitigation measures for the LOVR interchange vicinity, which include turn
pocket extensions, signal coordination of the LOVR/Calle Joaquin intersection with the adjacent
U.S. 101 Ramps intersections, and signal timing optimizations, sufficiently mitigate the Project’s
traffic impacts. This supplemental analysis is documented in a technical memorandum, which is
provided for reference in the Final EIR Appendix M.
Comment Response S.2-6
As mentioned in Comment Response S.2-5, a supplemental traffic operations analysis has been
prepared to provide further documentation to support the efficacy of the proposed mitigation
measures at the LOVR/U.S. 101 Southbound Ramps intersection. The City has also held
subsequent meetings with Caltrans to explore other acceptable mitigation strategies in lieu of full
reconstruction of the southbound off-ramp to two lanes. The mitigation recommendations
presented in the Final EIR represent the culmination of these discussions and include the Project’s
fair-share participation in the southbound off-ramp turn pocket extension to be constructed by the
San Luis Ranch development, as well as signal coordination of the LOVR/Calle Joaquin
intersection with the adjacent Caltrans ramp traffic signals. The technical memorandum provided
in Final EIR Appendix M documents the findings of this supplemental analysis, which confirms
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the anticipated effectiveness of the proposed mitigation measures in addressing the Project’s
impacts.
Comment Response S.2-7
The City’s current Transportation Impact Study Guidelines require that traffic studies utilize
existing traffic data that is no more than two years old. Further, per CEQA Section 15125, the
environmental setting established for analysis within an EIR shall be prepared based upon existing
information available at the time of publication of the Notice of Preparation (NOP). The EIR NOP
was issued July of 2017. The Transportation Impact Study for the Project was initiated in 2017
and utilized existing traffic count data collected winter of 2016, which is consistent with City
standards and CEQA guidelines. As noted above in Comment Response S.2-5 and S.2-6, to address
Caltrans’ specific concerns regarding impacts to the LOVR/U.S. 101 ramp intersections, a
supplemental traffic operations analysis was prepared for the closely-spaced intersection along
LOVR between Calle Joaquin and the U.S. 101 northbound ramps. For the purposes of the
supplemental analysis, traffic volumes were updated using more recent traffic count data collected
in February 2020. The technical memorandum summarizing the findings of this analysis is
provided in the Final EIR Appendix M.
Further, see Comment Response S.2-4 regarding addition of analysis summary results for “with
mitigation” conditions to the Final EIR and updated Transportation Impact Study. Timing/phasing
of each mitigation measure is identified in the EIR and appended Transportation Impact Study.
The Project’s equitable share contribution for applicable mitigation measures is summarized in the
final Transportation Impact Study (Appendix J). Development of schematic depictions and
preparations of cost estimates for each mitigation measure were not required in the scope of work
for the Project Transportation Impact Study.
Comment Response S.2-8
The City recognizes Caltrans’ permit authority for projects within its right of way. As disclosed in
Section 2.5, Required Approvals, phased development of the Project will require other permits and
required approvals or participation agreements from public agencies required to implement the
Project, including Caltrans for any needed improvements within the Caltrans right of way.
Comment Response S.2-9
It is recognized that the subject property is in a Federal Emergency Management Administration
(FEMA) floodplain hazard area; however, the floodplain is in a Zone A and has not been studied
in the past, except as a tributary area to the box culverts under U.S. 101. The proposed Project does
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
not impede or alter the functionality of the existing box culverts and does not intend to upgrade
facilities at U.S. 101. The Preliminary Hydrology and Hydraulic Calculations (PHHC; Appendix
H) present a condition that is improved from the existing condition that includes a substantial
increase in flood storage immediately upstream of the double box culverts to provide peak flow
management. The November 2010 report titled “LOVR/US 101 Interchange Improvement Project
Revised Location Hydraulic Study” prepared by Wreco investigated the existing box culverts
capacity. On page 9 of the Wreco report, it is identified that the capacity of the culverts is
overtopped during the 10-year event. Flow characteristics of the box culverts are identified on page
22 of the Wreco report ranging from a 10-year event at 547 cubic feet per second (cfs) to a 100-
year event at 1066 cfs. This information was the basis of the PHCC culvert analysis. The proposed
Project improves the condition where the box culverts do not overtop until the 25-year event and
provides storage to approximately 25-acre-feet upstream of the culverts far exceeding the existing
condition.
Comment Response S.2-10
The applicant for the FEMA Conditional Letter of Map Revision (CLOMR)/Letter of Map
Revision (LOMR) is the City of San Luis Obispo; coordination with Caltrans is anticipated during
the implementation process.
Detailed hydraulic analysis will be a required component of Project permitting and development.
As noted in Comment Response S.2-9, the Wreco report prepared for the LOVR interchange work
identifies the watershed runoff to the box culverts under U.S. 101 for a 100-year storm event at
1,066 cfs. The Project intends to manage the peak flow such that the culvert performance is
enhanced. The Project stormwater management program will comply with the City of San Luis
Obispo Waterways Management Program and state standards for stormwater management. The
City will coordinate with Caltrans and provide improvement plans and supporting documentation.
Comment Response S.2-11
The City will continue to include Caltrans in the public noticing and recognizes Caltrans statutory
right to request formal scoping meetings.
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01880
S.3-1
S.3-2
S.3-3
8-32
01881
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.1.3 Comment Letter S.3 – California Wildlife Foundation
Comment Response S.3-1
Thank you for your comments regarding the FRSP and EIR. As identified by the commenter, the
EIR thoroughly evaluates the Project’s impacts on oak woodlands and ecosystems, which are
important to the San Luis Obispo area for their roles in sequestering carbon, maintaining healthy
watersheds, providing habitat, supporting the movement of wildlife, and sustaining cultural values.
These comments supporting the EIR findings and mitigation measures or regarding preference for
any of the Project alternatives will be included in the public record and provided to planning and
policy decision makers for consideration.
Comment Response S.3-2
The comment expresses support for a mitigation measure which requires a development buffer to
avoid impacts to wildlife movements, streams, and surrounding oak woodlands. This
recommendation is incorporated in the EIR as MM BIO-13, which requires that the Applicant to
amend the FRSP to establish a 300-foot-wide buffer centered along the confluence of Drainage 1,
2, and 3 and the realigned Froom Creek (effectively resulting a 150-foot development buffer on
both sides of the drainages/confluence). Further, as described in Section 3.4, Biological Resources,
the Project provides protection via MM BIO-12 for special-status wildlife movement in the
required Biological Mitigation and Monitoring Plan. The buffer distance provided to streams and
special-status species habitat is consistent with applicable City General Plan policies, as well as
state regulatory agencies (e.g., CDFW). Additionally, MM BIO-9 requires construction and
grading of the realigned portion of Froom Creek to occur prior to removal of the existing creek
segment to protect special-status species habitat without interruption. For further discussion of
hydrologic stream protection measures, please refer to Section 3.8, Hydrology and Water Quality.
Comment Response S.3-3
The comment states development in proximity to oak woodlands leads to manipulations of the
woodland causing detrimental impacts. The comment recommends the Project remove proposed
development in the vicinity of the oak woodland habitat at the Project site through inclusion of
MM BIO-13. As described in the EIR, MM BIO-13 would require a 300-foot-wide buffer centered
along the confluence of Drainages 1, 2, 3 and Froom Creek to maintain a wildlife corridor through
this portion of the Project site. The measure requires the Applicant to amend the FRSP to
incorporate this buffer, which would require relocation of the portion of the proposed development
located closest to the oak woodlands. The relocation of residential land uses to avoid this
confluence would also ensure adequate distance between the proposed buildings and oak
8-33
01882
woodlands to avoid the need for wildfire fuel management within the woodland. City General Plan
COSE Policy 7.5.1 requires protection of existing oak woodland, which is present on the southern
and western portions of the Project site. The Project would not disturb any mature oak trees
consistent with City policy. Further, MM BIO-15 requires the Applicant to utilize a City-approved
arborist or qualified biologist to conduct daily, pre-construction surveys of all activities occurring
in protected root zones of protected trees, including oak woodland. The qualified specialist shall
provide recommendations for avoidance measures and any necessary remedial actions to protect
trees. If the Project results in compromised health of any native tree, including oaks, the Applicant
shall provide a native tree replacement planting program to mitigate impacts to biological
resources, including oak woodland. Inclusion of MM BIO-15 reduces impacts to less than
significant with mitigation.
8-34
01883
S.4-1
S.4-2
S.4-3
8-35
01884
S.4-3
cont.
S.4-4
S.4-5
S.4-6
8-36
01885
8-37
01886
8.4.1.4 Comment Letter S.4 – Department of Toxic Substances Control
Comment Response S.4-1
Thank you for your comments regarding the FRSP and EIR and recommendations for inclusion of
additional discussion regarding impacts to or from hazards and hazardous materials. Detailed
response to each of the DTSC’s recommendations are provided in the following responses.
Comment Response S.4-2
The comment states the EIR should acknowledge the potential for the Project to result in the release
of hazardous waste/substances. As described in the EIR, the Project site is largely
undeveloped/agricultural; development is limited to a cluster of historic ranch buildings and a
construction materials storage yard on the north side of the site. This setting indicates a very low
potential for onsite contamination within buildings and soils. However, the EIR conservatively
assumes that construction-related activities may result in encountering of asbestos-containing
material, lead-based paint, or other hazardous materials encountered within limited developed
portions of the Project. These materials would be disposed of in compliance with all pertinent
regulations for the handling of such waste as noted by the commenter, including SLO County
APCD National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements and
CCR Title 8, Industrial Relations. Therefore, construction activities, with compliance with
applicable policies, would not result in a significant risk of hazardous materials exposures to the
site environment. Further, EIR Section 3.4, Biological Resources, includes a mitigation measure
(MM BIO-1 [f]) that requires that in the event of a spill during construction, “materials and/or
contaminants shall be cleaned immediately and recycled or disposed of to the satisfaction of the
Regional Water Quality Control Board (RWQCB)”. This measure has been clarified to also
include unanticipated discovery of hazardous materials, and notes additional agency oversight
including San Luis Obispo County Public Health Environmental Services and the Department of
Toxic Substances Control.
As discussed in the EIR in Section 3.7, Hazards, Hazardous Materials, and Wildfires, the Project
involves residential and commercial uses that would not generate nor use hazardous materials,
with the exception of those routinely used at commercial and residential sites and senior care
facilities. Typical hazardous materials used and stored at the site would include, but not be limited
to, commercial cleaning products, medical supplies, limited mechanical fuels, commercial
pesticides, and waste. Potentially hazardous materials usage and storage would be limited within
the Project site and are consistent with those found in similar urban settings. The Project’s use and
storage of hazardous materials would not pose a significant risk to the public or environment. Any
8-38
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
business that handles or uses hazardous materials above regulatory levels would be required to
comply with federal, state, and local regulations and standards established by the U.S. EPA,
CalEPA, DTSC, the County, and the City to protect the public health and safety. Businesses are
required to comply with health and safety and environmental protection laws and regulations,
including the City’s Municipal Code. If the Project requires transportation of hazardous materials
offsite, the Project would comply with the U.S. Department of Transportation Office of Hazardous
Materials Safety regulations in relation to transportation of hazardous materials.
In addition, the Project site’s existing conditions do not indicate a substantial safety risk from
previous or current hazardous waste disposal. No known Above-ground storage tanks (AST) or
underground storage tanks (UST) are present at the Project site and the site consists of largely
undeveloped acreage historically used for grazing and dairy operations, which have a low risk of
contamination. For further detailed discussion of these issues as they relate to the proposed Project,
please refer to Section 3.7, Hazards, Hazardous Materials, and Wildfire.
Comment Response S.4-3
The comment states that surveys should be conducted for lead-based paints or products, mercury,
asbestos containing materials, and polychlorinated biphenyl caulk for buildings and structures that
would be demolished. As discussed in Section 3.7, Hazards, Hazardous Materials, and Wildfire,
the Project site is largely undeveloped/agricultural; development is limited to a cluster of historic
ranch buildings formerly used for dairy production and a construction materials storage yard on
the north side of the site. This setting indicates a very low potential for onsite contamination within
buildings and soils. Under the Project, several of these structures would be demolished, while other
more historically significant structures would undergo rehabilitation and relocation for eventual
reuse and preservation. Due to the age of the existing structures onsite, the EIR acknowledges the
potential for hazardous materials (e.g., asbestos-containing materials and lead-based paint) to be
present and encountered or released during the demolition, relocation, or rehabilitation of these
structures. As such, all demolition and construction activities would be required to comply with
all pertinent existing regulations for the handling of hazardous building materials, including SLO
County APCD NESHAP requirements and CCR Title 8, Industrial Relations. Compliance with
these existing regulations would address potential for release of these hazardous materials and
sampling is not required in support of the EIR findings. Please refer to Comment Response S.4-2,
above, and EIR Section 3.7, Hazards, Hazardous Materials, and Wildfires for further discussion
and analysis supporting the determination of less than significant impact from removal,
demolition, and disposal of the above-discussed materials.
8-39
01888
Comment Response S.4-4
The comment requests the EIR include discussion of investigation of mining activities conducted
at the Project site for potential mine waste and associated hazardous materials. As discussed in
Section 3.15, Mineral Resources, the Project site includes a 5.5-acre red rock quarry permitted
under SMARA and has an associated reclamation plan and performance bond in place with the
County of San Luis Obispo. As discussed in the EIR, the Project would reclaim the existing quarry
site consistent with the SMARA permit reclamation plan and in compliance with the California
Department of Conservation Mine Reclamation Statutes and Regulations. Section 3712 of the
State’s Mine Reclamation Statutes and Regulations require that all mine waste be handled and
disposed of consistent with the State Water Resources Control Board mine waste disposal
regulations in Article 1, Subchapter 1, Chapter 7 of Title 27 of the California Code of Regulations.
Compliance with the existing SMARA permit for the red rock quarry, and by extension the
SWRCB regulations governing disposal of mine waste, would ensure the existing red quarry is
closed and maintained in a manner such that there would be no significant increase in the
concentration of waste constituents in the ground or surface water prior to construction of the
Project. Therefore, implementation of the Project would not result in the release or exposure of
humans or the environment to hazardous mine wastes. Nevertheless, additional discussion has
been added to the EIR in Section 3.7, Hazards, Hazardous Materials, and Wildfires regarding the
applicability of these existing regulations and the less than significant effects of the Project relating
to mine wastes.
Comment Response S.4-5
The comment requests all imported fill material utilized for Project construction be sampled to
ensure the imported material is free of contamination. There are currently no existing federal, state,
or local regulations that require sampling of imported construction fill material prior to use at a
development site to ensure the fill material is free of contamination. However, like much of the
construction occurring within the City and County, imported fill material would be sourced from
appropriate construction sources and Project construction would not recycle soils that may contain
contaminants. Further, developers are encouraged to follow guidance provided by DTSC in the
2001 Information Advisory Clean Imported Fill Material to sample imported fill material prior to
use at a construction site. Additional discussion regarding standard construction practices for use
of non-contaminated soils and DTSC guidance regarding the sampling of imported fill material
has been added to Section 3.6, Geology and Soils.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response S.4-6
The comment requests further investigation of organochlorinated pesticide use at the Project site,
if prior agricultural activities have occurred. Per DTSC guidance, agricultural lands that may have
pesticide contamination are those under cultivation with row, fiber or food crops, orchards, or
pastures where agricultural chemicals were applied uniformly consistent with normal application
practices. As discussed in the EIR, farmland within the Project site has historically been utilized
for dairy operations and is currently used for grazing activities. As described in Section 3.2,
Agricultural Resources, the Project site has never been cultivated with crops and, therefore, the
potential for past pesticide or herbicide applications is negligible. No weed abatement using
pesticides or herbicides currently occurs at the site. Further, DTSC guidance provides that
residences, barns, animal facilities, ditches, and other areas that may have been treated differently
from an agricultural field are not considered agricultural lands that may have pesticide impacts.
Aside from the grazing land onsite, which has not been formerly cultivated, other uses onsite are
former dairy buildings, including barns and a residence, and a construction materials storage yard,
which do not have potential for pesticide release per DTSC. Lastly, DTSC guidance notes that
disturbed urban land does not have potential for substantial exposure to pesticides because
disturbance redistributes potential contaminants on the surface into the soils. The Project site has
been subject to grading over much of the non-wetland areas and non-waterways onsite, resulting
in substantial disturbance to top soils and eliminating the potential for pesticides on the surface.
Therefore, no further investigation into pesticide use and potential contamination is required. This
information has been added to Section 3.7, Hazards, Hazardous Materials, and Wildfires.
8-41
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.2 Local Agencies
[Insert Comment Letter L.1, Air Pollution Control District San Luis Obispo County, page 1 of 8]
8-42
01891
Environmental Impact Report for Froom Ranch Specific Plan Project
December 23, 2019
Page 2 of 8
widening of Los Osos Valley Road, a new transit stop, signalization of the Los Osos Valley Road and
Auto Park Way intersection. It is estimated that the Project would require approximately 160,000
cubic yards of cut, 378,000 cubic yards of fill, and 2,300 cubic yards of rock/aggregate import.
The following comments are formatted into 2 sections – (1) General Comments and (2) Air
Quality and Greenhouse Gas Emission Impacts. Comments pertain to information stated in
Section 3.3 Air Quality and Greenhouse Gas Emissions of the Draft Environmental Impact Report
(DEIR). The lead agency may contact the APCD Planning Division for questions and comments
related to the sections outlined below at 805-781-5912.
(1)General Comments
APCD Discretionary Authority
Throughout the “Plan Requirements and Timing” and “Monitoring” sections in the DEIR, it is stated
that the APCD will review and approve specific elements of the project. The APCD would like to
clarify our discretionary authority and state that the APCD has the authority to approve:
x APCD Authority to Construct & Permit to Operate (slocleanair.org/library/download-
forms.php)
o Permit categories that may require an APCD permit include dry cleaning, stationary
engines, standby or backup generators, winery, cannabis etc.
o Permits for hazardous material clean-up associated with site preparation, such as
hydrocarbon contaminated soil.
x Asbestos Regulatory Requirements (slocleanair.org/rules-regulations/asbestos.php)
o Demolition/renovation activities need to comply with the National Emission
Standards for Hazardous Air Pollutants (NESHAP) requirement (40 CFR 61 Subpart
M).
o Grading or other groundbreaking activities need to comply with naturally occurring
asbestos (NOA) requirements (CCR Title 17 93105 and 93106).
The APCD plans to consult with the lead agency to discuss the Construction Activity Management
Plan (CAMP; MM AQ-1) and off-site mitigation (MM AQ-3) to determine if APCD standards are met.
The lead agency is the final approval body for all elements that the APCD does not have
discretionary authority over.
Development Outside Urban Reserve Lines
To be consistent with the APCD’s Clean Air Plan Land Use Management Strategy 1 – Planning
Compact Communities, urban growth should occur within the Urban Reserve Lines of cities. The APCD
recommends that areas outside the urban reserve lines (URL) be retained as open space,
agriculture, and very low-density residential development. The proposed project is adjacent to the
URL for the city of San Luis Obispo (City). If approved, the project would annex the land into the
City’s URL. The APCD does not support annexations and development outside URLs as development
outside urban core centers leads to an increase in air quality impacts due to potential longer
commuting distances and increase of motor vehicle use.
L.1-1
cont.
L.1-2
L.1-3
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December 23, 2019
Page 3 of 8
However, if approved, this project has the potential to free up residential homes in the City as aging
seniors move to the development’s senior units. By increasing the available housing stock, those
working in the City may have a greater opportunity to live in the City. This may decrease commute
distances thus reducing emissions. However, the potential for emission reductions would only be
achieved if existing residents of the City are granted access to the senior units first. Similar to the
strategy developed for the San Luis Ranch development, the APCD would support a strategy to
ensure residents who are already living in the City are given the first opportunity to live in the senior
units.
(2)Section 3.3 Air Quality and Greenhouse Gas Emission Impacts
Impact AQ-1 The Project would result in potentially significant construction-related
emissions, including dust and air pollutant emissions (Less than Significant with Mitigation)
(pg. 3.3-27).
Construction Phase Impacts - Exceeds Threshold(s)
On page 3.3-28 & 29 of the DEIR, it states construction phase emission estimates were calculated
using the most recent CalEEMod computer model and that they would exceed the following APCD
construction emission threshold(s) identified in Table 2-1 of the CEQA Air Quality Handbook (April
2012):
x Daily ROG + NOx
x Annual Tier 1 ROG + NOx
x Annual Tier 2 ROG + NOx
To mitigate these significant impacts, the DEIR states three mitigation measures on pages 3.3 - 29
through 34. These measures include the APCD’s language for a Construction Activity Management
Plan (MM AQ-1) that includes but is not limited to (1) Fugitive Dust: Long List, (2) Best Available
Control Technology, (3) Standard Construction Mitigation Measures for Construction Equipment.
Additionally, (MM AQ-2) includes language to reduce ROG + NOx levels during the architectural
coating phase and (MM AQ-3) states an offsite mitigation strategy shall be developed. These
measures are consistent with the APCD’s analysis of the proposed project and the APCD supports
the inclusion of these measures in the conditions of approval for the construction phase.
Impact AQ-2 The Project would result in potentially significant long-term operational
emissions (Significant and Unavoidable) (pg. 3.3-35).
Operational Phase Impacts - Exceeds Threshold
On page 3.3-35 & 36 of the DEIR, it states construction phase emission estimates were calculated
using the most recent CalEEMod computer model and that they would exceed the following APCD
construction emission threshold(s) identified in Table 2-1 of the CEQA Air Quality Handbook (April
2012):
x Daily ROG + NOx
To mitigate these significant impacts, the DEIR states one mitigation (MM AQ-4) on page 3.3 – 36
through 45. This mitigation states all feasible measures from Table 3-5 in the APCD’s CEQA Air
Quality Handbook. Table 3.3-9 in the DEIR states many of measures from Table 3-5 would be
L.1-3
cont.
L.1-5
L.1-4
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Page 4 of 8
implemented into the project by amending the Draft FRSP. The measures broadly discuss how the
FRSP would be amended. Many of the stated measures from Table 3-5 are derived from the APCD’s
Clean Air Plan Land Use Strategies and Transportation Control Measures discussed in Impact AQ-5.
When amending the Draft FRSP, the applicant should pay particular attention to the “Changes
Needed” column in the APCD’s recommendations table found below in “Impact AQ-5”.
Impact AQ-3 Release of toxic diesel emissions or naturally occurring asbestos during
construction of the Project could expose sensitive receptors to emissions-related health risks
(3.3-46).
Impact AQ-3 in the DEIR describes the effects of toxic diesel emissions and naturally occurring
asbestos. The APCD would also like to remind the project proponents of the following which could
also expose sensitive receptors to emissions-related to health risks.
Proper Abatement of Asbestos-Containing Material (ACM)
Demolition activities can have potential negative air quality impacts, including issues surrounding
proper handling, abatement, and disposal of ACM. ACM could be encountered during the demolition
or remodeling of existing structures. If this project will include any of these activities, then it may be
subject to various regulatory jurisdictions, including the requirements stipulated in the National
Emission Standard for Hazardous Air Pollutants (40CFR61, Subpart M - asbestos NESHAP). Visit
slocleanair.org/rules-regulations/asbestos.php for further information.
NESHAP requirements include but are not limited to:
1) Written notification to the APCD, within at least 10 business days of activities commencing.
2) Asbestos survey report conducted by a Certified Asbestos Consultant.
3) Written work plan addressing asbestos handling procedures in order to prevent visible
emissions.
Proper Abatement of Lead-Based Coated Structures
Demolition, remodeling, sandblasting, or removal with a heat gun can result in the release of lead-
containing particles from the site. Proper abatement of lead-based paint must be performed to
prevent the release of lead particles from the site. An APCD permit is required for sandblasting
operations. For additional information regarding lead abatement, contact the San Luis Obispo
County Environmental Health Department at 805-781-5544 or Cal-OSHA at 818-901-5403. Additional
information can also be found online at epa.gov/lead.
Impact AQ-4 The Project would be consistent with the City’s Climate Action Plan but would
result in potentially significant GHG emissions during construction and operation (Less than
Significant with Mitigation) (pg. 3.3-49).
The APCD acknowledges the stated strategy on page 3.3-52 of the DEIR for addressing SB 32
consistency. The APCD is working to develop GHG impact and mitigation guidance for local projects
and plans to demonstrate consistency with state emission reduction targets. Until this guidance is
complete, please note that in the Newhall Ranch case, the Supreme Court identified that compliance
with a local qualified Climate Action Plan (CAP) is a potentially acceptable method for meeting CEQA
requirements. Guidance from the Sacramento Metropolitan Air Quality Management District states:
L.1-5
cont.
L.1-6
L.1-7
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If a jurisdiction does not have a qualified CAP, development projects may have to mitigate
GHG emissions from their projects to no-net increase level, which has already been done for
larger development projects1 and is the most defensible alternative to compliance with a
qualified CAP2.
As stated, the APCD supports MM AQ-5 which states the FRSP will be revised to include measures
necessary to reduce Project operational stationary-source GHG emissions to achieve net zero
emissions, consistent with the City’s 2035 net-zero GHG emissions target.
Impact AQ-5 The Project is potentially inconsistent with the SLO County APCD’s 2001 Clean Air
Plan (Significant and Unavoidable) (pg. 3.3-55).
Page 3.3-58 of the DEIR did not clearly state which Clean Air Plan (CAP) Transportation Control
Measures (TCMs) and Land Use Strategies are or are not consistent with the project. The APCD
analyzed the project and found that the following measures and strategies are not properly
implemented into the project and that MM TRANS 5, 8, 9 & 10 are not enough to mitigate the
inconsistency. The following table outlines what the project would need to do so all applicable land
use strategies and TCMs are included in the plan.
CAP TCM or Land
Use Strategy
APCD Analysis of TCMs or Land Use
Strategies
Changes Needed
T-2A Local Transit
System
Improvements
The focus of this measure is on
improving local transit service and
infrastructure to increase ridership by
enhancing the convenience and
overall viability of the system. While
Policy 5.6.1 of the FRSP requires
provision and/or enhancement of
existing City bus Routes, the APCD
would support an amendment to
include an actional objective to
ensure construction of the bus stop.
In collaboration with the City and
SLOCOG, the APCD recommends that
the project include a new bus stop
along LOVR directly in front of
Madonna Froom Ranch. The bus stop
should be designed as a pull-out bus
stop. Pedestrian access should be
included from the Madonna Froom
Ranch residential areas to the bus
stop. This bus stop should be
implemented during the first phase
development.
T-3 Bicycling and
Bikeway
enhancements
Although MM TRANS 5, 8, 9 & 10 will
improve the surrounding bikeways,
the project’s site design is not
conducive to bicycle riding and the
project does not have adequate
external connectivity.
To be consistent with this TCM and
support SLOCOG’s Sustainable
Communities Strategy, the
emergency access roadways and
points should be amended as
secondary access roadways and
there should be pubic access to Calle
Joaquin.
1 Newhall Ranch Resource Management and Development Plan and Spineflower Conservation Plan: Final Additional
Environmental Analysis. California Department of Fish and Wildlife SCH No. 2000011025, 12 June 2017.
2 “Final White Paper Beyond 2020 And Newhall: A Field Guide To New CEQA Greenhouse Gas Thresholds And Climate Action
Plan Targets For California.” Association of Environmental Professionals, 18 October 2016, https://califaep.org/docs/AEP-
2016_Final_White_Paper.pdf.
L.1-7
cont.
L.1-8
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T-6 Traffic Flow
Improvements
The goal of this measure is to
improve the road system and
infrastructure in a way that increases
its efficiency and reduces emissions.
MM Trans-1 states some strategies to
alleviate traffic impacts but this may
not be sufficient to avoid traffic
congestion. Additionally, in
collaboration with Caltrans, the APCD
has concerns regarding the analysis
and mitigations put forth in the
Traffic Study prepared for the FRSP.
Specific areas of concern include the
Trip Generation rates depicted in
Table 3.1-43, the analysis of the AB
1600 Impact Fee Program, and the
use of outdated baseline traffic
volumes.
To ensure traffic impacts are properly
analyzed, the APCD recommends the
applicant work with Caltrans and
revise the Traffic Study to proper
analyze impacts and identify
appropriate mitigation. In addition to
MM Trans-1, the APCD recommends
working with SLO Regional Rideshare
to develop a TDM Plan for the
project. This plan would:
x Recommend strategies to
reduce traffic impacts
generated by construction
activities.
x Recommend strategies to
reduce single-occupancy
vehicle trips made by new
residents and employees.
x Establish a measured
baseline of vehicle trips from
which reductions shall be
determined at the time of
the future trip generation
analyses.
x Identify a point of contact to
coordinate plan
implementation.
L-1 Planning
Compact
Communities
Policies stated in L-1 indicate the
project should:
1.Be developed at higher
densities,
2.Urban growth should occur
within urban reserve lines,
and
3.Neighborhoods should be
planned to allow for
convenient access for local
and regional transit systems.
While the project proposes higher
density land uses, the “Upper
Terrace” development is
disconnected from the core of the
development along with the upper
portion of Madonna Froom Ranch.
Also, the APCD does not support
annexations but rather supports
The APCD supports the Alternative 1 -
Clustered Development Below the
150-Foot Elevation, which is an
actionable alternative. This alternative
would cluster the “Upper Terrace”
and upper portion of the Madonna
Froom Ranch into the core of the
development. Additionally, the
planned emergency access roads and
points should be amended as
secondary access roadways to allow
greater convenience and access to
local and regional transit systems.
L.1-8
cont.
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Page 7 of 8
densifying inside existing urban
reserve lines.
L-2 Providing for
Mixed Land Use
Policies stated in L-2 indicate the
project should:
1.Mix compatible commercial
and residential land uses to
reduce dependence on the
automobile
The project includes a small
commercial/retail area in which
70,000 square feet would be
designated as a hotel with restaurant
and 30,000 square feet for retail and
office space. The majority of the
commercial use would be a hotel,
which would not reduce automobile
trips of residents living in the
development.
The proponents of the project should
consider essential services needed
for the future residents. By doing
this, automobile trips from the
development would be reduced
because residents would be able to
walk to essential services. Essential
services may include an affordable
childcare facility which would support
mitigation measure 23 in Table 3.3-9
in the DEIR.
L-4 Circulation
Management
Policies stated in L-4 indicate the
project should:
1.Encourage walking by
including safe and
interconnected street system
2.Develop pedestrian- and
bicycle-friendly design
standards
The project does not have an
interconnected street system. The
design includes multiple dead-end
streets. Because of this, and that the
“Upper Terrace” is unnecessarily far
from the only entrance/exit, the
design is not friendly to pedestrians
or bicycle riders. Additionally, the
project is adjacent to the Irish Hill
Shopping Center but there is no
proposed connection to the Center.
The street system within the project
should be interconnected and there
should not be dead-end streets.
Additionally, the project should be
connected with the surrounding
street system, which includes
amending the planned emergency
access roads and points as secondary
access roadways. Additionally, there
should be pubic access to Calle
Joaquin. Finally, the removable
bollards should be replaced with
connectivity to the Irish Hills
Shopping Center.
L.1-8
cont.
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Again, thank you for the opportunity to comment on this proposal.
Sincerely,
JACQUELINE MANSOOR
Air Quality Specialist
JNM/jjh
cc: John Madonna, Owner
Dan Gira, Agent
Tim Fuhs, APCD
Carrisa Reynolds, APCD
incerely,
ACQUELINE MANSOO
Ai Q lit S i li t
8-49
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8.4.2.2 Comment Letter L.1 – Air Pollution Control District San Luis Obispo County
Comment Response L.1-1
Thank you for your comments regarding the air quality and greenhouse gas emissions analysis for
the proposed FRSP. San Luis Obispo County APCD’s description and understanding of the Project
are accurate, and detailed responses to comments pertaining to the air quality and greenhouse gas
analysis presented in the EIR are provided in the following responses.
Comment Response L.1-2
The comment clarifies SLO County APCD’s discretionary authority over the Project. Section 3.3,
Air Quality and Greenhouse Gas Emissions of the EIR identifies various mitigation strategies
developed in compliance with or based upon SLO County APCD’s recommended mitigation
measures identified in the 2012 APCD CEQA Air Quality Handbook and the 2017 Clarification
Memorandum. Due to these mitigation measures originating from SLO County APCD and the
quantity and type of emissions to be generated by the Project, as well as the other complex
mitigation strategies identified in the EIR, the City has included language in these mitigation
measures to allow close coordination with SLO County APCD to ensure the effectiveness of
proposed mitigation. The City does not intend for implementation of these measures to be
dependent upon approval by SLO County APCD, but rather that the mitigation strategies,
monitoring of mitigation implementation, and emissions reduction calculations may be vetted or
coordinated with SLO County APCD. MM AQ-1 and MM AQ-3 have been clarified to note final
approval by the City.
Comment Response L.1-3
The comment notes SLO County APCD’s opinion of development occurring outside of the City’s
URL and that such development has tendency to increase air quality impacts due to longer
commuting distances and increases in motor use. However, SLO County APCD believes the
Project has potential to reduce these impacts by providing additional housing inside the City,
compared to vehicle use and air emissions generated by commuters who work within the City, but
must live outside the City’s URL due to low available housing stock. SLO APCD notes that this
is true if existing City residents are granted access to the senior units first, thereby freeing up other
housing units within the City. While this opinion does not result in changes to the EIR analysis of
air quality and GHG impacts, SLO County APCD’s comments on this topic have been noted and
will be considered by the Applicant and City decision makers.
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8.0 RESPONSE TO COMMENTS
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Final EIR
Comment Response L.1-4
The comment notes the Project would result in less than significant construction-related emissions
with the inclusion of MM AQ-1 through MM AQ-3, which would reduce construction-related air
pollutant emissions to a less than significant level and is consistent with SLO County APCD’s
analysis. The EIR’s analysis of construction-related emissions aligns with SLO County APCDs
understanding of the potential impacts and proposed mitigations. SLO County APCD’s comments
supporting the EIR’s air quality mitigation measures relating to construction will be included
within the public record and will be made available to the City decisionmakers for planning and
policy considerations.
Comment Response L.1-5
The comment directs attention to recommended changes to Section 3.3, Air Quality and
Greenhouse Gas Emissions, Impact AQ-5 discussion. Based on SLO County APCD’s
recommendations, provided changes under Comment L.1-8 of this letter have been incorporated
into the EIR to ensure sufficient Transportation Control Measures and Land Use Strategies by the
Project. Please see Comment Response L.1-8 for specifics on incorporated changes.
Comment Response L.1-6
The comment states the Project is subject to the Federal Asbestos NESHAP regulations, as well
as an APCD permit if sandblasting operations are proposed. No sandblasting would be required
under the Project; please refer to Section 2.0, Project Description for construction specifics. SLO
County APCD is a delegated authority by the U.S. EPA to implement Federal Asbestos NESHAP
regulations in 40 CFR 61, Subpart M. The Project would comply with all applicable requirements
and procedures delineated in this regulation and CCR Title 8, Industrial Relations that pertain to
Project-related activities and disposal of hazardous materials, as described in Section 3.7, Hazards,
Hazardous Materials, and Wildfire.
As discussed in Section 3.7, Hazardous, Hazardous Materials, and Wildfire, the Project has a low
likelihood of exposing asbestos or lead-based paint due to historical site use, which includes
largely undeveloped land onsite and minimal building demolition. However, the Project would
comply with all applicable federal and state regulations for any required disposal or handling of
such waste to prevent contamination, including to air quality via SLO County APCD NESHAP
requirements and CCR Title 8, Industrial Relations. This information has been added to Section
3.3, Air Quality and Greenhouse Gas Emissions and please see also, Comment Response S.4-3.
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01900
Comment Response L.1-7
The comment acknowledges SLO County APCD’s support of the EIR’s analysis of consistency
with SB 32 GHG emission reduction targets and inclusion of MM AQ-5. Support of the EIR’s
GHG analysis will be included within the public record and will be made available to the City
decisionmakers for planning and policy considerations.
Comment Response L.1-8
The comment states that: 1) the EIR did not clearly distinguish the Climate Action Plan
Transportation Control Measures (TCMs) and Land Use Strategies that are consistent and those
that are not consistent with the Project, and 2) MM TRANS-5, and MM TRANS-8 through -10 are
not sufficient to mitigate Project-related impacts. Regarding TCM T-2A, the Project proposes a
new bus stop along southbound LOVR just south of the Project’s primary access. Construction of
this transit improvement would occur during construction of the proposed LOVR improvements
in Phase I of the proposed construction schedule and operational well in advance of occupancy of
the first units of the proposed Project (see Section 2.6, Project Construction). The new bus stop
would be within a walkable distance to residents of Madonna Froom Ranch and Villaggio and
would be accessible by pedestrians via the proposed internal pedestrian circulation system, which
would include construction of separated sidewalks and Class II and Class III bike lanes along
roadways from residences of Madonna Froom Ranch to LOVR. Provision of a new bus stop
fronting the Project site that would be accessible to residents of Madonna Froom Ranch and
Villaggio via the proposed internal circulation system would ensure the Project is consistent with
TCM T-2A. Additional information on this matter has been added to the discussion of the Project’s
consistency with applicable TCM measures under Impact AQ-5 in Section 3.3, Air Quality and
Greenhouse Gas Emissions.
With regard to TCM T-3, the comment recommends that proposed emergency access roadways
and points be amended as secondary access roadways. As described in Section 3.13,
Transportation and Traffic, the Project proposed three emergency access points from 1) the
intersection of LOVR and Auto Park Way, 2) gated emergency access from Upper Terrace of
Villaggio to the Mountainbrook Church parking lot, and 3) the Irish Hills Plaza Parking Lot. With
the exception of the LOVR and Auto Park Way intersection access point (the Project’s main
entrance), none of these emergency access points are proposed as secondary access roadways due
to the infeasibility of securing or permitting such access through adjacent properties of the Irish
Hills Plaza and Mountainbrook Church. The proposed Villaggio would be a secure facility with a
gated entrance to ensure controlled access for residents and visitors. Further, providing secondary
access roadways through these locations would be dependent upon negotiation and approval with
8-52
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
the respective property owners, which cannot be assured. However, through these emergency
access routes are not proposed as secondary access roadways, pedestrian and bicycle access would
be available at these access points. Gated pedestrian access is proposed at the emergency access
point at Mountainbrook Church, while removable bollards at the Project site’s boundary with Irish
Hills Plaza would prohibit access by vehicles, but allow free access by pedestrians and cyclists.
Additional discussion on this matter has been added to the discussion of the Project’s consistency
with applicable TCM measures under Impact AQ-5 in Section 3.3, Air Quality and Greenhouse
Gas Emissions.
Regarding TCM T-6, SLO County APCD recommends the Applicant coordinate with Caltrans and
revise the Transportation Impact Study to include standard Caltrans methodology in Traffic-related
impact analysis. See Comment Responses S.2-1 through S.2-11 above for detailed responses to
Caltrans questions and concerns regarding transportation analysis. The comment further
recommends MM TRANS-1 be revised to require the Applicant to coordinate with SLO Regional
Rideshare for Construction Transportation Management Plan development. As discussed under
Section 3.3, Air Quality and Greenhouse Gas Emissions, the EIR requires the Project to include
measures to reduce mobile-source emissions and VMT, including incentivizing participation in
the San Luis Obispo Regional Rideshare program and promotion of carpools, vanpools, and
electric vehicle usage. The recommended revisions to MM TRANS-1 have been incorporated to
EIR. Upon further review of the feasibility of a car share program, MM AQ-4 has been amended
to state that “The City has consulted with car share programs in other areas and researched the
requirements of such a program, and have determined that a car share program is not feasible for
this Project.” Please also refer to Section 3.13, Transportation and Traffic for specific revisions.
Regarding L-1, the comment recommends the Project be developed at higher densities, that urban
growth should occur only within urban reserve lines (URL), and neighborhoods should be planned
to allow convenient access for local and regional transit systems. As discussed in the EIR, the
Project involves a specific plan for a mix of residential, commercial, and open space uses within
the Madonna Froom Ranch portion of the site, which lies within the URL. Though not wholly
within the URL, the FRSP also proposes a variety of uses, amenities, and ancillary services within
Villaggio to reduce automobile trips. The compact mixed-use nature of the Project and location
adjacent to commercial services, schools, and transit would help to reduce travel distances between
home, work, school, and shopping by providing services and opportunities near one another and
by locating development proximate to transit and non-vehicular transportation. Therefore,
implementation of the Project would be consistent with measures L-1. Additional discussion on
this matter has been added to the discussion of the Project’s consistency with applicable Land Use
Strategies under Impact AQ-5 in Section 3.3, Air Quality and Greenhouse Gas Emissions.
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Regarding L-2, the comment recommends the Project include essential services (e.g., affordable
childcare facility) at the Project site to reduce VMTs. As discussed in the EIR, the FRSP proposes
a variety of uses, amenities, and ancillary services to reduce automobile trips, primarily for
Villaggio. In addition, as identified by the comment, the EIR includes MM AQ-4 requiring
implementation of all feasible measures from Table 3-5 of the Air Quality Handbook, including
Measure No. 23. Per MM AQ-4 and Measure No. 23, the Applicant shall amend the Draft FRSP
to include policies that allow for the provision of childcare facilities onsite. With implementation
of these proposed measures and required mitigation, the Project would be consistent with APCD’s
recommendation to provide essential services onsite for residents. Additional discussion on this
matter has been added to the discussion of the Project’s consistency with applicable Land Use
Strategies under Impact AQ-5 in Section 3.3, Air Quality and Greenhouse Gas Emissions.
With regard to L-3, the Project’s proposed construction of 174 units within Madonna Froom Ranch
would provide additional housing for the existing and growing labor force. Since the units
proposed within Villaggio would provide specialized housing for seniors, the 404 units and 51
beds within Villaggio would not generally be utilized by the City’s labor force, and therefore are
not counted as part of the City’s housing supply. Further, the Project would also add jobs within
the City by facilitating the creation of 332 jobs within proposed retail and commercial uses and
within Villaggio health care and service sectors. Overall, the Project would result in both an
increased housing supply and an increase in jobs; therefore, the Project would be consistent with
measure L-3. Refer also to discussion of Project impacts on the City’s jobs-to-housing balance
presented in Section 3.11, Population and Housing. Additional discussion on this matter has been
added to the discussion of the Project’s consistency with applicable Land Use Strategies under
Impact AQ-5 in Section 3.3, Air Quality and Greenhouse Gas Emissions.
Lastly, with regard to the Project’s consistency with TCM L-4, given the site is currently located
on the southern edge of the City with limited surrounding development and constraining site
features (e.g., Froom Creek, Irish Hills), the opportunity and ability to develop an interconnected
street system is limited. However, as required under MM AQ-4 and Measure No. 3 of the Air
Quality Handbook, public commercial collector roads shall be connected to adjacent development
to the extent feasible to allow pedestrian and bicyclist access, and public pedestrian trails will
connect public roads to the existing trail system in the Irish Hills Natural Reserve. Implementation
of this measure would ensure to proposed circulation system is designed to reduce the number of
cul-de-sacs and dead-end streets to the extent feasible. It should be noted that through the planning
process for this Project, the Applicant has tried to provide access to Irish Hills Plaza. While this
was explored, a reciprocal vehicular access agreement was not approved by the Irish Hills Plaza
property owner. Access to Calle Joaquin was also evaluated, but the feasibility of such a
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
connection was determined infeasible due to natural constraints by intervening wetlands and
Froom Creek. Additional discussion on this matter has been added to the discussion of the Project’s
consistent with applicable Land Use Strategies under Impact AQ-5 in Section 3.3, Air Quality and
Greenhouse Gas Emissions.
8-55
01904
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: December 18, 2019
TO: Shawna Scott, Senior Planner, San Luis Obispo Community Development
Department
FROM: Lynda L. Auchinachie, San Luis Obispo County Agriculture Department
SUBJECT: Froom Ranch Specific Plan Draft Environmental Impact Report (3175)
Thank you for the opportunity to comment on the draft environmental impact report (DEIR) for
the Froom Ranch and Villaggio Life Plan Community Specific Plan project. It appears that our
department’s notice of preparation (NOP) question regarding the proposed reconfiguration of
the existing agricultural easement has been addressed. However, our department continues to
be concerned that impacts to “prime agricultural land,” as defined in Government Code 56064,
may need further consideration based on:
x The DEIR indicates there are over 45 acres of Cropley clay (0-2 percent slope) and
Salinas silty clay loam (0-2 percent slope) soils that would be converted as a result of the
proposed project. These are the same soils that supported a variety of high value
vegetable crops on the San Luis Ranch site.
x The above soils have an irrigated rating of class 1 or 2 by the USDA Natural Resources
Conservation Service.
x It appears irrigated production is feasible as the DEIR indicates there are adequate
onsite water resources for irrigation during drought and non-drought years.
x It appears the Cropley clay and Salinas silty clay loam meet the definition of prime
agricultural land and therefore local policies to protect agricultural resources may
require an agricultural easement.
Thank you for your consideration. If you have questions, please call 781-5914.
cc. David Church, LAFCO Executive Director
L.2-1
L.2-2
L.2-3
L.2-4
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.2.3 Comment Letter L.2 – County of San Luis Obispo Department of Agriculture/ Weights
& Measures
Comment Response L.2-1
Thank you for your comments regarding the FRSP and EIR. The comment notes the EIR has
addressed the County Department of Agriculture/Weights and Measures initial comments on the
NOP associated with the existing agricultural easement as discussed in Section 3.2, Agricultural
Resources. Comments regarding concerns over potential impacts to prime agricultural land are
provided in the following responses.
Comment Response L.2-2
The comment accurately acknowledges the EIR indicated over 45 acres of Cropley clay and
Salinas silty clay loam soils would be converted onsite under the Project and, the soils have an
irrigated rating of Class 1 or 2 by the USDA Natural Recourses Conservation Service. As described
in the EIR, Cropley Clay is rated with a land capability classification (LCC) of Class IIs with
irrigation and Salinas silty clay loam is rated with an LCC of Class I with irrigation.
Comment Response L.2-3
The comment accurately acknowledges the EIR’s conclusion that irrigation of onsite soils is
feasible. It should be noted that the Project site is not currently irrigated and has not been irrigated
in the past. Also, with regard to onsite water resources, the Project site has a moderate potential
for subsidence and subsidence has historically been observed along LOVR during the drought of
1987-1991 when significant groundwater pumping occurred in the region as documented in
Appendix H, Hydrologic Resources Studies (refer to Groundwater Impacts Assessment prepared
by Cleath-Harris Geologists, Inc.). However, the conditions surrounding those former pumping
activities vary significantly from current conditions and there are other ways in which irrigation of
the site could potentially be achieved.
Comment Response L.2-4
The comment states that onsite soils appear to meet the definition of prime agricultural land
pursuant to Government Code Section 56064 (Cortese-Knox-Hertzberg Act) and an agricultural
easement may be necessary. As assessed in Section 3.2, Agricultural Resources, the Project site is
not Important Farmland, as defined by the California Farmland Mapping and Monitoring Program
(FMMP); however, the EIR acknowledges that soil types onsite are prime if irrigated. To assess
the CEQA agricultural value of the Project site given these facts, the City used the California
Agricultural Land Evaluation and Site Assessment (LESA) Model to evaluate potential impacts
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related to the conversion of agricultural soils for the purposes of the CEQA analysis. 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 factors are based upon measures of soil resource quality,
and four Site Assessment factors provide measures of a given project’s size, water resource
availability, surrounding agricultural lands, and surrounding protected resource lands. Appendix
G of the State CEQA Guidelines specifically states that lead agencies can rely on the LESA model
in making their determination regarding the significance of impacts related to the conversion of
farmland:
“In determining whether impacts to agricultural resources are significant environmental effects,
lead agencies may refer to the California Land Evaluation and Site Assessment Model (1997)
prepared by the California Dept. of Conservation as an optional model to use in assessing impacts
on agriculture and farmland.”
Please refer to Section 3.2, Agricultural Resources and the LESA analysis provided in Appendix
L for detailed discussion and classification of soils onsite.
Regarding the requirement for an agricultural easement, the EIR also recognizes that the Project
is subject to the annexation approval jurisdiction of the San Luis Obispo County Local Agency
Formation Commission (LAFCO). Page 3.2-12 and 3.2-13 of the EIR identify LAFCO’s
Agricultural Policies, which the Project would be required to comply with before LAFCO can
approve annexation of the Project site into the City. These policies state that LAFCO can 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 1:1 substitution may be met by (1) acquisition and dedication of farmland,
development rights, and/or conservation easements to permanently protect farmlands within the
annexation area or lands with similar characteristics within the County Planning Area; (2) payment
of in-lieu fees to an established, qualified, mitigation/conservation program or organization
sufficient to fully fund the acquisition and dedication stated above (in item [1]); or (3) other
measures agreed by the applicant and the land use jurisdiction that meet the intent of replacing
prime agricultural land at a 1:1 ratio. Refer to EIR pages 3.2-12 and 3.2-13.
As indicated in the EIR, existing regulations will require the Project to comply with these
agricultural policies as a prerequisite to LAFCO’s approval of the requested annexation. Therefore,
affected onsite prime soils will be required to be preserved or substituted at a 1:1 ratio through one
(or a combination of) the agricultural substitution requirements stated above. A portion of the
prime agricultural soils onsite (approximately 7 acres) currently support established jurisdictional
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
wetlands (e.g., in the 8.3-acre Calle Joaquin wetland). Direct impacts to these areas would be
avoided to the greatest extent feasible and these areas are proposed to be permanently protected
for habitat/open space use through amendment of the onsite agriculture and open space easement.
Impacts to these prime agricultural soils would be avoided and these areas would be permanently
protected, consistent with LAFCO’s policies.
In addition, the Project includes a total of 59.0 acres of open space, including 38.9 acres within
Villaggio and 20.1 acres within Madonna Froom Ranch, the majority of which would be preserved
within the Upper Terrace. The Upper Terrace area supports only grazing land along with a wide
variety of sensitive biological resources. The Lower Area of Villaggio and Madonna Froom Ranch
contain the prime soils (if irrigated) that would be affected by the Project, including both
development and preservation with designated open space areas; however, the Project site does
not currently (and has not historically) supported irrigated row crops or other intensive agricultural
uses and is not irrigated. The site is currently used for horse grazing and has not otherwise been
used for agricultural production purposes. The preservation of onsite wetlands and the unique and
highly sensitive biological resources in the Upper Terrace as designated open space provide a
substantial public benefit by protecting and preserving grazing lands and the highest quality natural
resources within the Specific Plan area and may, in part, meet the intent of LAFCO’s agricultural
policies, as stated in (3) above.
As the Project moves through the approval process, the City will be required to ensure the Project
is consistent with the Cortese-Knox-Hertzberg Act, LAFCO polies, and City policies related to the
protection of prime farmland. This will include ensuring conversion of agricultural soils has been
achieved at a 1:1 ratio consistent with the LAFCO policies stated above. This could be achieved
through permanent protection of onsite resources described above and/or a combination of
additional offsite agricultural lands at a minimum of a 1:1 ratio.
Additional regulatory information regarding the requirements of the Cortese-Knox-Hertzberg
Local Government Reorganization Act of 2000, which establishes the procedures for local
government changes of organization (including annexations), and which LAFCO is required to
comply with, has been added to Section 3.2.2.1 of the EIR (pages 3.2-8 and 3.2-9). Additional
information regarding the Project’s requirement to be consistent with these policies has also been
added to Impact AG-1 of the EIR.
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December 20, 2019
City of San Luis Obispo
Community Development Department
Attn: Shawna Scott, Senior Planner
919 Palm Street
San Luis Obispo, CA 93401
Subject: Froom Ranch Specific Plan Draft Environmental Impact Report
State Clearinghouse #2017071033
Dear Ms. Scott:
The San Luis Obispo Council of Governments (SLOCOG) appreciates the opportunity to review the Draft
Environmental Impact (DEIR) for the Froom Ranch Specific Plan (FRSP) Project. The State of California and Federal
Highways Administration designate SLOCOG as the Regional Transportation Planning Agency (RTPA) and the
Metropolitan Planning Organization (MPO) for the region. While SLOCOG does not have permit or regulatory
authority for land use proposals, SLOCOG is responsible for planning the long-term viability of the regional surface
transportation system, and for programming funds to achieve the objectives of the Regional Transportation Plan and
Sustainable Communities Strategy. SLOCOG received a Notice of Availability on the DEIR for the Froom Ranch Specific
Plan on November 8, 2019.
SLOCOG staff reviews EIRs and Specific Plans to ensure positive outcomes in transportation choices, mobility,
circulation, efficiency, safety and connectivity within and between our communities. SLOCOG’s adopted the 2019
RTP (available online at https://slocog.org/2019RTP) includes a forecasted development pattern and intermodal
transportation investment portfolio that meet greenhouse gas emission reduction targets specified by the California
Air Resources Board. The 2019 RTP includes numerous principles, goals, and policies that were used to prepare the
following comments; and is our blueprint for our future transportation system. It strives to enhance our quality of
life, promotes more sustainable communities, and develops a comprehensive intermodal transportation system.
The proposed FRSP consists of two main components - the Villaggio Life Plan Community and Madonna Froom Ranch,
which are anticipated to be constructed in phases. The Villaggio Life Plan Community (Villaggio) consists of a 70.4-
acre gated senior residential community (residents must be 60+ years of age), which would be located in the central
and southern portions of the FRSP. The Madonna Froom Ranch would consist of multi-family residential, retail
commercial uses, and a public park within 39.3 acres of the northern and eastern portions of the FRSP area.
Specifically, the project includes:
x 404 senior housing units that would include 51 beds for memory care and skilled nursing
x 174 units of multi-family residential
x 100,000 square feet (2.3 acres) of commercial that would include approximately 70,000 sf of hotel use with
up to 120 rooms and 30,000 sf of retail and office uses
x 59 acres of open space/conservation
x 2.9 acres public park
L.3-1
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Page 2 of 5
Additionally, the proposed Project includes a request for a General Plan Amendment to allow development above the
150-foot elevation, which is currently prohibited by Land Use Element Policy 6.4.7(H), Hillside Planning Areas.
Improvements associated with the FRSP would include the realignment and restoration of Froom Creek, construction
of a stormwater basin, widening of Los Osos Valley Road, a new transit stop, signalization of the Los Osos Valley Road
and Auto Park Way intersection, sidewalk infill, class IV bike lanes, and protected bike intersections. It is estimated
that the Project would require approximately 160,000 cubic yards of cut, 378,000 cubic yards of fill, and 2,300 cubic
yards of rock/aggregate import.
SLOCOG supports efforts to provide additional housing in the city as this will promote a better jobs-housing balance
and reduce vehicle miles traveled and related greenhouse gas emissions. Aspects of the FRSP support the
implementation of SLOCOG’s 2019 RTP, which strives to accommodate growth while improving quality of life for the
region’s residents.
SLOCOG respectfully submits the following comments in response to the Project.
GGeneral Areas of Concern
Hillside Development Policies and Planning
A strategy of SLOCOG’s RTP is to support policies that protect valuable habitats and natural resources through
acquisitions, setbacks, conservation easements, and environmental mitigation programs. As stated in the EIR, building
above the 150-foot elevation line would result in potentially significant and unavoidable impacts to aesthetic and
visual resources, biological resources, and emergency access and fire hazards. Due to these environmental
constraints, SLOCOG recommends looking at alternative options to development.
Multimodal Transportation Mitigation Measures
SLOCOG’s 2019 RTP encourages local jurisdictions to establish and maintain a mix of transit, bicycle, and pedestrian
access choices. It also supports incorporating design features and infrastructure in new projects that promote active
transportation and transit use. SLOCOG supports the proposed mitigation measures that improve the multimodal
environment and promote an interconnected transportation network.
Park and Ride Lot Facilities
Park and ride lots are “change of mode facilities” where individuals meet and then group-travel to their destinations
via carpool, vanpool, or transit and are a major component of SLOCOG’s overall transportation demand management
(TDM) efforts to reduce single-occupancy vehicle trips, vehicle miles traveled, and related greenhouse gas emissions.
An existing park and ride lot facility is located at the Hampton Inn and Suites located on Called Joaquin and SLOCOG
supports mitigation measure that incorporate the use of this existing facility.
Connectivity
SLOCOG encourages the City to explore opportunities provide a secondary access point to LOVR or Calle Joaquin to
improve connectivity to the external transportation network and adjacent land uses, the Irish Hills public trail
network, and the existing park and ride lot facility, and to provide an additional emergency evacuation route.
Transportation Demand Management Plan
SLOCOG recommends the City of San Luis Obispo work with SLO Regional Rideshare to develop a transportation
demand management plan.
This plan would:
x Recommend strategies to reduce traffic impacts generated by construction activities.
L.3-1
cont.
L.3-2
L3-3
L.3-4
L.3-5
L.3-6
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Page 3 of 5
x Recommend strategies to reduce single-occupancy vehicle trips made by new residents and employees.
x Establish a measured baseline of vehicle trips from which reductions shall be determined at the time of the
future trip generation analyses.
x Identify a point of contact to coordinate plan implantation.
Existing Conditions Baseline Traffic Volume Data
The February 2016 and March 2016 existing condition baseline traffic volumes used in the traffic study are outdated
at 3.5 years old. Page 36 of the Multimodal Transportation Impact Analysis Report (Appendix J) confirms the use of
the outdated data. Caltrans requires a baseline conditions analysis based upon traffic data that is no more than 2
years old. SLOCOG recommends the Froom Ranch Development provide an existing conditions analysis that is based
upon new data.
Bicycle and Pedestrian Intersection Level of Service Methodology
Table 3.13-4 describes qualitative LOS criteria for bicycle and pedestrian facilities. Tables 3.13-5 and 3.13-6 describe
quantitative pedestrian and bicycle segment LOS methodologies. No methodology is identified to determine bicycle
and pedestrian intersection LOS. SLOCOG recommends the inclusion of a bicycle and pedestrian intersection LOS
methodology.
TTransportation Comments
Transit Improvements
The Plan requires provision and/or enhancement of existing bus stop(s) within or adjacent to the Specific Plan Area
for inclusion on existing City bus Routes or future bus routes. SLOCOG suggests that the project include a new bus
stop along LOVR directly in front of Madonna Froom Ranch that is a pullout bus stop. Pedestrian access should be
included from the Madonna Froom Ranch residential areas to the bus stop. SLOCOG suggests this be implemented
during the first phase development.
MM TRANS-1
Construction activities creating traffic impacts will include import of soil and rock via heavy haul trucks. MM TRANS-1
states that a Construction Transportation Management Plan shall be developed for all phases of the Project for
review and approval by the City prior to issuance of grading or building permits to address and manage traffic during
construction. The Plan will include a number of preconstruction and ongoing safety measures, including:
x Trucks shall only travel on a city-approved construction route;
x The traveling public shall be advised of impending construction activities that may substantially affect key
roadways or other facilities (e.g., information signs, portable message signs, media listing/notification, and
implementation of an approved construction impact mitigation plan);
x Timely notification of construction schedules shall be provided to all affected agencies (e.g., Police
Department, Fire Department, Public Works Department, and Community Development Department) and to
all owners and residential and commercial tenants of property within a radius of 0.25 mile.
When construction activities include the use of heavy haul trucks for import of soil and rock from local quarry
operations accessed by highways and roads potentially frequented by bicyclists, SLOCOG recommends import
schedule be shared with local bicycle advisory committees and stakeholders.
L.3-6
cont.
L.3-7
L.3-8
L.3-9
L.3-10
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Page 4 of 5
MM AQ-6
There is no Dial-a-Ride service operating within the City of San Luis Obispo, or this portion of currently
unincorporated land. MM AQ-6 states that Applicant shall provide clean fuel shuttle services or coordinate with
existing shuttle service providers. In order to mitigate GHG impacts of AQ-4, and in the event that Villaggio foregoes
provision of clean fuel shuttles to rely strictly on coordination with existing shuttle services, SLOCOG recommends the
purchase of, or fair share contribution toward the purchase of, new clean fuel vehicles for existing shuttle service
providers.
MM TRANS-5
SLOCOG supports the extension of the westbound bike lane on Tank Farm Road approaching the intersection with
South Higurea Street and the installation of a bike box to facilitate left turn movements through the intersection.
SLOCOG encourages consideration for upgrade to, or project fair share contribution toward, pedestrian safety
enhancements at the northeast corner of the intersection, such as a pedestrian refuge island or pedestrian lead
interval.
MM TRANS-9
SLOCOG supports the completion of the sidewalk connection and installation of Class IV bicycle lanes on LOVR between
the Irish Hills Plaza and Calle Joaquin and encourages consideration to install a protected intersection at the northwest
corner of the intersection. These mitigation measures will provide safe multimodal access to the existing park and ride
lot facility.
MM AQ-3
SLOCOG supports implementation of offsite mitigation strategies to replace transit buses and the expansion of transit
services, and improvements to the existing park and ride lot facility.
HHousing Comments
MM HAZ-4
With a potential of 1,231 residents, one main roadway access point via Los Osos Valley Road (LOVR), and senior living
focused facilities, SLOCOG suggests an evacuation plan and protocol be created and maintained so staff at the
Villaggio complex and residents in Madonna Froom Ranch are aware of how to proceed in the event of an emergency.
“Given this negligible change in the jobs-to-housing ratio, the Project would maintain the City’s current jobs-
to-housing ratio of 2.5 to 1, ensuring consistency with Policy LU 1.5. The Project would provide a substantial
increase in the City’s housing supply, including a range of housing types and affordability as well as long-term
job growth both within Villaggio and Madonna Froom Ranch.” (p.3.11-23)
Earlier in the section it was discussed that the 404 specialized senior housing units will not be counted in the City’s
Housing supply. There will be 174 units added to the city’s housing supply. Please verify where the substantial
increase in the City’s housing supply coming from if the ratio remains the same.
As stated in the specific plan, “Policy HE 4.2 Include both market-rate and affordable units in apartment and
residential condominium projects and intermix the types of units. Affordable units should be comparable in size,
appearance and basic quality to market-rate units.” SLOCOG’s RTA/SCS supports a mix of housing options in new
residential developments.
It is a strategy of the SCS to “Support residential development that increases the region’s supply of deed-restricted
affordable housing, and supply of rental housing.” SLOCOG supports the inclusion of deed-restricted affordable
housing units within the development.
L.3-11
L.3-12
L.3-13
L.3-15
L.3-16
L.3-17
L.3-14
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Page 5 of 5
Development Outside the Urban Reserve Line
SLOCOG’s 2019 RTP supports the consideration of urban service boundaries as a criterion for reviewing development
projects. The proposed project is adjacent to the urban reserve line (URL) for the City. If approved, the project would
annex and develop land outside of the City’s URL, which can lead to an increase in air quality impacts due to longer
commuting distances and increase of motor vehicle use.
However, the RTP also supports the expansion of the region’s supply of housing for renters, first-time homebuyers,
and the broader workforce to maintain the vitality of regional economy. If approved, this project has the potential to
free up residential homes in the City as aging seniors move to the development’s senior units. By increasing the
available housing stock, those working in the City may have a greater opportunity to live in the City, reducing
commute distances and related emissions while reducing overall transportation expenses. Reducing these expenses
provides greater opportunity to invest those funds in the local economy. These potential benefits would only be
achieved if existing residents of the City are granted access to the senior units first. SLOCOG supports the
development of strategies that ensure residents who are already living in the City, or people that are already working
in the City, are given the first opportunity to live in the senior units.
GGrammatical Changes
x “Consistent with state law, the City’s RHNA is reduced based on the number of dwelling units approved, under
construction, or built between January 1, 2014 and June 30, 2014 2019.” (p. 3.11-10)
x Vesting Tentative Tract Map (VTTM) acronym throughout the document should be corrected as there are 167
references to VTM
x “The RTP/Sustainable Communities Strategy (SCS) outlines SCAG’s SLOCOG’s plan for integrating the
transportation network and related strategies with an overall land use pattern that responds to projected growth
to attain and exceed the GHG emission-reduction targets set forth by CARB.” (p. 3-13-53)
Thank you again for providing SLOCOG the opportunity to review and comment on the Project and we wish you and all
those involved success in moving the Project forward. There should be close coordination with Caltrans, the Air
Pollution Control District, SLOCOG, SLO Regional Rideshare, and the developer to continue to refine data analysis and
identify necessary solutions for the project’s impacts.
Please do not hesitate to reach out to Stephen Hanamaikai for transportation issues at 805-788-2104 or via email at
shanamaikai@slocog.org or to Sara Sanders for housing related issues at 805-597-8052 or via email at
ssanders@slocog.org.
Sincerely,
Stephen Hanamaikai, Transportation Planner Sara Sanders, Transportation Planner
San Luis Obispo Council of Governments San Luis Obispo Council of Governments
CC: Sarah Woolsey, SLOCOG
Jacqueline Mansoor, APCD
Jenna Schudson, Caltrans District 5
Sincerely,
StephenHanamaikai Transportation
L.3-18
L.3-19
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.2.4 Comment Letter L.3 – San Luis Obispo Council of Governments
Comment Response L.3-1
Thank you for your comments regarding the FRSP and EIR. The comment states SLOCOG’s
support of the overall Project efforts to increase housing in the City and promote a greater job-
housing balance while reducing VMTs and associated emissions. The City recognizes the
importance of SLOCOG in planning for long-term viability of transportation systems in the Project
area. Detailed responses to SLOCOG’s specific comments are provided in the following responses.
Comment Response L.3-2
The comment describes SLOCOG’s concern of development above 150-foot elevation line. The
EIR recognizes the proposed Project would be potentially inconsistent with the City’s existing
hillside protection policies regarding the limitation to development to below the 150-foot elevation
line in Section 3.9, Land Use and Planning. While the EIR identifies a potential inconsistency for
the Project with this adopted policy, the EIR includes analysis of Alternative 1, which would be
designed to be consistent with City policies for hillside development. As analyzed in Section 5.0,
Alternatives, Alternative 1- Clustered Development Below the 150-foot Elevation would involve
the consolidation of proposed development towards the lower elevation areas of the site below the
150-foot elevation line to ensure consistency with City hillside development policies. Due to
Alternative 1 consistency with these City policies, as well as redesign of the Project to address or
reduce other impacts identified of the Project, Alternative 1 is identified as the Environmentally
Superior Alternative. For additional analysis and specifics on Alternative 1, please refer to Section
5.0, Alternatives.
Comment Response L.3-3
The comment supports the EIR’s mitigation measures related to multimodal transportation
improvements and promotion of an interconnected transportation network. These comments
supporting the EIR findings and mitigation measures will be included within the public record and
will be made available to the City decisionmakers for planning and policy consideration.
Comment Response L.3-4
The comment supports mitigation that incorporates the use or enhancement of the existing Calle
Joaquin Park and Ride Lot, located just south of the Project. MM AQ-4 includes a recommendation
for the Project Applicant to coordinate with SLOCOG to improve the nearby Calle Joaquin Park
and Ride Lot. Potential opportunities for enhancement of this facility include funding and
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installing an electric vehicle charging station or contributing fair-share mitigation for the
installation of the electric vehicle charging station.
Comment Response L.3-5
This comment encourages the City to explore opportunities to provide secondary access points to
LOVR or Calle Joaquin to improve connectivity between the Project and adjacent land uses. The
Project includes several points of access for pedestrians and cyclists to connect with the adjacent
transportation network and land uses, including to the Irish Hills Plaza, along the primary Project
access road (Commercial Collector A), and via a secondary pedestrian/emergency access point
that connects Villaggio to Mountainbrook Church. Alternative 1, the Environmentally Superior
Alternative, also evaluated additional connection points to Calle Joaquin and from Froom Creek
Trail and Villaggio to LOVR south of the primary access road. The feasibility of a connection to
Calle Joaquin is constrained by wetlands and the existing (and proposed) Froom Creek alignment.
The Project would be required to meet City standards for emergency access and safety.
Comment Response L.3-6
This comment recommends that the City and Project Applicant work with SLO Regional
Rideshare to develop a transportation demand management plan for the Project. MM AQ-4 and
MM AQ-6 identify a multitude of measures required to reduce the Project’s traffic/parking demand
and emissions, including several strategies that recommend coordination with SLO Regional
Rideshare.
Comment Response L.3-7
This comment repeats the statements expressed in Comment S.2-7. For the purposes of the
supplemental analysis, traffic volumes were updated using more recent traffic count data collected
in February 2020. The technical memorandum summarizing the findings of this analysis is
provided in the Final EIR Appendix M. See Comment Response S.2-7 for additional details.
Comment Response L.3-8
This comment recommends the inclusion of bicycle and pedestrian intersection level of service
(LOS) methodology summary tables in Section 3.13, Transportation and Traffic of the EIR. Tables
3.13-5 and 3.13-6 summarize pedestrian, bicycle, and transit LOS methodologies for roadway
segments. These LOS tables are applicable to segment and intersection analyses. The Final EIR
has been revised to include a table description to clarify this.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response L.3-9
This comment recommends that the Project provide a new bus stop with turnout on LOVR directly
in front of the Madonna Froom Ranch site and that pedestrian access be provided between the bus
stop and Madonna Froom Ranch residential uses. The Project proposes construction of a new bus
stop and turnout at the intersection of LOVR/Auto Park, directly fronting the Project site. This
facility would be constructed prior to occupancy of any phases of the Project. Pedestrian and
bicycle connectivity will be provided along Commercial Collector A to provide access to the new
bus stop to site residents, employees, and visitors.
Comment Response L.3-10
This comment requests construction traffic routes and schedules be shared with local bicycle
advisory committees and stakeholders. The Final EIR includes additional language within MM
TRANS-1 that requires the Applicant and City to share information on construction traffic plans,
routes and schedules with the City Active Transportation Committee, County Public Works
Department (for distribution to the County Bicycle Advisory Committee), and local bicycle
advocacy groups, such as Bike SLO County and the SLO Bicycle Club.
Comment Response L.3-11
The comment states that there is no Dial-a-Ride service operating in the City and recommends the
Project Applicant purchase or contribute fair-share contribution toward the purchase of, new clean
fuel vehicles for existing shuttle service providers as a means of mitigating GHG impacts. MM
AQ-6 has been clarified to remove the reference to Dial-a-Ride service and has been clarified to
require that sufficient onsite electric vehicle charging infrastructure shall be provided to support
the proposed Villaggio clean fuel shuttle service. Table 3.3-9 has been amended to require
installation of an electric vehicle charging station at the Calle Joaquin Park & Ride and to require
the provision of electric vehicle charging infrastructure for fleet, shuttle, or group-transport
vehicles within the commercially zoned areas of the Specific Plan. These measures will all support
electric vehicle use.
Comment Response L.3-12
This comment notes support for the bicycle improvement proposed at the South Higuera/Tank
Farm intersection and recommends additional pedestrian safety enhancements at the northeast
corner of the intersection, such as addition of a pedestrian refuge or lead pedestrian intervals. MM
TRANS-14 includes addition of lead pedestrian intervals at each crossing at this intersection. It
should also be noted that the intersection improvements described in MM TRANS-6a include
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elimination of the free “yield” westbound right-turn movement, which will also contribute towards
improving pedestrian crossing safety at this intersection.
Comment Response L.3-13
This comment notes support for the sidewalk and Class IV bicycle lanes recommended along
LOVR and recommends consideration for protected intersection elements at the LOVR/Auto Park
intersection. Per MM TRANS-22, the Project is required to install a protected intersection in
conjunction with signalization of the LOVR/Auto Park intersection.
Comment Response L.3-14
This comment notes SLOCOG support for offsite mitigation strategies to replace transit buses
and/or expand transit services, and improvements to the existing park and ride lot at Calle Joaquin.
For reference, mitigation strategies addressing these suggestions are described in MM AQ-4 and
MM AQ-6.
Comment Response L.3-15
The comment recommends the Project provide an evacuation plan and protocol, so staff are aware
of how to proceed in the event of an emergency. The EIR in Section 3.7, Hazards, Hazardous
Materials, and Wildfires identifies potentially significant impacts associated with emergency
evacuation in the event of a wildfire or emergency due to the substantial number of people that
could be present at the site and potential for congestion along evacuation routes out of the Project
site. To reduce Project impacts relating to emergency evacuation, the EIR identifies MM HAZ-4,
which would require the Applicant to prepare and implement an Evacuation Plan for both
Villaggio and Madonna Froom Ranch areas, including but not limited to regular practice drills of
the Evacuation Plan, signage of evacuation routes, and shelter-in-place accommodations. Please
refer to Section 3.7, Hazards, Hazardous Materials, and Wildfire for further detail on MM HAZ-
4, which is consistent with the recommendations made in this comment.
Comment Response L.3-16
The comment requests verification of discussion regarding the increase in the City’s housing
supply despite the City’s current jobs-to-housing ratio of 2.5:1 remaining the same with
implementation of the proposed Project. Detailed discussion regarding the Project impacts on the
City’s population, housing supply, and jobs-to-housing ratio is provided in Section 3.11,
Population and Housing. As discussed therein, the Project’s proposed construction of 174 new
residential units within Madonna Froom Ranch that would provide additional housing for the
existing and growing labor force. Since the units proposed within Villaggio would provide
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
specialized housing for seniors, the 404 units and 51 beds within Villaggio would not be utilized
by the City’s labor force, and therefore are not counted as part of the City’s housing supply. The
EIR in the section cited by the comment mischaracterizes the addition of 174 new residential units
a substantial increase in the City’s housing supply. The referenced text in Section 3.11, Population
and Housing has been revised accordingly.
Comment Response L.3-17
The comment states SLOCOG supports the Project’s inclusion of deed-restricted affordable
housing units onsite. Comments pertaining to SLOCOG’s support of the mix of affordable units
and market-rate units will be included within the public record and will be made available to the
City decisionmakers for planning and policy consideration.
Comment Response L.3-18
The comment states SLOCOG supports the development of senior living units under the Project
and states the potential of the Project to “free up” residential homes increasing the available
housing stock, which may reduce commuting as workers move into the City limits. Based on the
Applicant’s current deposit list, approximately 300 persons proposing to reside at Villaggio once
constructed are current City residents that would move from and vacate their existing homes (RRM
Design Group 2019). Though future residents of the Project are likely to be existing residents of
the City, the action of moving to the Project and vacating their homes has the potential to attract
new residents to the City from outside the existing population. Given this circumstance and the
fact that the origin of future residents of the Project cannot reliably be forecasted, the Project is
estimated to result in a residential population growth of approximately 1,231 persons.
Nevertheless, SLOCOG’s recommendation that residents of the City of San Luis Obispo are
provided priority to senior living units at the Project will be included within the public record and
will be made available to the Applicant and City decisionmakers.
Comment Response L.3-19
The comment identifies several recommendations for grammatical changes. These recommended
grammatical corrections have been made in the appropriate sections of the EIR. However, the term
Vesting Tentative Tract Map (VTTM) refers to the physical map provided in Appendix B of the
EIR. References to the Vesting Tract Map (VTM) are referring to the future VTM prepared for the
Project, if the FRSP is approved. The EIR’s mitigation measures use VTMs as this requires the
Project to use the finalized version of the Maps. Use of and reference to the VTTM in the EIR is
intentional and does not require correction.
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01918
L.4-1
L.4-2
L.4-3
8-70
01919
L.4-4
L.4-6
L.4-7
L.4-5
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01920
8.4.2.5 Comment Letter L.4 – San Luis Obispo Local Agency Formation Commission
Comment Response L.4-1
Thank you for your comments regarding the FRSP and EIR. The comments and recommendations
made by LAFCO will be included in the public record and will be made available to the City
decisionmakers for planning and policy considerations. Detailed responses to each of the discrete
comments made in this letter are addressed below.
Comment Response L.4-2
The comment states use of the LESA Model for the definition of prime agricultural land may not
align with the Government Code Section 56064 Cortese-Knox-Hertzberg Act definition of prime
farmland, and under the CKH Act definition, the Project may result in the conversion of prime
agricultural land. Under the CKH Act Section 56064, prime agricultural land is defined as:
“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 compatibility classification,
whether or not land is actually irrigated, provided that irrigation is feasible.
b)Land that qualifies for rating 80 through 100 Storie Index Rating.
c)Land that supports livestock used for the production of food and fiber and that has
an annual carrying capacity equivalent to at least one animal unit per acre as
defined by the United States Department of Agriculture in the National Range and
Pasture Handbook, Revision 1, December 2003.
d)Land planted with fruit or nut-bearing trees, vines, bushes, or crops that have a
nonbearing period of less than five years and that will return during the commercial
bearing period on an annual basis from the production of unprocessed agricultural
plant production not less than four hundred dollars ($400) per acre.
e)Land that has returned from the production of unprocessed agricultural plant
products an annual gross value of not less than four hundred dollars ($400) per
acre for three of the previous five calendar years.”
As assessed in Section 3.2, Agricultural Resources, the Project site is not Important Farmland, as
defined by the California FMMP; however, the EIR acknowledges that soil types onsite are prime
if irrigated. To assess the CEQA agricultural value of the Project site given these facts, the City
used the LESA Model to evaluate potential impacts related to the conversion of agricultural soils
for the purposes of CEQA analysis. LESA is a method used to define an approach for rating the
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
relative quality of land resources based upon specific measurable features. The California
Agricultural LESA Model is composed of six different factors: two Land Evaluation factors are
based upon measures of soil resource quality, and four Site Assessment factors provide measures
of a given project’s size, water resource availability, surrounding agricultural lands, and
surrounding protected resource lands. Appendix G of the State CEQA Guidelines specifically
states that lead agencies can rely on the LESA model in making their determination regarding the
significance of impacts related to the conversion of farmland:
“In determining whether impacts to agricultural resources are significant environmental effects,
lead agencies may refer to the California Land Evaluation and Site Assessment Model (1997)
prepared by the California Dept. of Conservation as an optional model to use in assessing impacts
on agriculture and farmland.”
Please refer to Section 3.2, Agricultural Resources and the LESA analysis provided in Appendix
L for detailed discussion and classification of soils onsite.
Regarding the requirement for an agricultural easement, the EIR also recognizes that the Project
is subject to the annexation approval jurisdiction of the San Luis Obispo County LAFCO. Page
3.2-12 and 3.2-13 of the EIR identify LAFCO’s Agricultural Policies, which the Project would be
required to comply with before LAFCO can approve annexation of the Project site into the City.
These policies state that LAFCO can 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 1:1 substitution may be met by (1)
acquisition and dedication of farmland, development rights, and/or conservation easements to
permanently protect farmlands within the annexation area or lands with similar characteristics
within the County Planning Area; (2) payment of in-lieu fees to an established, qualified,
mitigation/conservation program or organization sufficient to fully fund the acquisition and
dedication stated above (in item [1]); or (3) other measures agreed by the applicant and the land
use jurisdiction that meet the intent of replacing prime agricultural land at a 1:1 ratio. Refer to EIR
pages 3.2-12 and 3.2-13.
As indicated in the EIR, existing regulations will require the Project to comply with these
agricultural policies as a prerequisite to LAFCO’s approval of the requested annexation. Therefore,
affected onsite prime soils will be required to be preserved or substituted at a 1:1 ratio through one
(or a combination of) the agricultural substitution requirements stated above. A portion of the
prime agricultural soils onsite (approximately 7 acres) currently support established jurisdictional
wetlands (e.g., in the 8.3-acre Calle Joaquin wetland). Direct impacts to these areas would be
avoided to the greatest extent feasible and these areas are proposed to be permanently protected
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for habitat/open space use through amendment of the onsite agriculture and open space easement.
Impacts to these prime agricultural soils would be avoided and these areas would be permanently
protected, consistent with LAFCO’s policies.
In addition, the Project includes a total of 59.0 acres of open space, including 38.9 acres within
Villaggio and 20.1 acres within Madonna Froom Ranch, the majority of which would be preserved
within the Upper Terrace. The Upper Terrace area supports only grazing land along with a wide
variety of sensitive biological resources. The Lower Area of Villaggio and Madonna Froom Ranch
contain the prime soils (if irrigated) that would be affected by the Project, including both
development and preservation with designated open space areas; however, the Project site does
not currently (and has not historically) supported irrigated row crops or other intensive agricultural
uses and is not irrigated. The site is currently used for horse grazing and has not otherwise been
used for agricultural production purposes. The preservation of onsite wetlands and the unique and
highly sensitive biological resources in the Upper Terrace as designated open space provide a
substantial public benefit by protecting and preserving grazing lands and the highest quality natural
resources within the Specific Plan area and may, in part, meet the intent of LAFCO’s agricultural
policies, as stated in (3) above.
As the Project moves through the approval process, the City will be required to ensure the Project
is consistent with the Cortese-Knox-Hertzberg Act, LAFCO polies, and City policies related to the
protection of prime farmland. This will include ensuring conversion of agricultural soils has been
achieved at a 1:1 ratio consistent with the LAFCO policies stated above. This could be achieved
through permanent protection of onsite resources described above and/or a combination of
additional offsite agricultural lands at a minimum of a 1:1 ratio.
Additional regulatory information regarding the requirements of the Cortese-Knox-Hertzberg
Local Government Reorganization Act of 2000, which establishes the procedures for local
government changes of organization (including annexations), and which LAFCO is required to
comply with, has been added to Section 3.2.2.1 of the EIR (pages 3.2-8 and 3.2-9). Additional
information regarding the Project’s requirement to be consistent with these policies has also been
added to Impact AG-1 of the EIR.
Comment Response L.4-3
The comment requests the City meet the intent of LAFCO’s prime agricultural policies based on
Comment L.4-2. Please refer to Comment Response L.4-2.
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01923
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response L.4-4
The comment supports approval of Alternative 1 for the Project to avoid impacts to resources
present within the Upper Terrace and an overall Project resulting in greater consistency with
LAFCO policies. Alternative 1 has been identified in the EIR as the Environmentally Superior
Alternative. LAFCO’s support and preference for adoption of Alternative 1 is noted and those
comments will be included in the public record and provided to planning and policy decision
makers for consideration.
Comment Response L.4-5
The comment states that LAFCO considers the reconfigured Agricultural Easement to generally
appear consistent with the existing condition. LAFCO’s support of the EIR discussion and findings
regarding the agricultural easement will be included in the public record and passed along to policy
makers in the decision-making process.
Comment Response L.4-6
The comment recommends the City and Applicant identify an offsite opportunity to preserve prime
agricultural land that meets LAFCO’s 1:1 preservation requirement. As discussed in Section 3.2,
Agricultural Resources, the Project would be required to comply with LAFCO Policy 2.9.12,
Agricultural Policies, which states LAFCO may only approve annexations of prime agricultural
land if mitigation equates to a substitution ratio of at least 1:1 for the prime land to be converted.
Language has been added to the EIR that clarifies and confirms the Applicant would be required
to comply with LAFCO policies (refer to Comment Responses L.2-4 and L.4-2, above).
Comment Response L.4-7
The comment states the Project would provide 74 acres of open space area. As described in the
EIR, the Project would include designation of 59.0 acres of open space, which includes 51.9 acres
of open space and an existing 7.1-acre (minimum) agricultural and open space easement. In total,
the Project would result in designation of approximately 54 percent of the site as open space. The
EIR also analyzes the increase in designated open space that would result from Alternative 1,
which clusters proposed development below the 150-foot elevation line. Under Alternative 1, 66.8
acres would be designated as open space, an increase of 13 percent compared to the Project. The
comment acknowledges the requirement of Project easements being approved and in place prior
to filing for final annexation of the Project site. The Project would comply with LAFCO policies
related to easements, if approved.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3 Organizations
[Insert Comment Letter O.1, California Native Plant Society (1), page 1 of 9]
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01925
O.1-1
cont.
O.1-2
O.1-3
8-77
01926
O.1-3
cont.
O.1-4
O.1-5
O.1-6
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01927
O.1-7
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O.1-8
O.1-9
O.1-10
O.1-11
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O.1-11
cont.
O.1-12
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8-83
01932
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.1 Comment Letter O.1 – California Native Plant Society (1)
Comment Response O.1-1
Thank you for your comments and overall feedback regarding the proposed FRSP and EIR. These
comments supporting the EIR findings, mitigation measures, and identification of Alternative 1 as
the Environmentally Superior Alternative will be included within the public record and will be
made available to the City decisionmakers for planning and policy consideration.
Comment Response O.1-2
The comment relates to flooding of the wetland area that has occurred in the past and concerns
about additional flooding as a result of Project development. The Preliminary Hydrologic and
Hydraulic Calculations prepared for the Project (PHHC; EIR Appendix H.1) reflects that flooding
of the Calle Joaquin wetland area has been designed in a manner consistent with historical patterns.
The PHHC, pages 1-4 and 1-5, identifies that the existing alignment of Froom Creek has changed
during farming and ranching operations from the original alignment nearer to LOVR, and this has
included placement of fill along the outer creek bank, outside of the creek corridor. However, as
documented in Appendix H, overbanking of the creek has continued to provide surface runoff to
the Calle Joaquin wetland even after placement of fill material. This was cited in a 2004 report:
Hydrologic Sufficiency for Sustaining a Separated Wetland near Calle Joaquin (Balance
Hydrologics 2004) and again in the Existing Creek Hydrologic Analysis included in the Draft EIR
(Appendix H.2).
The “Total Creek Flow” table shown on page 2 of the Existing Creek Hydrologic Analysis
indicating total creek flow and overflow flow rate (overbanking) for “historic” conditions (defined
as before 2013), “existing” as the current condition that exists today, and “proposed” which
represents the Project, are included below:
Creek Flowrate (Overflow Flowrate) (cfs)
Historic Existing Proposed
2-year 253.3 (100) 253.3 (0) 518.7 (0)
10-year 521.5 (318) 521.5 (89.4) 707.3 (188.6)
25-year 714.3 (475.2) 714.3 (282.2) 877.2 (358.5)
50-year 867.6 (599.3) 867.6 (435.5) 1098.1 (579.4)
100-year 980.4 (691) 980.4 (548.3) 1240.8 (722.1)
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01934
The capacity of the Calle Joaquin wetlands is analyzed thoroughly as part of the HEC–RAS
analysis contained in the PHHC report. The overall capacity of the proposed detention basin on
Mountainbrook Church property, the developed areas within the Project site, and the Calle Joaquin
wetlands is defined in Table 1-3 of the PHHC. The Project as designed provides approximately
31.895 acre-feet of storage; this amount is in excess of the 16.991 acre-feet of required storage
volume calculated by the Applicant. The storage volume for the Project is shown in Table 1-3 and
described in the text on page 1-11 of the PHHC. The calculations utilize the HEC-HMS program
as described on Page 1-3 of the PHHC and outlined in Appendix 3. The areas in the calculations
are graphically shown in Appendix 2 in the “watershed analysis” exhibit, and include the Irish
Hills Plaza, Costco, the upper tributaries, and the Project site.
The proposed low-flow swale as designed also conveys up to a 2-year event within the bottom of
the proposed Froom Creek corridor. The PHCC report concludes that the corridor adjacent to
LOVR and the Calle Joaquin wetlands in conjunction with the Mountainbrook Church basin
significantly improve (reduce) the flooding potential throughout the area. The PHHC report is
based on the discharge capacity of the existing U.S. Highway 101 box culverts (a 10-year storm
event).
The PHHC includes analysis of the creek corridor up to and including the 100-year storm event
with additional embankment allowance (freeboard). Regarding the potential for a sudden course
change of the creek (avulsion), the restoration component of the creek corridor allows for
meandering of the low-flow swale within the confines of the creek bed in a manner consistent with
natural creek corridors and the City of SLO Waterways Management Plan, Drainage Design
Manual (see Chapter 3 of the PHHC).
Comment Response O.1-3
The report prepared by Cleath-Harris Geologists titled “Groundwater Impacts Assessment”
(Appendix 7 of the PHHC) concludes that the realignment of Froom Creek will increase
groundwater recharge (page 6 “groundwater recharge impact”) and that groundwater levels will
not be significantly altered by the Project (page 5 “Impact Assessment” 2nd paragraph). The
Cleath-Harris report concludes that groundwater is the primary source of water for the Calle
Joaquin wetlands and the proposed creek realignment does not alter that function. The design of
the creek corridor is above groundwater levels determined in the Cleath Harris report and allows
for groundwater recharge. Based on the Cleath-Harris report, the realigned creek corridor would
not intercept groundwater at any location. The Cleath-Harris Groundwater report (PHHC appendix
7) concludes that groundwater levels will not be significantly impacted as a result of the Project.
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01935
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
The proposed creek corridor integrates the wetland area into the creek ecology in a manner
consistent with functional wetland habitat.
In addition, the EIR identifies the potential for changes to the Calle Joaquin wetlands as a result
of the changes in the site’s hydrology. MM BIO-5 requires the Applicant to prepare a Long-Term
Wetland Monitoring Plan for documenting and mitigating any adverse changes to the Calle
Joaquin wetlands that occur over the course of development under the Specific Plan. Significant
loss or adverse change to the Calle Joaquin wetlands would require compensatory mitigation if
observed over 7 years of required monitoring and reporting.
Comment Response O.1-4
The comment reiterates the requirements of the City’s Creek Setback Ordinance (Municipal Code
Section 17.70.030) and CNPS’s opinion that the Project would constitute a special privilege for
exception to the City’s Creek Setback ordinance, which is not allowed. This comment is related to
an issue of policy interpretation and does not specifically relate to any physical change to the
environment or the analysis in the EIR. Additional discussion regarding the Project’s consistency
with the City’s Creek Setback requirements is provided in Section 3.9, Land Use and Planning.
The realignment of Froom Creek and the Project’s final consistency with City policy and setback
requirements will be subject to final review and approval by City decision makers. The comments
related to the City’s Creek setback ordinance will be provided to policy makers in the decision
process.
The EIR also addresses flooding and potential impacts to the Calle Joaquin wetlands. As discussed
in Section 3.8, Hydrology and Water Quality, the proposed realignment of Froom Creek has been
designed with features such as ditches, retention and detention basins, and drainage conveyance
systems, which would avoid flooding and retain runoff in compliance with the City’s Drainage
Design manual and the Central Coast RWQCB Post-Construction Runoff requirements. Based on
the analysis prepared by RRM Design Group, all on- and offsite stormwater detention and control
measures are adequately sized to detain on- and offsite flows, consistent with the City’s Drainage
Design Manual requirements for attenuation of runoff from 2-year through 100-year events.
Implementation of these measures would adequately attenuate all Project stormwater peak flows
and even slightly reduce peak flows at the U.S. 101 double box culvert. Due to the reduction in
peak flows at the U.S. 101 box culvert, realignment of the creek and implementation of the Project
would reduce flooding potential in the Project vicinity.
In addition, the EIR identifies the potential for changes to the Calle Joaquin wetlands as a result
of the changes in the site’s hydrology. MM BIO-5 requires the Applicant to prepare a Long-Term
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Wetland Monitoring Plan for documenting and mitigating any adverse changes to the Calle
Joaquin wetlands that occur over the course of development under the Specific Plan. Significant
loss or adverse change to the Calle Joaquin wetlands would require compensatory mitigation if
observed over 7 years of required monitoring and reporting.
Comment Response O.1-5
The comment expresses concern regarding lack of detail in the EIR on the relocation of the Irish
Hills Detention Basin and the viability of the proposed replacement stormwater detention feature
to act as a functioning wetland. The proposed stormwater basin at Mountainbrook Church is not
proposed to act as a functioning wetland or to provide for emergent wetland vegetation; it is solely
a flood control and drainage facility. The proposed basin would be regularly maintained/graded to
ensure it continues to operate properly and provide the necessary stormwater detention capacity
for the site. The proposed basin is not designed to provide wetland habitat and is not intended to
mitigate any direct impacts to existing onsite wetlands.
The existing stormwater detention facility is required to be maintained and has been subject to
periodic maintenance over the last 15 years. This basin is not identified as a jurisdictional feature
in the Preliminary Jurisdictional Determination prepared for the Project and approved by USACE
on September 24, 2015. Although wetland features occur in wet years, periodic basin maintenance
to provide retention capacity removes this as permanent vegetation. During preparation of the
Draft EIR, the stormwater basin was not functioning (draining) properly, which allowed water to
stay in the basin for longer periods of time, thus facilitating development of wetland habitat within
the basin. The Draft EIR conservatively considered these wetland features as jurisdictional and
required mitigation for their removal.
Subsequent to circulation of the Draft EIR for public review, the City consulted further with
USACE and RWQCB regarding the EIR’s evaluation of the wetlands that had established within
the stormwater basin and both agencies indicated that they would not consider them to be
jurisdictional waters or wetlands due to the fact that the basin was man-made and located entirely
in upland habitat; therefore, the location of the basin would not have the potential to support
wetland vegetation if not for the man-made condition created by diversion of the Irish Hills Plaza
stormwater it retains and treats. During consultation in February 2020, Jerry Hidalgo, Project
Manager of the USACE North Coast Branch Regulatory Division, confirmed that USACE would
recommend a Jurisdictional Determination be prepared that showed the basin as a non-
jurisdictional feature for USACE approval, which would allow the landowner to maintain the basin
as needed without the need for a regulatory permit. This recommendation is consistent with the
prior Preliminary Jurisdictional Determination prepared for the Project (approved by USACE
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01937
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
September 24, 2015). In March 2020, the City consulted further with Kathleen Hicks,
Environmental Scientist with the Central Coast Regional Water Quality Control Board, who was
generally supportive of the approach suggested by USACE.
Mitigation for removal of wetlands within this basin is also not required by City policy. COSE
Policy 8.6.3, Required Mitigation, provides mitigation requirements for “natural habitat”:
For natural habitat that is relatively limited in extent (such as riparian or wetland habitat)
mitigation shall consist of creating twice the area of habitat lost, of equal quality, in the following
order of preference:
1. The same kind on the same site.
2. The same kind on a different site (the site shall be within the San Luis Obispo planning
area).
3. A similar kind (such as seasonal wetland in place of freshwater marsh) on the same site.
4. A similar kind on a different site (the site shall be within the San Luis Obispo planning
area.
Therefore, City policy requires mitigation only for natural habitats.
The EIR has been clarified to accurately identify these wetlands as non-jurisdictional features.
Mitigation in the form of replacement wetlands would not be required for these man-made features,
which is consistent with regulatory agency guidance and City policy which addresses natural
habitats only. It should be noted, however, that the Project would still be required to obtain a
regulatory permit from CDFW, which is the agency that regulates habitat for sensitive species
within the state. The Project would be required to comply with any terms and conditions of the
CDFW permit. In addition, natural wetlands within the Project site that would be temporarily or
permanently impacted by Project development would be required to be mitigated at minimum
ratios of 1:1 for temporary impacts and 3:1 for permanent impacts.
The Project proposes to detain and treat discharges from the Irish Hills Plaza in a basin as a
component of the “Home Depot Ditch”, described on page 1-9 of the PHHC, located adjacent to
the northerly property line upstream of the LOVR ditch. The detained flow is released into the
LOVR ditch for approximately 800 feet prior to entering Froom Creek. With regard to concerns
for flood risk resulting from implementation of the proposed Project and associated flood
management features, please refer to Comment Response O.1-4.
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01938
Comment Response O.1-6
The proposed alignment of the Froom Creek corridor has been designed to effectively manage the
flood risk for the Project area. The creek corridor would convey the 100-year storm event and the
low-flow swale proposed for the creek bottom is designed to convey up to a 2-year storm. The
low-flow conveyance will maintain consistent functionality of the creek corridor prior to
overbanking into the Calle Joaquin wetland or into the downstream Mountainbrook Church basin.
Additionally, the rehabilitation of the LOVR ditch combined with the new alignment of Froom
Creek is anticipated to alleviate localized ponding that occurs at the intersection of Calle Joaquin
and LOVR (near the U.S. 101 on-ramp) since the low-lying very flat areas adjacent to LOVR
subject to stormwater migrating into the street will be eliminated through the required widening of
LOVR along the Project’s frontage.
The PHHC and supplementary reports analyzed the watershed in the context of the larger San Luis
Obispo watershed and comprehensively included use of the City hydrology modeling for the upper
Froom Creek and Irish Hills watershed. The PHHC and accompanying reports comply with
established standards and engineering practice for analysis of hydrologic and hydraulic conditions
(Drainage Design Manual and Regional Water Quality Control Board Post Construction
Stormwater Requirements).
Comment Response O.1-7
The comment expresses concern over the proposed amendment to the open space and agricultural
conservation easement at the Project site. As discussed in the EIR Section 3.2, Agricultural
Resources, the 2010 annexation and development of Prefumo Creek Commons project across
LOVR from the Project site established an open space and agricultural conservation easement of
a 7.1-acre portion of the Project site to meet LAFCO Policy 2.9.12, Agricultural Policies. The
easement is managed by the City and may be amended with written consent of Irish Hills Plaza,
LLC, and the City. The open space and agricultural conservation easement allows for amendment
of the easement with the consent of the City and the landowner (per Item 14 of the recorded
document) and states that the easement may be used for wetland mitigation, relative item 3 of the
recorded document. The easement is proposed to remain the same size (at minimum) as the original
easement but would more closely align with the current wetland habitat it was initially intended to
protect. The proposed amended easement area would permanently protect a minimum of
approximately 5.8 acres of onsite wetlands (see also, Section 3.4, Biological Resources and
Appendix E).
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01939
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
LAFCO has also commented that the proposed reconfiguration of the 7.1 acres that are already
under a conservation easement appears to be consistent with the original condition. Please refer to
Section 3.2, Agricultural Resources and Section 3.9, Land Use and Planning for a comprehensive
analysis of the easement.
Comment Response O.1-8
The comment provides recommendations to City decision makers regarding approval of the
Project, portions of the Project, or Project alternatives analyzed in the EIR. These comments will
be included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.1-9
The comment provides recommendations to City decision makers regarding approval of the
Project, portions of the Project, or Project alternatives analyzed in the EIR. These comments will
be included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.1-10
The comment provides recommendations to City decision makers regarding approval of the
Project, portions of the Project, or Project alternatives analyzed in the EIR. These comments will
be included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.1-11
The comment provides recommendations to City decision makers regarding approval of the
Project, portions of the Project, or Project alternatives analyzed in the EIR. These comments will
be included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.1-12
The Applicant has included regulatory agencies in discussion of the proposed realignment of the
Froom Creek corridor, including those mentioned in this comment letter, and anticipates
processing the final construction documents through the appropriate regulatory agencies, as well
as the City of San Luis Obispo for final approval and implementation. See Section 2.5, Required
Approvals.
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As disclosed in Section 2.5, Required Approvals, phased development of the FRSP will require
other permits and required approvals or participation agreements from public agencies required to
implement the Project including:
•U.S. Army Corps of Engineers (USACE) Nationwide or Individual Permit (depending on
acreage of total disturbance within jurisdictional areas);
•California Department of Fish and Wildlife (CDFW) Streambed Alteration Agreement;
•RWQCB Section 401 Water Quality Certification, National Pollutant Discharge
Elimination System (NPDES) Permit;
•U.S. Fish and Wildlife Service (USFWS) consultation, Biological Opinion, possible
incidental take permit(s), and protocol surveys;
•National Oceanic and Atmospheric Administration Fisheries (NOAA Fisheries)
consultation and possible incidental take permit(s);
•FEMA – Conditional Letter of Map Revision (CLOMR)/Letter of Map Revision (LOMR);
•California Department of Transportation (Caltrans) for any needed improvements within
the Caltrans right of way;
•San Luis Obispo County Air Pollution Control District (APCD) – construction and/or
operational permits, grading permits, and fugitive dust regulation compliance; and
•Encroachment permits, and approval of improvement plans by the County for portions of
the Project’s infrastructure to be developed outside of the City limits, namely the proposed
stormwater detention basin and associated adjacent streambed alterations.
The wetland area on the south side of Calle Joaquin is proposed to be protected in place. The level
piping that allows water to migrate under the road to the south side of Calle Joaquin is to remain
unchanged. It is not a required component of the proposed drainage program. In addition, this area
is proposed to be permanently protected for wetland habitat under the amended onsite agricultural
conservation and open space easement as discussed above in Comment Response O.1-7.
8-92
01941
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O.2-1
O.2-2
8-93
01942
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O.2-2
cont.
O.2-3
O.2-4
8-94
01943
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O.2-5
O.2-6
O.2-7
O.2-8
8-95
01944
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h
O.2-8
cont.
O.2-9
O.2-10
O.2-11
8-96
01945
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O.2-11
cont
O.2-12
O.2-13
8-97
01946
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O.2-13
cont.
O.2-14
8-98
01947
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UC0JU;VH.(??Z\(C\;AIKHV0A0CP\HV0K\P:0\.UKK0CP\0(O0A0CP\ '0\OU990OP\P:(P\P:0\/0/;.(P;HC\H1\
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(PUK(?\$0O0KV0\:0?/\-Z\P:0\ (C/\HCO0KV(C.Z\H1\%(C\ U;O\"-;OIH\HUCP[\(C/\0YI(C/;C9\P:0\
(9K;.U?PUK(?\.HCO0KV(P;HC\0(O0A0CP\(O\IKHIHO0/\A;9:P\A00P\P:;O\P0OP \
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O.2-14
cont.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.2 Comment Letter O.2 – California Native Plant Society (2)
Comment Response O.2-1
Thank you for your comments regarding the proposed FRSP and EIR. Detailed response to each
discrete comment identified in this letter are provided in the following responses. With regard to
support of adoption of Alternative 1, these comments will be included within the public record and
will be made available to the City decisionmakers for planning and policy consideration.
Comment Response O.2-2
The comment expresses support for adoption of Alternative 1, which proposes all development
with the exception of the public park be located below the 150-foot elevation line, consistent with
City hillside planning policies. These comments are consistent with the EIR’s analysis of
Alternative 1 and do not directly pertain to the analysis presented in the EIR, but will nonetheless
be included within the public record and will be made available to City decision makers for
planning and policy consideration.
Comment Response O.2-3
Please refer to Comment Response O.1-7. Comments regarding opposition to the proposed
Project’s alteration of the open space and agricultural easement will be included within the public
record and made available to the City decisionmakers for planning and policy consideration.
Comment Response O.2-4
Please refer to Comment Response O.1-5. As described, the EIR has been clarified to accurately
identify the wetlands within the existing onsite detention basin as non-jurisdictional features.
Mitigation in the form of replacement wetlands would not be required for these man-made features,
which is consistent with regulatory agency guidance and City policy which addresses natural
habitats only.
Comment Response O.2-5
This comment expresses support for MM BIO-13, which requires a 300-foot buffer centered along
the centerline of the confluence of Drainages 1, 2, and 3 with Froom Creek to preserve that area’s
function as a wildlife corridor. Please also refer to Comment Response S.3-2. The comment
provides recommendations to City decision makers regarding approval of the Project, portions of
the Project, or Project alternatives analyzed in the EIR. These comments will be included within
the public record and will be made available to the City decisionmakers for planning and policy
consideration.
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Comment Response O.2-6
This comment expresses support for the Project Applicant’s stated intent to eliminate requested
development above the 150-foot elevation, which would protect Chorro Creek bog thistle and other
special status plant species populations in the Upper Terrace. The comment provides
recommendations to City decision makers regarding approval of the Project, portions of the
Project, or Project alternatives analyzed in the EIR, including Alternative 1. These comments will
be included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.2-7
The comment asserts that the Project’s statement that realignment of Froom Creek would benefit
south-central California coast steelhead is problematic as consistent surface water flow would not
be feasible without excavation to a depth that would impact local groundwater supplies and in turn,
the Calle Joaquin wetland. As described in the Section 3.4, Biological Resources, Froom Creek,
including the portion extending through the Project site, is designated critical habitat for the
federally threatened south-central California coast steelhead distinct population segment (DPS)
(steelhead; Oncorhynchus mykiss) by USFWS (Appendix E; USFWS 2018). Within the Project
site, Froom Creek has the potential to provide suitable habitat for steelhead passage during years
of high rainfall when flowing water is present. However, steelhead are not expected to spawn
onsite given seasonally dry conditions, and it is expected that steelhead would typically only use
this portion of Froom Creek as a movement corridor to areas of more suitable upstream habitat
(Appendix E).
The existing creek section through the Project site is composed of a cobble and gravel bed and
does not support riparian vegetation. As described in the FRSP and EIR Section 2.0, Project
Description, the proposed low-flow channel of the realigned creek would be constructed to
meander and to aid and control fish migration passage through a series of constructed stepped
pools and terraces throughout the realigned segment. Restoration and planting of riparian species,
provision of shade of the creek channel, and creation of stepped pools and terraces would promote
prolonged retention of water within the channel and would improve ability for fish to migrate
through the creek compared to existing conditions. However, as noted by the commenter, the
Project assumes Froom Creek would continue to be subject to seasonal rainfall, which would result
in intermittent flows with potential ability to support steelhead and other special status species
during periods of higher flows.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response O.2-8
The comment states the Draft EIR needs to discuss the extent and character of the Froom Creek
banks in greater detail so potential impacts to riparian woodland can be adequately evaluated.
Please refer to Chapter 3 of the PHHC (Froom Creek Restoration Program), which includes: a
species list of 15-gallon trees and one-gallon shrubs and groundcover within the riparian buffer; a
species list of one-gallon shrubs and groundcover proposed for planting along the channel banks;
and a list of species proposed for the channel bottom (refer to PHHC Section 3.6 Froom Creek
Restoration Plant List). Conceptual sections of the creek realignment are shown in PHHC Section
3.7 (Froom Creek Restoration Sections); this description notes that “boulders, cobbles, logs, and
embedded tree roots will be placed in key locations along the Channel Bank and Channel Bottom
to provide habitat areas.” In the area of the bridge crossing, a “Conspan” natural bottom culvert is
proposed, and would be “enhanced with a railing and decorative concrete, and armored with
boulders, cobble and vegetation.” Further, MM BIO-5 requires riparian vegetation along Froom
Creek to be maintained in perpetuity to the satisfaction of the City by the Applicant or a City-
approved designee. Froom Creek conditions shall be monitored annually following winter storm
seasons to assess damage to riparian vegetation and need for maintenance restoration. Monitoring
and maintenance of riparian vegetation conditions shall be conducted consistent with the
requirements of the Habitat Mitigation and Monitoring Plan outlined in MM BIO-3.
Comment Response O.2-9
The comment requests additional detail supporting the proposed roadway widening along the
LOVR Project frontage and confirmation that potential biological impacts related to these
improvements have been adequately addressed in the EIR. The Project proposes widening along
the west side of LOVR to provide width for a southbound right-turn lane, a bus turnout, and dual
northbound left-turn lanes at the LOVR/Auto Park intersection. In addition, MM TRANS-9
requires that the Project construct sidewalks and Class IV bike lanes (protected bike lanes) along
the Project frontage, MM TRANS-19 recommends installation of a raised median within the
existing two-way left-turn lane along LOVR between Irish Hills Plaza and Calle Joaquin, and MM
TRANS-22 requires installation of a protected intersection at the LOVR/Auto Park intersection.
MM TRANS-22 also requires that only a single northbound left-turn lane be provided at the
LOVR/Auto Park intersection to reduce unnecessary roadway widening. The justification for each
of these roadway features is provided as follows:
• Southbound Right-Turn Lane at LOVR/Auto Park – Right-turn lanes are recommended at
major intersections on high-speed roads, such as LOVR (40 mph posted speed), to reduce
potential for rear-end collisions by allowing right-turning vehicles to decelerate in a lane
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separate from faster-moving through traffic and if needed, stop to yield to pedestrians and
bicyclists crossing the side street.
• Northbound Left-Turn Lane at LOVR/Auto Park – The Project is proposed to widen LOVR
to provide width for dual northbound left-turn lanes at the intersection with Auto Park. The
Project Transportation Impact Study analyzed this intersection in detail and concluded that
a single left-turn lane would provide for acceptable operations. For this reason, MM
TRANS-22 requires that the Project only design for a single left-turn lane to minimize
roadway widening and shorten crossing distances for pedestrians. LOVR has an existing
two-way left-turn lane; thus, the additional roadway widening needed to maintain a single
northbound left-turn lane is minimal.
• Bus Turnout – The Project is proposing to construct a new southbound bus turnout and
stop on LOVR just south of the Auto Park intersection. This feature is consistent with City
policies to support access to sustainable transportation options and is necessary to provide
efficient access to public transit services for residents, employees, and visitors of the
proposed development.
• Sidewalk and Class IV Bike Lanes – MM TRANS-9 requires that the Project construct
sidewalks and Class IV bike lanes along the west side of LOVR between Irish Hills Plaza
and Calle Joaquin. These features are consistent with City policies to support safe
multimodal access and circulation and are consistent with the improvements identified in
the adopted Bob Jones Trail (Calle Joaquin to Oceanaire) Project Study Report, which
plans for sidewalks and Class IV bike lanes on both sides of LOVR along the Project
frontage. LOVR already includes Class II bike lanes with painted buffers from vehicle
traffic; thus, minimal roadway widening is required to provide Class IV bike lanes.
Widening is required to provide pedestrian sidewalks per City Standards.
• LOVR Medians – The FRSP Transportation Impact Study (Appendix J) reported that
LOVR between Froom Ranch Way and Calle Joaquin is ranked as one of the highest
collision rate arterial street segments in the City. To address collision trends and provide
consistency with City Access Management Policies, MM TRANS-19 recommends
installation of a raised median along LOVR along the Project frontage. The median is
intended to restrict left-turn access along this high-speed arterial street, provide traffic
calming benefits to reduce high-end speeds, and provide a refuge area for pedestrians at
the LOVR/Auto Park intersection to improve pedestrian crossing safety with addition of
the Project. The existing two-way left-turn lane along LOVR provides the majority of the
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
width needed for the proposed median; however, some additional widening is required to
accommodate this improvement.
The secondary impacts of these mitigation measures and the widening of LOVR, which would
result in the loss or disturbance of existing riparian areas along the boundary of the Project site and
within the LOVR ditch are evaluated in Section 3.4, Biological Resources. As discussed therein,
Project construction would result in permanent direct loss of 1.13 acres of Arroyo Willow Riparian
Scrub through realignment of the existing LOVR ditch, widening of LOVR, construction of a new
Project entrance road and culvert, realignment of Froom Creek and construction of the proposed
stormwater detention basin on the Mountainbrook Church property. The design of the road
widening required under MM TRANS-9 would result in an estimated 19,300 square feet (sf) of
additional pavement area extending into the Project site, resulting in an estimated 18,425 sf of
disturbance to the wetlands and riparian habitat located within the existing LOVR ditch and Calle
Joaquin wetlands. Based on the total area of disturbance associated with widening of LOVR to
accommodate this improvement, the secondary impact to sensitive riparian and wetland habitat is
estimated to be up to 25,000 sf (0.57 acre). Impacts to riparian species and habitat as a result of
these improvements would be subject to MM BIO-1, MM BIO-2, and MM BIO-4 through MM
BIO-6, which would require preconstruction surveys to determine the total area impacted,
avoidance where feasible, and on- or offsite restoration or replacement of affected areas.
Comment Response O.2-10
The comment reiterates the requirements of the City’s Creek Setback ordinance (Municipal Code
Section 17.70.030) and an opinion that the Project would constitute a special privilege for
exception to the City’s Creek Setback ordinance, which is not allowed. This comment is related to
an issue of policy interpretation and does not specifically relate to any physical change to the
environment or the analysis in the EIR. Additional discussion regarding the Project’s consistency
with the City’s Creek Setback requirements is provided in Section 3.9, Land Use and Planning.
The realignment of Froom Creek and the Project’s final consistency with City policy and setback
requirements will be subject to final review and approval by City decision makers. The potential
impacts of proposed realignment of Froom Creek have been comprehensively analyzed in Section
3.4, Biological Resources of the EIR. These comments will be included within the public record
and will be made available to the City decisionmakers for planning and policy consideration.
As discussed in Section 3.8, Hydrology and Water Quality, the proposed realignment of Froom
Creek has been designed with features such as ditches, retention and detention basins, and drainage
conveyance systems which would avoid flooding and retain runoff in compliance with the City’s
Drainage Design manual and the Central Coast RWQCB Post-Construction Runoff requirements.
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Based on the analysis prepared by RRM Design Group, all on- and offsite stormwater detention
and control measures are adequately sized to detain on- and offsite flows, consistent with the City’s
Drainage Design Manual requirements for attenuation of runoff from 2-year through 100-year
events.
As noted in Comment Response O.2-8, above, a Creek Restoration Program is provided in
Appendix H (PSSH, Chapter 3). Mitigation measures identified in the EIR require preparation and
implementation of a Habitat Mitigation and Monitoring Plan (HMMP) and compliance with
identified performance standards as verified by a retained qualified biologist (MM BIO-3, MM
BIO-5). MM BIO-6 requires a weed management plan and weekly maintenance of habitat
restoration and enhancement areas for three years following Project completion and quarterly
thereafter. These measures are recommended to ensure the creek realignment meets identified
performance standards for the establishment of riparian vegetation. Further, MM BIO-5 requires
riparian vegetation along Froom Creek to be maintained in perpetuity to the satisfaction of the City
by the Applicant or a City-approved designee. Froom Creek conditions shall be monitored
annually following winter storm seasons to assess damage to riparian vegetation and need for
maintenance restoration. Monitoring and maintenance of riparian vegetation conditions shall be
conducted consistent with the requirements of the Habitat Mitigation and Monitoring Plan outlined
in MM BIO-3.
Comment Response O.2-11
The proposed alignment of the Froom Creek corridor has been designed to effectively manage the
flood risk for the Project area. The creek corridor would convey the 100-year storm event and the
low-flow swale proposed for the creek bottom is designed to convey up to a 2-year storm. The
low-flow conveyance will maintain consistent functionality of the creek corridor prior to
overbanking into the Calle Joaquin wetland or into the downstream Mountainbrook Church basin.
Additionally, the rehabilitation of the LOVR ditch combined with the new alignment of Froom
Creek is anticipated to alleviate localized ponding that occurs at the intersection of Calle Joaquin
and LOVR (near the U.S. 101 on-ramp) since the low-lying very flat areas adjacent to LOVR
subject to stormwater migrating into the street will be eliminated.
The PHHC and supplementary reports analyzed the watershed in the context of the larger San Luis
Obispo Creek watershed and comprehensively included use of the City hydrology modeling for
the upper Froom Creek and Irish Hills watershed. The PHHC and accompanying reports comply
with established standards and engineering practice for analysis of hydrologic and hydraulic
conditions (Drainage Design Manual and Regional Water Quality Control Board Post Construction
Stormwater Requirements).
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
The Calle Joaquin wetland receives both surface and subsurface flow from Froom Creek in the
existing condition and in the future post-Project construction proposed condition. Project
development and surrounding storm drain facilities have been designed in a manner consistent
with engineering practices and the City of San Luis Obispo’s Drainage Design Manual. Storm
events up to the 100-year storm event have been analyzed and would be managed within the
confines of the open space and wetland areas within the Project site.
The Project proposes to detain and treat discharges from the Irish Hills Plaza in a basin as a
component of the “Home Depot Ditch”, described on page 1-9 of the Preliminary Hydrologic and
Hydraulic Calculations (PHHC), located adjacent to the northerly property line upstream of the
LOVR ditch. The detained flow is released into the LOVR ditch for approximately 800 feet prior
to entering Froom Creek.
The proposed Project’s detention basin has been designed to accommodate storage volumes for
Irish Hills Plaza, Home Depot, and potential future work at Mountainbrook Church (which makes
up approximately 4 acre-feet of the approximately 28 acre-feet of storage available in the proposed
basin; see Table 1-2 and written description on page 1-10 of the PHHC). The proposed stormwater
basin at Mountainbrook Church is not proposed to seasonally retain water or provide for emergent
wetland vegetation or habitat to develop within the basin, but would be managed as an upland area.
The proposed basin is not being considered as an area of wetland creation that would help mitigate
and direct impact to existing onsite wetlands. Although wetland features may occur in wet years,
maintenance of the basin would remove this as permanent vegetation. Refer to Comment Response
O.1-5. The proposed Froom Creek corridor has been designed to provide an opportunity to create
a riparian corridor along the entire length of the proposed alignment and to provide more
opportunity for habitat restoration than currently exists under existing conditions.
The Calle Joaquin wetland drains by gravity around the Marriott Courtyard hotel and toward the
U.S. 101 culverts; it does not remain in the wetland. The proposed low-flow swale conveys storm
events up to a 2-year event before overbanking into the wetland as it before it wraps around the
existing hotels. This is both the existing condition and the proposed condition.
In addition, the EIR identifies and mitigates for the potential for adverse changes to the Calle
Joaquin wetlands as a result of the changes in the site’s hydrology. MM BIO-5(d) has been revised
to require preparation of a Long-Term Wetland Monitoring Plan. The plan would require annual
evaluation of the condition of the Calle Joaquin wetland through the use of a regulatory agency
approved method throughout development under the Specific Plan to determine and document any
degree of change to the wetland as a result of the proposed changes in site hydrology and drainage.
In the event adverse changes to the wetland over the course of Project development and operation
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(e.g., extensive ponding that results in bare soils devoid of vegetation, increased
sedimentation/erosion from the realigned channel, bank failure), mitigation would be required to
modify the Project design in coordination with the City and appropriate regulatory agencies and/or
through on- or offsite mitigation at a minimum 2:1 ratio. This mitigation would be equally effective
in mitigating potential impacts to the Calle Joaquin wetlands and would ensure mitigation
requirements are proportionate with the ultimate level of change/impact, if any. Please refer to
Comment Response A.1-76.
Comment Response O.2-12
The design of the creek corridor is above groundwater levels determined in the Cleath Harris report
(PHHC appendix 7; EIR Appendix H) and allows for groundwater recharge. The realigned creek
corridor does not intercept groundwater at any location. The Cleath Harris Groundwater report
concludes that groundwater levels will not be significantly impacted as a result of the Project. The
proposed creek corridor integrates the wetland area into the creek ecology in a manner consistent
with functional wetland habitat. Please also refer to Comment Response O.1-3.
Comment Response O.2-13
The comment expresses support of the relocation of historic buildings and designation of the public
park area under Alternative 1 as evaluated and described in the EIR, and that such a proposal would
better align with City General Plan policies. These comments will be included within the public
record and will be made available to the City decisionmakers for planning and policy
consideration.
Comment Response O.2-14
The comment provides recommendations to City decision makers regarding approval of the
Project, portions of the Project, or Project alternatives analyzed in the EIR with regard to clustering
Project development below the 150-foot elevation line, permitting development of the existing
quarry and staging area as a public park and relocating historic structures to this location, and
preserving the “cove” area at the confluence of Drainages 1, 2, and 3 with Froom Creek. These
comments will be included within the public record and will be made available to the City
decisionmakers for planning and policy consideration.
The comment also recommends the EIR provide additional discussion and reasonable proof
regarding flooding and functionality of the realigned of Froom Creek, impacts from flooding and
loss of habitat from relocation of the Irish Hills Plaza detention basin, and justification for
realignment of the existing agricultural easement. For detailed response to each of these concerns,
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
please refer to Comment Responses O.1-5, O.1-7, O.2-3, O.2-4, O.2-10, O.2-11, and O.2-12,
respectively.
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O.3-4
8-113
01962
8.4.3.3 Comment Letter O.3 – Friends of Bob Jones Trail
Comment Response O.3-1
Thank you for your comments regarding the proposed FRSP and EIR. Comments regarding your
recommendation of the City-to-the-Sea multiuse trail do not directly pertain to the proposed
Project or the analysis presented in this EIR. Nevertheless, these comments will be included within
the public record and will be made available to the City decision makers for planning and policy
considerations.
Comment Response O.3-2
The comment expresses concern regarding the level of detail of the Bob Jones Trail provided in
the EIR. Section 3.13, Transportation and Traffic, provides discussion of the existing setting of
the Bob Jones Trail in Section 3.13.1.3, Existing Bicycle Facilities, including connection points,
duration, and plans for future trail extension. The Bob Jones Trail does not intersect with the
Project site, but is accessible via surface streets from the Project site to facilitate regional bicycle
connectivity. The EIR additionally considers the Bob Jones Trail under cumulative impacts as a
cumulative transportation project.
Through required participation in the Citywide Transportation Impact Fee Program, the proposed
Project would provide fair-share funding contributions towards the high-priority bikeway projects
included in the City’s Fee Program, which include planned segments of the Bob Jones Trail within
the City limits, and the crosstown Railroad Safety Trail. Per MM TRANS-8, MM TRANS-9, and
MM TRANS-22, the Project will also be required to construct physically-separated bicycle and
pedestrian facilities along the LOVR corridor, which improves access to the existing and future
Bob Jones Trail segments.
The City and this EIR consider the Bob Jones Trail an important regional bicycle facility, and
additional discussion regarding this bicycle facility have been added to relevant discussions in
Section 3.13, Transportation and Traffic.
Comment Response O.3-3
The comment expresses concern that the trip generation estimates by travel mode presented in the
Project Transportation Impact Study do not match the City’s General Plan Mode Share Targets,
which endeavor towards reducing the share of citywide trips made by single-occupant automobile.
The Project trip generation estimates are developed based on data from professional surveys of
similar types of land uses and based on existing City mode share data as referenced from the
American Community Survey and the City’s biennial traffic data collection program. While the
8-114
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Project will be required construct infrastructure (on- and offsite) and implement programs that are
likely to facilitate increased progress towards reaching the City’s long-term mode share targets,
for the purposes of a focused transportation impact analysis, it is important that the Project traffic
generation estimates reflect an accurate, if not conservative, estimate of multimodal traffic
anticipated to be induced by the proposed development.
The comment also expressed concern regarding timing and responsibility of offsite mitigation
measures. Mitigation timing can be challenging to describe for some offsite improvements, as
several of the proposed mitigation measures are consistent with improvements already planned as
part of other approved development projects or City-initiated capital improvement projects, but
have not yet been completed. The Project will be required to either participate in a fair-share
financial contribution towards said improvements, or in some cases, implement these
improvements if they have not yet been completed by others prior to Project occupancy. The
descriptions of the transportation mitigation measures have been refined in Final EIR Section 3.13,
Transportation and Traffic, to provide additional clarity regarding timing and responsibility for
mitigation improvements.
Comment Response O.3-4
The comment expresses concern regarding the adequacy of infrastructure along LOVR to facilitate
safe and comfortable pedestrian and bicycle access, particularly to and from the Bob Jones Trail.
As described in MM TRANS-8, MM TRANS-9 and MM TRANS-22, the Project will be required
to construct several onsite and offsite improvements to enhance safety and mobility for active
transportation users, including improved access to existing and future Bob Jones Trail segments.
As noted in the mitigation, these improvements will be required prior to first occupancy of the
development and include addition of protected bike lanes along LOVR (Descanso to South
Higuera), protected bike lanes along the primary site access road (Commercial Collector A), a
bicycle protected intersection at LOVR/Auto Park, and completing the sidewalk gap on the west
side of LOVR between Irish Hills Plaza and Calle Joaquin.
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COALITION PARTNERS:
Bike SLO County
Boys and Girls Club – South County
Cal Poly State University
Center for Sustainability
Food Science & Nutrition Department
Kinesiology Department
CenCal Health
City of San Luis Obispo Parks and Recreation
Community Action Partnership of SLO
Community Foundation of SLO County
Dairy Council of California
Diringer & Associates
First 5 San Luis Obispo County
Food Bank Coalition of SLO County
French Hospital Medical Center
HomeShareSLO
Lucia Mar Unified School District
One Cool Earth
Rideshare – Safe Routes to School
San Luis Sports Therapy
SLO Council of Governments
SLO County Departments:
Board of Supervisors
Health Commission
Planning and Building
Public Health
SLO County Office of Education
UC Cooperative Extension
YMCA of SLO County
HEAL-SLO is a community coalition addressing complex and overlapping health challenges through integrated solutions. In carrying out that
mission, a subcommittee called the Healthy Communities Work Group provides responses to Planning staff from a healthy community’s
perspective on proposed land development projects, ordinance and general plan amendments, and special projects.
December 20, 2019
Shawna Scott, Senior Planner
City of San Luis Obispo
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401
RE: Froom Ranch Specific Plan Draft Environmental Impact Report
Dear Ms. Scott,
The Healthy Communities Work Group has reviewed the Froom Ranch DEIR.
Overall, our group supports the “Actionable Alternative”, or “Alternative 1” of
the project design; however, we recommend the following improvements or
considerations to promote community health:
Include improvements to enhance bicycle and pedestrian safety.
The California Office of Traffic Safety ranked San Luis Obispo County as the 6th
worst county in the state for bicycle safety based on collision numbers1.
Bicycle safety was recently identified as a priority issue in the 2018-2023
Community Health Improvement Plan, including a specific objective to “reduce
the number of bicycle-involved motor vehicle collision injuries by 10% by Dec.
2020”.2 Additionally, only 28.8% of adults in San Luis Obispo County walk
regularly (150 minutes per week or more)3. Safe, accessible bicycle and
pedestrian infrastructure are critical to support and promote the health of
residents. The Healthy Communities Work Group recommends that a Class IV
bikeway is included along Los Osos Valley Road from Calle Joaquin to Froom
Ranch Road, in accordance with the recently adopted Bicycle Transportation
Plan. We also recommend the addition of a marked and signalized pedestrian
crossing at the intersection of Auto Way and Los Osos Valley Road. Finally, we
recommend that the City explore a secondary access point to LOVR or Calle
Joaquin to improve connectivity and provide an additional emergency
evacuation route.
Improve transit facilities/services to encourage use of public transportation.
Research has demonstrated that enabling potentially isolated populations,
such as seniors and the disabled, to utilize public transportation is critical to
promoting their social and mental health, allowing them to age in place and
maintain a critical support network4. The Healthy Communities Work Group
recommends that provisions are made to decrease bus headways to 10 or 15
minutes to better serve the transit-dependent population, and to attract non-
transit-dependent users.
O.4-1
O.4-2
O.4-3
8-116
01965
COALITION PARTNERS:
Bike SLO County
Boys and Girls Club – South County
Cal Poly State University
Center for Sustainability
Food Science & Nutrition Department
Kinesiology Department
CenCal Health
City of San Luis Obispo Parks and Recreation
Community Action Partnership of SLO
Community Foundation of SLO County
Dairy Council of California
Diringer & Associates
First 5 San Luis Obispo County
Food Bank Coalition of SLO County
French Hospital Medical Center
HomeShareSLO
Lucia Mar Unified School District
One Cool Earth
Rideshare – Safe Routes to School
San Luis Sports Therapy
SLO Council of Governments
SLO County Departments:
Board of Supervisors
Health Commission
Planning and Building
Public Health
SLO County Office of Education
UC Cooperative Extension
YMCA of SLO County
HEAL-SLO is a community coalition addressing complex and overlapping health challenges through integrated solutions. In carrying out that
mission, a subcommittee called the Healthy Communities Work Group provides responses to Planning staff from a healthy community’s
perspective on proposed land development projects, ordinance and general plan amendments, and special projects.
Maximize commercial/retail space as a resource to residents.
The inclusion of 100,000 sq/ft of commercial/retail space can provide
numerous services and benefits to residents; however, a 70,000 sq/ft hotel
does not serve residents or nearby communities. The Healthy Communities
Work Group recommends that the commercial/retail space is maximized to
provide services to residents, build community, and thus support health.
Thank you for this opportunity to provide comment.
Sincerely,
Stephanie Teaford
Chair, Healthy Communities Work Group
1 The CA Office of Traffic Safety Report (2015)
2 Community Health Improvement Plan, Injuries, pg 43
3 SLOHealthCounts.org, Adults Who Walk Regularly, 2014
4 The Role of the Built Environment in Healthy Aging: Community Design,
Physical Activity, and Health among Older Adults. Journal of Planning
Literature, 43-60.
O.4-4
8-117
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Comment Letter O.4 – Healthy Communities Work Group
Comment Response O.4-1
Thank you for your comments regarding the proposed FRSP, including support of Alternative 1.
These comments will be included within the public record and will be made available to the City
decisionmakers for planning and policy consideration.
Comment Response O.4-2
The comment requests that a series of bicycle and pedestrian safety improvements be provided
along LOVR and that a secondary access point be provided to LOVR or Calle Joaquin to improve
connectivity and emergency access. MM TRANS-8, MM TRANS-9 and MM TRANS-22 require
installation of these exact improvements, which include addition of Class IV protected bike lanes
along LOVR, bicycle protected intersection features at LOVR/Auto Park, and signalized
pedestrian crossings at LOVR/Auto Park with hi-vis crosswalk markings, bulb outs and median
refuges to improve the pedestrian crossing experience.
The Project includes several points of access for pedestrians and cyclists to connect with the
adjacent transportation network and land uses, including to the Irish Hills Plaza, along the primary
Project access road (Commercial Collector A), and via a secondary pedestrian/emergency access
point that connects Villaggio to Mountainbrook Church. Alternative 1, the Environmentally
Superior Alternative, also evaluated additional connection points to Calle Joaquin and from Froom
Creek Trail and Villaggio to LOVR south of the primary access road. The feasibility of a
connection to Calle Joaquin is constrained by wetlands and the existing (and proposed) Froom
Creek alignment. The Project would be required to meet City standards for emergency access and
safety.
Comment Response O.4-3
The comment recommends that provisions be made to decrease bus headways to 10 or 15 minutes
to better serve the transit-dependent population, and to attract non-transit-dependent users. The
Project proposes to install a new bus turnout and stop at the intersection or LOVR/Auto Park to
improve access to public transit service for Project residents, employees, and visitors. In addition,
the Villaggio Life Plan Community is proposed to provide free shuttle service to connect residents
and employees to other destinations in the City, including offsite transit services. The SLO Transit
2017-21 Short Range Transit Plan includes plans to improve frequency of bus service, including
doubling frequency along Routes 2A and 2B, which serve LOVR, decreasing headways from
roughly 60 to 30 minutes. SLO Transit is making progress towards implementing these
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
improvements through planned procurement of additional buses. Through participation in the
Citywide Transportation Impact Fee Program, the Project would be providing a fair-share financial
contribution towards SLO Transit fleet expansion, which is partially funded through the Fee
Program.
Comment Response O.4-4
The comment provides recommendations to City decision makers to consider replacing the
proposed 70,000-sf hotel with additional commercial and retail uses to maximize commercial and
retail space. Comments regarding opposition to elements of the proposed Project do not directly
pertain to the analysis of the EIR but will be included within the public record and will be made
available to the City decisionmakers for planning and policy considerations.
8-119
01968
From: Lisa Schott
Sent: Wednesday, December 11, 2019 4:55 PM
To: Wilbanks, Megan
Cc: Advisory Bodies
Subject: Planning Commission Letter
Attachments: Planning Commissionletter12.11.19 Froom Ranch.pdf
Please forward this letter to the Planning Commission
LlsaS.�)
Phone: .....
8-120
01969
O.5-1
O.5-2
O.5-3
8-121
01970
O.5-3
cont.
O.5-4
8-122
01971
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.4 Comment Letter O.5 – Los Verdes Park 1
Comment Response O.5-1
Thank you for your comments regarding the proposed FRSP and EIR. Comments regarding your
opposition to the proposed Project do not directly pertain to the analysis of the EIR but will be
included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.5-2
The comment notes that more recent traffic data needs to be used for the transportation analysis
and expresses concern regarding congestion at several study intersections. As discussed in detail
previously in Comment Response S.2-7, the existing traffic data utilized for the Project
Transportation Impact Study was collected in 2016 and was less than two years old at the time the
EIR NOP and traffic study were initiated in 2017, which is consistent with City and CEQA
guidelines. It should also be noted that the Transportation Impact Study includes a “near-term”
analysis scenario, which accounts for anticipated changes in traffic conditions within
approximately a five-year horizon from the “existing conditions” baseline. The intent of this
analysis scenario is to sufficiently consider potential Project-related transportation impacts that
may occur by Project occupancy, which includes additional growth in traffic volumes related to
already planned and proposed development within the study area. Some, but not all of this growth
has already occurred and is inherently reflected in the “near-term” scenario analysis findings and
mitigation recommendations. In addition, as noted in Comment Response S.2-7, per Caltrans’
request, a supplemental traffic analysis memo has been prepared to provide a more detailed
assessment of traffic operations and efficacy of proposed mitigation strategies along LOVR within
the vicinity of the LOVR/U.S. 101 Interchange. This supplemental analysis includes use of more
recent existing traffic volumes collected in February 2020 for this focused study. This analysis is
documented in a technical memorandum provided in the Final EIR Appendix M.
Regarding concerns with traffic congestion at the intersections of LOVR/Calle Joaquin,
LOVR/U.S. 101 Ramps, and LOVR/South Higuera, these intersections were evaluated in the
comprehensive Transportation Impact Study per the City’s adopted analysis procedures and
thresholds of significance. The EIR documents Project impacts and mitigation measures, where
required, for these intersections consistent with City and CEQA guidelines.
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Comment Response O.5-3
The comment notes that recent approved development within the City has resulted in cumulative
impacts to traffic, fugitive dust emissions, biological resources, changes in hydrology, noise, and
safety. The City understands these issues and, pursuant to the requirements of CEQA, fully
evaluates the direct impacts of the Project in the EIR, both individually as well as the cumulative
impacts of the Project and other development within the City. These impacts are evaluated in detail
within each of the respective resource analysis sections of the EIR. Mitigation measures, as
described in the EIR, include a discussion of the personnel responsible (e.g., City, Applicant, or
identified agency) for implementation, as well as any required approval processes prior to
implementation. The Mitigation Monitoring and Reporting Program (MMRP) adopted with the
Project by the City Council would ensure mitigation measures identified in this EIR would be
tracked by appropriate parties identified in the MMRP and implemented as required. Consistent
with CEQA Guidelines Section 15097, the MMRP identifies persons or parties responsible for
monitoring and reporting that the mitigation measures are being appropriately implemented, while
the City would be responsible for ensuring that mitigation measures occur in accordance with the
MMRP. Where significant direct or cumulatively significant impacts the Project are identified, the
EIR identifies and requires all feasible mitigation to reduce impacts to the extent feasible.
Comment Response O.5-4
The comment requests the Project 1) provide additional examination of CEQA Guidelines, 2)
examine more current LOVR traffic issues, and 3) hold developers accountable. The EIR provides
a comprehensive analysis of the proposed Project components through the use of CEQA
regulations and the most up to date thresholds adopted or employed by the City. Please refer to
Comment Response O.5-2 for discussion of Project’s traffic analysis. Comments regarding
opposition to the proposed Project that do not pertain to the analysis of the EIR will be included
within the public record and will be made available to the City decision makers for planning and
policy consideration.
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"&'
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MEETING DATE: 12/11/2019
ITEM NO: 2
Received
12/10/2019
SLO CITY CLERK
8-125
01974
O.6-1
O.6-2
O.6-3
8-126
01975
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.5 Comment Letter O.6 – Preserve the SLO Life
Comment Response O.6-1
Thank you for your comments regarding the proposed FRSP and EIR. Comments regarding your
opposition to the proposed Project do not directly pertain to the analysis of the EIR but will be
included within the public record and will be made available to the City decisionmakers for
planning and policy consideration.
Comment Response O.6-2
The comment notes that traffic studies need to utilize current traffic data and expresses concerns
with traffic congestion along LOVR, at the LOVR/U.S. 101 Ramps intersection, and at the
LOVR/South Higuera intersection. See Comment Response S.2-7 and Comment Response O.5.2,
which address these concerns. In addition, a supplemental traffic analysis memo has been prepared
to provide a more detailed assessment of traffic operations and efficacy of proposed mitigation
strategies along LOVR within the vicinity of the LOVR/U.S. 101 Interchange. This supplemental
analysis includes use of more recent existing traffic volumes collected in February 2020 for this
focused study. This analysis is documented in a technical memorandum provided in the Final EIR
Appendix M.
Comment Response O.6-3
The comment notes that recent approved development within the City has resulted in cumulative
impacts to traffic, fugitive dust emissions, biological resources, changes in hydrology, noise, and
safety. The City understands these issues and, pursuant to the requirements of CEQA, fully
evaluates the direct impacts of the Project in the EIR, both individually as well as the cumulative
impacts of the Project and other development within the City. These impacts are evaluated in detail
within each of the respective resource analysis sections of the EIR. Mitigation measures, as
described in the EIR, include a discussion of the personnel responsible (e.g., City, Applicant, or
identified agency) for implementation, as well as any required approval processes prior to
implementation. The MMRP adopted with the Project by the City Council would ensure mitigation
measures identified in this EIR would be tracked by appropriate parties identified in the MMRP
and implemented as required. Consistent with CEQA Guidelines Section 15097, the MMRP
identifies persons or parties responsible for monitoring and reporting that the mitigation measures
are being appropriately implemented, while the City would be responsible for ensuring that
mitigation measures occur in accordance with the MMRP. Where significant direct or
cumulatively significant impacts the Project are identified, the EIR identifies and requires all
feasible mitigation to reduce impacts to the extent feasible.
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December 23, 2019
Via E-Mail
City of San Luis Obispo
Community Development Department
Attn: Shawna Scott, Senior Planner
919 Palm Street
San Luis Obispo, CA 93401-3218
sscott@slocity.org
Re: Comments on Draft Environmental Impact Report for the Froom
Ranch Specific Pan (State Clearinghouse # 2017071033)
Dear Ms. Scott:
Please accept the following comments on the Draft EIR for the Froom Ranch
Specific Plan referenced above (“Project”), submitted on behalf of Preserve the SLO
Life and Los Verdes Park Unit One Homeowners Association. Preserve the SLO Life
is an unincorporated association of San Luis Obispo City and County residents and
business owners. Los Verdes Park Unit One Homeowners Association, Inc. is a
California non-profit corporation operating as the homeowners association for the
Los Verdes Park Unit One subdivision in San Luis Obispo. Members of both entities
live and/or own property in the Project vicinity and will be directly affected by any
adverse environmental impacts the Project may foreseeably cause. Our comments
and concerns follow, organized by impact category.
I. Biological Resources
The Draft EIR identifies several potentially significant impacts to biological
resources from construction and operation of the Project. These include permanent
loss of sensitive riparian, wetland, and native grassland habitats, as well as direct
impacts to special-status species. In nearly all instances, the Draft EIR identifies as
mitigation a requirement that the applicant submit a “Biological Mitigation and
Monitoring Plan” to the City for review and approval before grading permits are
issued and the final vesting tentative map is recorded. The Plan is meant to
incorporate “additional measures or requirements” recommended by the California
Department of Fish & Game, the U.S. Fish & Wildlife Service, the Regional Water
Quality Control Board, and NOAA Fisheries (aka NMFS), an “specify all mitigation
site locations, timing of surveys and activities, species composition, habitat
O.7-2
O.7-1
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December 23, 2019
Page 2
compensation, species avoidance measures, and other required information, including
identification of appropriate onsite construction staging locations.” The Plan is to be
reviewed by “a qualified Environmental Coordinator/qualified biologist.” Likewise,
for impacts stemming from the realignment of Froom Creek, the applicant is to
submit a “Froom Creek restoration plan that identifies measures for securing the
proposed low-flow channel berm along the stretch of Froom Creek proposed
adjacent to the Calle Joaquin wetlands to protect the bank from erosion and prevent
migration of the Froom Creek channel into these wetlands.” The Draft EIR
concludes that notwithstanding these requirements for pre-construction plan
submittals, impacts to biological resources will be significant and unavoidable.1
The Draft EIR has improperly deferred meaningful analysis and mitigation of
biological resource impacts in contravention of CEQA. Under Section 15126.4 of the
CEQA Guidelines, formulation of mitigation measures for impacts identified in an
EIR ordinarily may not be deferred. Only if the EIR identifies specific, objective
performance standards that can be feasibly accomplished in more than one way may
mitigation specifics be deferred to a future time. Even then, CEQA requires
mitigation to be demonstrably feasible, incorporated into the design of the project,
and legally enforceable. In the current case, the Biological Mitigation Monitoring Plan
and Froom Creek Restoration Plan do not meet the requisite requirements for
specificity, demonstrated feasibility and enforceability to warrant the proposed
deferral of formulation of precise mitigation measures. It is impossible, for example,
to gauge whether “additional measures or requirements” recommended by state and
federal resource agencies will be feasible, whether they can be incorporated into the
Project’s design, or be enforceable. There likewise will be no opportunity for the
public, sister agencies, or anyone other than City staff to review the Plans for
adequacy before they are approved by an amorphously “qualified” biologist before
grading permits are issued and habitat is irretrievably lost.
To the extent the deferral of formulation of precise mitigation measures is due
to a lack of sufficient detail in the applicant’s construction plans, as the Draft EIR
acknowledges is the case for wetland impacts, the City should require the applicant to
provide new plans that contain enough information to allow the City, with input
from the resource agencies and the public, to formulate actual mitigation measures
that will be feasible, effective, and legally enforceable. Please note that the Draft
EIR’s conclusion that these biological resource impacts are significant and
unavoidable has no bearing on the City’s duty under CEQA to thoroughly evaluate
1 Notably, with respect to wetlands, the Draft EIR states that “[d]ue to the lack of detailed
plans and setbacks for these minor drainages at this stage in the process, these wetlands could be
directly impacted through culvert-headwall installation and sedimentation from grading and
development, and the ability to reestablish and maintain rare plant species present within these areas
is unknown.”
O.7-2
cont.
O.7-3
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December 23, 2019
Page 3
and mitigate those impacts. An agency may not simply label an impact unavoidably
significant in order to dispense with analysis. Berkeley Keep Jets Over the Bay Committee v.
Board of Port Commissioners (2001) 91 Cal.App.4th 1344, 1371. The City should circulate
a revised Draft EIR containing these measures after they are formulated.
II. Air Quality/Health Risks
The Draft EIR correctly notes that the California Supreme Court has held that
with limited exceptions CEQA does not require an EIR to analyze impacts of the
existing environment on a proposed project. However, when a project includes both
residential and commercial components, as is the case with Froom Ranch, the EIR
must disclose, evaluates, and mitigate any impacts that the commercial component
may impose on the residential component. Specifically, if long-term operation of
commercial retail uses will result in the delivery truck traffic, then an assessment of
health risks from long-term exposure to the particulate component of diesel exhaust
(“DPM”) is necessary to gauge whether senior citizens or other sensitive receptors
occupying the site will be exposed to undue health risks in excess of applicable
significance thresholds. Likewise, if construction activities are to occur on site after
the senior housing is occupied, then construction emissions must be factored into a
risk assessment. Regardless, the City should update the Draft EIR to disclose the
number of diesel-fueled truck deliveries expected to occur at the Project site on a
weekly basis during both construction and operational periods, and model any health
risks to on-site receptors due to long-term exposure to DPM or other toxic air
contaminants.
The Draft EIR does not adequately assess potential cumulative air quality
impacts/health risks to off-site receptors living near the Project site and LOVR
and/or U.S. 101, which is less than 1,000 feet away. These thoroughfares, and the
commercial uses operating along them, likely generate DPM emissions that already
bring an elevated health risk to residents, and any additional DPM emissions
generated by Project construction and operation could be a cumulatively considerable
contribution to an already significant cumulative impact. A cumulative risk
assessment should be performed and circulated for public review and comment.
III. Noise
As with air quality/health risks, the Draft EIR should evaluate the impacts to
sensitive noise receptors in the senior housing component of the Project from noise
generated by delivery, loading, and unloading activities associated with the Project’s
commercial component. Depending on the number, frequency, and time of day of
heavy truck deliveries, and whether those truck carry top-mounted refrigeration units,
O.7-3
cont.
O.7-4
O.7-5
O.7-6
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Page 4
impacts to nearby on-site receptors could easily exceed the City’s residential noise
standards. If that is the case, mitigation or avoidance measures will be required.
IV. Traffic
The Draft EIR’s analysis of traffic impacts is highly complex, and does not
meet CEQA’s standards of readability to the general public. Nearly all EIRs this
office has reviewed for similarly scaled development projects have included tables
that plainly disclose a project’s share of projected future impacts to nearby roadway
segments and intersections. This Draft EIR lacks tables comparing, for example,
“Existing Without Project” conditions to “Existing With Project,” or “Future (2025)
Without Project” to “Future With project,” or similar tables documenting the
differences between Scenario 1 and Scenario 2 in the year 2025 analysis. This forces
the reader to print out multiple tables from the EIR and appendices and then try to
create their own tables in order to reveal the differences. Absent such table, the Draft
EIR does not meet CEQA’s standards for disclosure and analysis and hence fails as
an informational document.
In addition, there are two major development projects nearby, Avila Ranch
and San Luis Ranch, that include major additions to transportation infrastructure as
part of their plans. The Draft EIR’s analysis, claiming conservatism, analyzes the
Scenario 2 condition as the Near Term 2025 Condition baseline, a scenario that lacks
the fundamental Prado Road westerly extension and interchange revision, which
would mitigate the effects of these three major projects and cumulative regional
growth. This is contrary to CEQA’s requirement that the environmental baseline for
evaluating impact significance should be conditions as they exist at the time a notice
of preparation of the EIR is issued. The Draft EIR contains an existing conditions
analysis but not an existing plus Project analysis. It likewise does not disclose impacts
or mitigation measures in its Existing Plus Project analysis, leaving it to the 2025
Near Term analysis.
The 2025 Near Term analysis includes the San Luis Ranch and Avila Ranch
projects and significant transportation improvements required for their development,
but omits details of funding, environmental clearance and, where appropriate,
Caltrans or County approvals necessary for each of the improvements assumed in
either of the two Scenarios. Often, where several development projects are
contributing fair share funds to a roadway improvement that does not return the
condition to an acceptable level, but is arguably sufficient to mitigate a particular
project’s incremental contribution to the condition, several projects claim the whole
of the incremental mitigation even though they are only contributing a fair share to
the cost of the improvement. In this case, where the Draft EIR finds that traffic
impacts are significant and unavoidable, but also identifies some level of mitigation, it
O.7-6
cont.
O.7-7
O.7-8
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December 23, 2019
Page 5
impossible to determine whether this Project is overclaiming mitigation. The City
should revise the traffic analysis to cure the foregoing informational defects and
recirculate for further public review and comment.
Thank you for your consideration of these comments.
Yours sincerely,
M. R. WOLFE & ASSOCIATES, P.C.
Mark R. Wolfe
on behalf of Preserve the SLO Life and
Los Verdes Park Unit One Homeowners
Association
MRW:sa
O.7-8
cont.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.6 Comment Letter O.7 – Preserve the SLO Life and Los Verdes Park Unit 1 Homeowners
Association
Comment Response O.7-1
Thank you for your comments regarding the proposed FRSP and EIR. Detailed responses to the
discrete comments and concerns expressed in this letter are provided below.
Comment Response O.7-2
The comment suggests the EIR improperly deferred meaningful analysis of biological resource
impacts and does not meet CEQA Guidelines. However, the EIR provides a thorough and detailed
discussion of the Project’s potential biological impacts and associated required mitigation
measures in over 100 pages of analysis in Section 3.4, Biological Resources. Despite the claims
by the commenter, the mitigation measures identified in the EIR analysis to address biological
resource impacts do not constitute deferred mitigation under CEQA Section 15126.4. Mitigation
measures would be implemented in a phased manner as appropriate to link mitigating actions with
or in advance of Project development and associated impacts. The mitigation measures identified
in the EIR to address impacts to biological resources, namely those relating to preparation of a
Biological Monitoring and Mitigation Plan, include commonly required mitigation measures
adopted or implemented for similar types of development. These mitigation measures are
developed to reflect the programmatic nature of the Project, which involves adoption of a land use
and development program that would guide future development of the site and does not currently
propose specific development or design of any physical improvements. The Biological Monitoring
and Mitigation Plan would be required prior to any construction activities onsite. The mitigation
measures identified in the EIR were prepared with a sufficient level of detail to provide coverage
for the reasonable extent and type of development currently anticipated under the FRSP; however,
in some regards, detailed mitigation could not be formulated due to the lack of detail regarding
development under the FRSP. For instance, detailed plans reflecting the exact location, footprint,
or setbacks of proposed structures is not available, and specific detail regarding the exact area of
disturbance needing to be restored or replacement could not be included in these mitigation
measures. Despite these constraints, the mitigation measures identified in the EIR relating to
biological resources include an appropriate and sufficient level of detail required under CEQA and
to provide adequate opportunity for public and responsible agency approval. Consistent with the
requirements of CEQA, each of these mitigation measures includes detailed language identifying
required specific and objective performance criteria and for identifying success of the required
mitigation. For instance, MM BIO-3(f) specifies that success criteria for restored plants or habitat
shall be at least 70-percent survival of container plants and 70-percent relative cover by vegetation
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type. Where restoration fails to meet performance or final success criteria within 5 years, the
restoration shall be completed through an extension of the plans for an additional 2 years or at the
discretion of the City Natural Resources Manager. Further, mitigation measures identified in the
EIR require preparation and implementation of a Habitat Mitigation and Monitoring Plan (HMMP)
and compliance with identified performance standards as verified by a retained qualified biologist
(MM BIO-3, MM BIO-5). MM BIO-6 requires a weed management plan and weekly maintenance
of habitat restoration and enhancement areas for three years following Project completion and
quarterly thereafter. These measures are recommended to ensure the creek realignment meets
identified performance standards for the establishment of riparian vegetation. MM BIO-5 requires
riparian vegetation along Froom Creek to be maintained in perpetuity to the satisfaction of the City
by the Applicant or a City-approved designee. Froom Creek conditions shall be monitored
annually following winter storm seasons to assess damage to riparian vegetation and need for
maintenance restoration. Monitoring and maintenance of riparian vegetation conditions shall be
conducted consistent with the requirements of the Habitat Mitigation and Monitoring Plan outlined
in MM BIO-3.
Comment Response O.7-3
The comment suggests the City require the Applicant to provide new plans containing additional
information to allow the City to formulate feasible, effective, and legally enforceable mitigation
with regards to wetland impacts. Further, the comment states that the EIR’s biological resource
impact findings of “significant and unavoidable” do not have bearing on the City’s mandate under
CEQA to evaluate and mitigate impacts. Please also refer to Comment Response A.1-76.
With regard to the City’s responsibility in fully analyzing the impacts of the proposed Project
under CEQA, the EIR does in fact use a reasonable worst-case analysis to fully analyze the impacts
of the proposed Project in compliance with the requirements and guidance under CEQA. Impacts
of the Project are extensively analyzed in the over 800 pages of detailed discussion presented in
Chapters 3 through Chapter 5 of the EIR. Within this analysis, the EIR identifies the potentially
significant impacts of the Project, identifies all feasible mitigation that wholly or at least partially
offset or reduce impacts, and describes in detail the residual impacts resulting from implementation
of mitigation. In some cases, the mitigation identified within the EIR would not feasibly be able
to reduce Project impacts below the adopted threshold of significance and would result in a
significant and unavoidable impact on the environment. However, the EIR fully discloses these
impacts and the effectiveness, inadequacies, or infeasibility of mitigation in reducing Project
impacts. The mitigation measures identified in the EIR were prepared with a sufficient level of
detail to provide coverage for the reasonable extent and type of development which is currently
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
anticipated under the FRSP; however, in some regards, mitigation measures were formulated
programmatically to match the level of detail available regarding proposed development under the
FRSP, which is a broad based specific plan. For instance, mitigation measures are tailored to reflect
the level of detail available in proposed Project plans reflecting the general location, footprint, or
setbacks of proposed structures, with as much detail as possible regarding the estimated area of
habitat disturbance needing to be restored or replacement to the extent feasible in these mitigation
measures, consistent with the approach to a broad based specific plan. Consistent with the
requirements to address a specific plan, the mitigation measures identified in the EIR relating to
biological resources include an appropriate and sufficient level of detail required under CEQA and
to provide adequate opportunity for public and responsible agency approval. Consistent with the
requirements of CEQA, each of these mitigation measures includes detailed language identifying
required specific and objective performance criteria and for identifying success of the required
mitigation. For instance, MM BIO-3(f) specifies that success criteria for restored plants or habitat
shall be at least 70-percent survival of container plants and 70-percent relative cover by vegetation
type. Where restoration fails to meet performance or final success criteria within 5 years, the
restoration shall be completed through an extension of the plans for an additional 2 years or at the
discretion of the City Natural Resources Manager. Further, mitigation measures identified in the
EIR require preparation and implementation of a Habitat Mitigation and Monitoring Plan (HMMP)
and compliance with identified performance standards as verified by a retained qualified biologist
(MM BIO-3, MM BIO-5). MM BIO-6 requires a weed management plan and weekly maintenance
of habitat restoration and enhancement areas for three years following Project completion and
quarterly thereafter. These measures are recommended to ensure the creek realignment meets
identified performance standards for the establishment of riparian vegetation. MM BIO-5 requires
riparian vegetation along Froom Creek to be maintained in perpetuity to the satisfaction of the City
by the Applicant or a City-approved designee. Froom Creek conditions shall be monitored
annually following winter storm seasons to assess damage to riparian vegetation and need for
maintenance restoration. Monitoring and maintenance of riparian vegetation conditions shall be
conducted consistent with the requirements of the Habitat Mitigation and Monitoring Plan outlined
in MM BIO-3.
Comment Response O.7-4
The comment states the EIR failed to discuss and mitigate impacts of proposed commercial land
use on proposed onsite residential uses. Additionally, the comment requests that the EIR disclose
the number of diesel-fueled truck deliveries projected under the Project during construction and
operations. Though not required under CEQA, consideration and disclosure of potential adverse
air quality impacts to onsite residents during short-term construction are discussed in detail Section
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3.3, Air Quality and Greenhouse Gas Emissions. As discussed therein, the Villaggio Health Care
Administration building, and senior assisted living facilities would be occupied in 2022 during
Phase 3 and Phase 4 of Project construction in the Upper Terrace and Madonna Froom Ranch.
Results of the EIR’s air quality and greenhouse gas emissions modeling are presented in Appendix
D. As presented therein, the exceedance of SLO County APCD thresholds for short-term
construction diesel particulate matter (DPM) emissions is anticipated to occur during the period of
overlap of Phases 1, 2, and 3 of the Project when grading activities are expected to be the most
intense, well before occupancy of any residences at the Project site. As a result, construction-
related DPM emissions would not exceed adopted thresholds or present a substantial health risk
for residents of the site during construction of the Project. Further, operation-related DPM
emissions, including those resulting from operation of large commercial delivery trucks servicing
the proposed commercial uses, are expected to be well below SLO County APCD’s thresholds and
would not result substantial health risks to onsite receptors from long-term exposure to DPM or
other toxic air contaminants. The EIR accurately compares potential impacts against the existing
environmental baseline while also disclosing potential impacts associated with the future
environmental baseline post construction of initial phases.
The comment also asserts that when a project includes both residential and commercial
components it must disclose, evaluate, and mitigate any impacts that the commercial components
may have on the residential components during operation. The Project does not propose any
commercial uses that would result in operational emissions having adverse health effects on
residential uses. Commercial uses would entail retail, office and hotel uses developed consistent
with City land use restrictions (e.g., setbacks) and consistent with the City General Plan. The
allowable commercial uses under the Project would be similar to adjacent commercial uses in Irish
Hills Plaza to the north and the hotel properties to the south and would not generate substantial
emissions, such as DPM, which would adversely affect the health of existing or future nearby
residents. As proposed, the commercial uses would be compatible with residential uses, much like
other mixed-use commercial-residential development within the City. Further, commercial uses
that would generate emissions causing adverse health impacts to nearby sensitive receptors include
operations which would be required to acquire permits from SLO County APCD. These may
include gas stations, dry cleaners, auto body shops, and other operations involving the use of
chemicals or generate other emissions that are potentially harmful to human health. These types
of uses are not proposed by the Project. Therefore, evaluation of health risks associated with
proposed commercial land uses on proposed residential land uses is not required. During
subsequent approvals and permitting, City review would ensure that the anticipated mix of land
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
uses is consistent with those in the approved FRSP and inconsistent uses would either not be
permitted or subject to existing adopted regulations to protect the public health.
Comment Response O.7-5
The comment states the EIR does not adequately assess potential cumulative air quality impacts
and health risks offsite receptors in the Project vicinity. As described Section 3.3, Air Quality and
Greenhouse Gas Emissions, the Project site is located within 400 to 600 feet of the high traffic
U.S. 101. The California Air Resources Board (CARB) considers freeways and other “High Traffic
Roadways” with 100,000 vehicles per day (vpd) or more to constitute sources of DPM emissions
that may elevate health risks, and recommends sensitive receptors be located a minimum of 500
feet away from these sources. Under the proposed Project, the nearest sensitive receptors would
be located a minimum of 500 feet away, consistent with CARB guidance. Further, as discussed in
Comment Response O.5-4 above, Project construction and operation would not result in direct
substantial impacts from DPM emissions, nor would the Project result in significant cumulative
health risks associated with DPM emissions. A cumulative assessment of health risks from DPM
is therefore not warranted for the proposed Project. Further, as provided in the SLO County APCD
2017 Clarification Memorandum and as a result of the California Building Industry Association v.
Bay Area Air Quality Management District (2015) court decision, SLO County APCD no longer
requires that a Lead Agency prepare a Type B Health Risk Assessment (HRA) as part of the CEQA
process. Type B HRAs calculate health risk from the existing environment on a project’s sensitive
receptors, of which the most significant health risks are associated with diesel truck impacts from
high volume roadways (SLO County APCD 2017).
Comment Response O.7-6
The comment addresses the EIR evaluation of impacts to sensitive noise receptors living onsite
during construction. As discussed in this comment, onsite sensitive noise receptors would be
located onsite during Phase 3 and Phase 4 of construction activities and have the potential to be
adversely affected by noise-related impacts. Consideration and disclosure of potential noise-
related impacts on sensitive receptors located on the Project site during construction activities is
provided in the EIR. Please refer to Section 3.10, Noise for detailed discussion of these potential
effects.
Comment Response O.7-7
The comment states that the traffic analysis presented in the EIR is too complex to understand and
does not meet CEQA’s standards for readability to the general public. Section 3.13, Transportation
and Traffic provides a detailed evaluation of traffic impacts and summary of the Transportation
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Impact Study prepared by the City’s consultant (TJKM) and provided in Appendix J. Key
summary tables and written analysis to distill and summarize the findings of the Transportation
Impact Study are provided in the EIR. The tables requested by the commenter and provided in the
Transportation Impact Study consist of over 100 highly complex tables, many of which are several
pages in length. For these reasons, the City has determined that their inclusion in the EIR analysis
would diminish the readability of the EIR. The lack of these tables in Section 3.13, Transportation
and Traffic does not result in the EIR failing to meet CEQA standards for disclosure and analysis
as an information document, as the discussion provided in Section 3.13, Transportation and Traffic
provides a clear summary of the findings and conclusions of the Transportation Impact Study and
the Project’s impacts on transportation.
Comment Response O.7-8
The comment claims that the Draft EIR traffic analysis is inconsistent with CEQA requirements
because the Near-Term (2025) impact findings and mitigation recommendations assume that the
Prado Road Interchange is not yet in place. The Prado Road Interchange is a planned and
programmed capital improvement project with a targeted construction year of 2022. While there
is a chance that this project is fully funded and complete prior to occupancy of any portions of the
Project, because the interchange project is a very complex endeavor and is still in the
planning/design phase, there is a possibility that the construction schedule will slip due to
unforeseeable circumstances. The Project’s Transportation Impact Study analyzed two Near-Term
(2025) analysis scenarios: Scenario 1 assumes the Prado Interchange to be in place by Project
occupancy, while Scenario 2 assumes the Prado Interchange is not yet complete. Because Near-
Term (2025) Scenario 2 represents a more conservative, worst-case representation of traffic
conditions, this scenario was the basis for the impact and mitigation findings in the Draft EIR. If
completion of the Prado Interchange Project was assumed in the Near-Term (2025) scenario
impact analysis findings, the EIR would potentially fail to disclose the full range of potential
Project-related impacts. This approach taken is consistent with CEQA Guidelines and provides a
conservative and defendable analysis.
This comment also claims that the Draft EIR fails to disclose an Existing Plus Project analysis
scenario. This is not accurate, as both the focused Transportation Impact Study prepared by TJKM
provided in the Draft EIR Appendix J, and the Draft EIR Section 3.13, Transportation and Traffic
(see discussion under Impact TRANS-2) include discussion of Existing Plus Project impacts and
mitigations.
The comment also claims that the Near-Term (2025) analysis includes transportation
improvements and mitigation measures that are required by other approved development
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
projects—specifically the San Luis Ranch and Avila Ranch projects—and does not clearly
articulate details regarding funding, environmental clearance and what incremental contribution
towards these improvements the Project is responsible for. There are several transportation impacts
and mitigations identified in the Draft EIR that overlap with improvements that are already
required by previously approved San Luis Ranch and Avila Ranch development projects, and two
improvements that are planned to be implemented by the City as capital improvement projects.
This is reasonable because the improvements are regionally serving and would serve and reduce
impacts from all cumulative projects. For each of these Near-Term impacts where the Project has
a cumulatively significant contribution, the EIR mitigation recommendations dictate that the
Project is required to either implement the improvements or participate in a fair-share financial
contribution towards these improvements, with the fair-share mitigation contribution
commensurate with the Project’s incremental contribution to the impacted transportation facility.
The Project’s fair-share obligation towards each applicable improvement is identified in the
Transportation Impact Study prepared by TJKM, or is inherently captured through participation in
the City’s Transportation Improvement Fee Program, which levies fees to individual development
projects based on an established nexus to how much incremental traffic is generated by each
development. For additional clarity, the Section 3.13, Transportation and Traffic includes refined
discussion of timing, implementation responsibility, and fair-share participation for impacts and
mitigation strategies that overlap with obligations from other approved development projects.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.3.7 Comment Letter O.8 – Sierra Club Santa Lucia Chapter
Comment Response O.8-1
Thank you for your comments regarding the proposed FRSP and EIR. Comments regarding your
opposition and concerns of the proposed Project relating to impacts to biological resources are
addressed in detail in the following responses.
Comment Response O.8-2
The comment expresses concern over biological resource mitigation measures that require future
mitigation and monitoring plan creation and the lack of detail provided in the identified mitigation
measures that would allow for meaningful review and comment from the public on these measures.
The EIR provides a detailed discussion of the Project’s potential biological impacts and associated
required mitigation measures in Section 3.4, Biological Resources. The mitigation measures
identified in the EIR to address impacts to biological resources, namely those relating to
preparation of a Biological Monitoring and Mitigation Plan, include commonly required mitigation
measures adopted or implemented for similar types of development. These mitigation measures
are developed to reflect the programmatic nature of the Project, which involves adoption of a land
use and development program that would guide future development of the site and does not
currently propose specific development or design of any physical improvements. The mitigation
measures identified in the EIR were prepared with a sufficient level of detail to provide coverage
for the reasonable extent of type of development which is currently anticipated under the proposed
FRSP.
MM BIO-1 requires the preparation of a Biological Mitigation and Monitoring Plan to manage
construction- and operational-related avoidance, reduction, and mitigation measures for impacts
to sensitive natural communities and the sensitive species that rely on them, including pre-
construction surveys. MM BIO-2 requires the Applicant to retain a qualified Environmental
Coordinator/Biologist, subject to review and approval of the City, to oversee compliance with the
Biological Mitigation and Monitoring Plan for the Project. MM BIO-11 addresses special-status
wildlife species management and protection during Project implementation, including avoidance
strategies, worker training, and pre-construction surveys. Prior to Project earth-moving activities,
the Project would fulfill required mitigation measures related to biological surveys. These would
include pre-construction habitat and special status species surveys to ensure avoidance, adjustment
of development envelopes in response and required habitat replacement and replanting. Identified
mitigation measures provide as a high a level of detail as possible at the Specific Plan level and
clearly describe the requirements, detail, implementation, monitoring, and reporting of success of
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the mitigation to allow for meaningful review. The mitigation measures identified in the EIR were
prepared with a sufficient level of detail to provide coverage for the reasonable extent and type of
development which is currently anticipated under the FRSP. This includes detailed mitigation
measures that are commensurate with the level of detail available at the specific plan stage. Such
measures are flexible to address impacts associated with future detailed development plans that
refine the exact location, footprint, or setbacks of proposed structures. These measures are also
structured to be flexible to address specific details regarding the exact area of disturbance needing
to be restored or replaced when such precise details become available at the development plan
stage. The programmatic mitigation measures identified in the EIR relating to biological resources
match the level of detail available in the FRSP and include an appropriate and sufficient level of
detail required under CEQA to mitigate impacts and to provide adequate information for informed
opportunity for public and responsible agency comments and consideration. Consistent with the
requirements of CEQA, each of these mitigation measures includes detailed language identifying
required specific and objective performance criteria and for identifying success of the required
mitigation. For instance, MM BIO-3(f) specifies that success criteria for restored plants or habitat
shall be at least 70-percent survival of container plants and 70-percent relative cover by vegetation
type. Where restoration fails to meet performance or final success criteria within 5 years, the
restoration shall be completed through an extension of the plans for an additional 2 years or at the
discretion of the City Natural Resources Manager. Further, mitigation measures identified in the
EIR require preparation and implementation of a Habitat Mitigation and Monitoring Plan (HMMP)
and compliance with identified performance standards as verified by a retained qualified biologist
(MM BIO-3, MM BIO-5). MM BIO-6 requires a weed management plan and weekly maintenance
of habitat restoration and enhancement areas for three years following Project completion and
quarterly thereafter. These measures are recommended to ensure the creek realignment meets
identified performance standards for the establishment of riparian vegetation. MM BIO-5 requires
riparian vegetation along Froom Creek to be maintained in perpetuity to the satisfaction of the City
by the Applicant or a City-approved designee. Froom Creek conditions shall be monitored
annually following winter storm seasons to assess damage to riparian vegetation and need for
maintenance restoration. Monitoring and maintenance of riparian vegetation conditions shall be
conducted consistent with the requirements of the Habitat Mitigation and Monitoring Plan outlined
in MM BIO-3.
Where uncertainty exists regarding the success in restoration or replacement mitigation for certain
species or habitat, the EIR fully documents and accounts for these uncertainties in the analysis.
For instance, mitigation addressing impacts to the Nassella pulchra Herbacious Alliance would
involve avoidance, restoration, or enhancement of the habitat; however, the inability or difficulty
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
in successfully restoring this sensitive habitat is well documented, and as such, the EIR finds that
impacts to this habitat would be significant and unavoidable. Therefore, the EIR sufficiently
analyzed impacts of the Project on biological resources and identifies feasible and appropriate
mitigation consistent with the requirements of CEQA. For further detail related to the
comprehensive analysis of biological resources, please refer to Section 3.4, Biological Resources.
Comment Response O.8-3
The comment expresses concern regarding the realignment and revegetation of Froom Creek to
native riparian habitat and the uncertainty expressed in the EIR regarding the success of proposed
mitigation. As discussed in the EIR, the Project includes realignment and restoration of Froom
Creek, which may mitigate some of these losses of riparian habitat. If successful, and as shown in
the Applicant’s proposed restoration plan, the Project would result in the creation of riparian
habitat through the relocation and restoration of Froom Creek. As acknowledged in the comment
however, given the existing Froom Creek habitats and channel characteristics, successful
establishment of a riparian woodland and, its long-term survival may be challenging based on the
current plans proposed by the Applicant. As discussed in Section 3.4, Biological Resources, the
EIR categorizes the risks to riparian woodland habitat as potentially significant. Proposed
mitigation would require the Applicant to prepare and implement a Biological Mitigation and
Monitoring Plan that identifies construction and operational measures related to avoidance,
relocation, restoration, and/or enhancement of affected habitat, including riparian habitat located
along Froom Creek, the LOVR ditch, and the Calle Joaquin wetlands. To ensure restored riparian
vegetation along Froom Creek is successful in mitigation impacts of the Project, MM BIO-5
requires that the riparian vegetation along Froom Creek be maintained in perpetuity to the
satisfaction of the City by the Applicant or a City-approved designee by conducting annual
monitoring to assess for damage and maintenance restoration. With implementation of this
proposed measure, in conjunction with all other mitigation pertaining to the Habitat Mitigation
and Monitoring Plan outlined in MM BIO-3, associated impacts to riparian vegetation would be
reduced to the maximum extent feasible. The EIR adequately evaluates and discloses these
potential impacts, required mitigation, and residual effects in Section 3.4, Biological Resources.
Comment Response O.8-4
The comment states MM BIO-4 and MM BIO-5 create an analysis inconsistency of onsite habitat
restoration. As discussed under BIO MM-4, mitigation for impacted sensitive natural communities
that cannot be avoided shall be achieved through a range of options, for future City approval and
selection, including onsite restoration, enhancement, or creation; offsite restoration or creation of
suitable habitat at a 2:1 ratio per City General Plan policy; financial contribution of an in-lieu fee;
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or purchase of mitigation credits. The option of onsite restoration would only be selected if
determined feasible and would be required to be consistent with ratios provided in MM BIO-5.
The payment of an in-lieu fee program and/or purchase of mitigation credits at a USFWS and/or
CDFW-approved mitigation bank would contribute to wetland restoration, so this mitigation
would not result in unmitigated impacts to sensitive natural communities, as noted by the
comment. These forms of mitigation are considered appropriate by the City, USFWS, and CDFW
for addressing impacts to wetlands. Please refer to Section 3.4, Biological Resources, for further
analysis and specifics of sensitive wetland habitat mitigation measures.
Comment Response O.8-5
The comment expresses concern that the Project’s objectives are not in alignment with the City’s
Land Use Element (LUE) and General Plan, and that the EIR should evaluate a range of intensity
of residential and commercial development. While the EIR evaluates the impacts of the Project as
proposed in the Applicant’s application to the City and described in Section 2.0, Project
Description, the EIR also includes analysis of three alternative site configurations that change the
extent and intensity of the Project. Alternative 1 - Clustered Development Below the 150-foot
Elevation Alternative involves relocating and clustering proposed development within the Lower
Area and Madonna Froom Ranch areas of the Project site to substantially reduce the extent of site
disturbance and development and is the Environmentally Superior Alternative. Alternative 2 -
Residential Development Project Alternative would cluster proposed development in the Lower
Area and Madonna Froom Ranch areas of the Project site and would replace commercial uses with
residential uses to reduce intensity of proposed land uses. Alternative 3 – Minimum LUCE-
Compliant Alternative would involve a scaled back alternative consistent with the City’s LUCE.
This alternative would be most closely aligned with existing General Plan LUE standards and
minimum development policy framework for the site, and therefore, Alternative 3 provides the
EIR with sufficient investigation into a low-build option of development. Inclusion of these
alternatives provides analysis of a smaller footprint and low-build alternatives to consider
reductions in Project impacts through redesign.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.4 Individuals
[Insert Comment Letter I.1, David Chipping, page 1 of 5]
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I.1-12
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8.4.4.2 Comment Letter I.1 – David Chipping
Comment Response I.1-1
Thank you for your comments regarding the proposed Project. Section 3.9, Land Use and Planning
provides an evaluation of the consistency of the proposed Project with the City’s 2014 LUE. The
Draft EIR recognizes the proposed Project would be inconsistent with the City’s hillside protection
policies regarding the limitation to development to the 150-foot elevation line, so to address this
inconsistency, analysis of alternatives is comprehensively discussed in Section 5.0, Alternatives.
Alternative 1 – Clustered Development Below the 150-foot Elevation is identified as the
Environmentally Superior Alternative and is more consistent with hillside protection policies as
proposed development would be located below 150-foot elevation line, with the exception of the
proposed public trailhead park. For additional analysis and specifics on Alternative 1, please refer
to Section 5.0, Alternatives.
Focused comments regarding drainage-related issues of the proposed Project are addressed in
detail in the following responses.
Comment Response I.1-2
This comment notes a correct description of the historic creek alignment in Section 1.4 of the EIR,
which clarifies that the Project would not fully realign the creek to its historic location. The
“Preliminary Hydrology and Hydraulic Calculations” (PHHC) shows a very similar image (figure
1-2 on page 1-3) portraying the same historic alignment referenced in this comment letter. The
PHHC identifies the “Restored Froom Creek Corridor” as being aligned “more closely” to the
historic alignment and revegetated with native plants but it is not presented in the PHHC or EIR
as a significant historic restoration, consistent with this comment.
Comment Response I.1-3
The comment addresses potential for increased flow depth, decreased flow velocity, and increased
flood depths along Calle Joaquin wetland areas due to the proposed realignment of Froom Creek.
The figure referenced identifying the “Crossing Contour” and “Low Point” uses existing contour
115, which reflects the existing detention basin as a low point. Implementation of the Project would
place fill in this area, and the topography would slope from west (elevation 125 feet) to east
(elevation 120 feet) from the existing hillside towards LOVR. The proposed Project maintains
positive drainage at all points in the restored creek.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response I.1-4
The comment asks how will Froom Creek channel excavation affect subsurface water conditions
in the Calle Joaquin wetlands. The proposed restored Froom Creek corridor would not be in a cut
condition (requiring excavation) at any location. The HEC-RAS cross-sections do not show the
existing surface, they reflect the proposed surface of the creek corridor. Figure 1-4 on page 1-7 of
the PHHC shows the extent of the restored creek corridor and does not propose any grading in the
existing wetland delineation.
Comment Response I.1-5
The comment requests clarification of the expected flood discharge to the Calle Joaquin wetlands
and in the proposed creek channel during 2-year to 100-year storm events. Page 1-6 of the PHHC
discusses the proposed capacity of the “low-flow channel”, which has been designed consistent
with the requirements of the “City of San Luis Obispo Drainage Design Manual” with a 2-year
capacity with the overbank into the Calle Joaquin wetland that is similar to the existing condition.
The Table shown in the Existing Froom Creek analysis lists overbanking flow rates in parentheses
for storms 2- through 100-year for historic, existing, and proposed creek corridors. Both the Calle
Joaquin wetland and the Proposed Froom Creek ultimately discharge to the existing double box
culvert discussed throughout the PHHC.
The proposed Froom Creek discharges directly to the double box culverts that convey flows under
U.S. 101. The Calle Joaquin wetland discharges to the southeasterly corner of the wetland and
continues by gravity to the creek channel and ultimately to the box culverts. The proposed basin
at Mountainbrook Church is proposed to discharge through a metered outflow pipe in a controlled
manner consistent with pre-developed flow rates to the capacity of the double box culverts.
Once the storm event has passed, flow out of the discharge pipe will continue until the basin is
emptied. Through development of the proposed detention basin, surrounding open space, and the
Calle Joaquin wetlands, the Project would provide nearly double the flood capacity of the pre-
developed condition.
Comment Response I.1-6
The comment expresses concern about the proposed Froom Creek overbank flow rates and the
ability of the proposed stormwater management system to contain/convey flood waters. The
“overbank flowrates” are shown in parentheses in the table provided in Comment Response O.1-
2, above. The proposed condition does not overbank in the 2-year event as shown by the “0” in
parentheses. The 100-year overbank flowrate is 722.1 cfs, not 1240.8, which is the total 100-year
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flow rate. The flow rates shown in the table also include runoff from Irish Hills Plaza and the
proposed Project, flows that have not entered the existing creek corridor at that point.
Comment Response I.1-7
The comment requests the EIR analyze the effects of removing the existing onsite detention basin
and the Project’s effect on overbank flow spilling. The Project proposes to construct a water quality
basin handling the 85th percentile storm events as described in Appendix 6 of the PHHC. There is
no scenario where stormwater would flow unretained, so there is no reason to analyze the effect
of removing the onsite detention basin without consideration of the proposed stormwater
management system. Under the Project, detention beyond the 85th percentile storm events migrate
through the restored/realigned Froom Creek channel and are detained in the proposed flood control
basin immediately upstream of the box culverts which includes storage far exceeding existing
onsite basins. See Comment Response I.1-6 related to overbank flow rates.
Comment Response I.1-8
The comment addresses the proposed detention basin and questions how the facility would affect
overbank flow rates at the Calle Joaquin wetlands, which is an issue addressed in Section 3.8,
Hydrology and Water Quality in the EIR. The existing condition of the wetlands receive inflow
from events larger than a 2-year event and discharge to the box culverts. The basin provides storage
and peak management of runoff conveyance to the box culverts. Proposed overbanking at the
wetlands is by design to assist in hydrologic function of the wetlands. Pursuant to the
comprehensive mitigation measures identified in the EIR, long-term monitoring of the wetland
will occur to document potential changes to the wetland function. MM BIO-5 requires the
Applicant to prepare a Long-Term Wetland Monitoring Plan for documenting and mitigating any
adverse changes to the Calle Joaquin wetlands that occur over the course of development under
the Specific Plan. Significant loss or adverse change to the Calle Joaquin wetlands would require
compensatory mitigation if observed over 7 years of required monitoring and reporting.
Comment Response I.1-9
The comment address existing levees in the Calle Joaquin wetlands and the ability of the wetland
to contain flood flows. Volume beyond the capacity of the existing Calle Joaquin wetlands are
hydraulically connected to the proposed basin upstream of the box culverts. The Calle Joaquin
wetlands become a component of the creek corridor that conveys flows ultimately to the box
culverts. The basin is not designed to retain the 100-year event. The basin is designed to provide a
flood control volume for larger events as they are conveyed to the existing double box culverts.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response I.1-10
The comment addresses the designed bed slope of the proposed Froom Creek channel and the
potential for sediment to build up within the channel. The proposed slope where the Project
continues the Froom Creek corridor is close to the existing slope where it connects on the property.
As the site flattens out downstream the slope of the channel also flattens to match the existing
topography. The sedimentation analysis evaluates the potential for transport but is also a tool to
show where additional creek design measures will be effective. Based on the evaluation, the
proposed creek corridor is stabilized after the first year and erosivity is controlled upstream of the
wetland. The EIR presents a conservative analysis of the potential effects of the Project on the
environment, including Froom Creek, San Luis Obispo Creek, and the Calle Joaquin wetlands.
The creek and wetland will be monitored pursuant to comprehensive mitigation measures,
including but not limited to the Biological Mitigation and Monitoring Plan shall include a Habitat
Mitigation and Monitoring Plan (HMMP). MM BIO-5 requires the Applicant to prepare a Long-
Term Wetland Monitoring Plan for documenting and mitigating any adverse changes to the Calle
Joaquin wetlands that occur over the course of development under the Specific Plan. Significant
loss or adverse change to the Calle Joaquin wetlands would require compensatory mitigation if
observed over 7 years of required monitoring and reporting.
Comment Response I.1-11
The comment requests information related to the elevation and places where LOVR and Home
Depot drainages enter the proposed Froom Creek channel. The graph presented is taken from the
“Preliminary Sediment Transport Analysis and Calculations”. The body of this report explains the
methodology and results of the analysis; the graph shows the Project’s proposed creek profile
(higher) and the projected profile after sediment transport alters the streambed over time. As
discussed in the above response, the analysis is a way to identify areas where creek design
measures will be most effective. See Comment Response I.1-6 related to overbank flow rates.
Comment Response I.1-12
The comment addresses potential public safety and property damage impacts from flooding of the
proposed Froom Creek. Appendix 3 of the PHHC shows a summary of modeled elements for the
various storm events for the contributing watersheds. The proposed Project modifies the timing of
the peak discharge which results in a decrease in peak flows at the downstream confluence for
every event except the 2-year storm (which has a 0.02% increase). A significant portion of the
existing flooding occurs as a tailwater condition from this downstream confluence — by reducing
this peak flow it reduces the base flood elevation for all events.
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MEETING DATE: 12/10/2019
ITEM NO: 1
Received
12/10/2019
SLO CITY CLERK
I.2-1
I.2-2
I.2-3
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02007
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Letter I.2 – Garrett Otto
Comment Response I.2-1
Comment requests addition of a mitigation measure that requires preservation of dedicated bicycle
and pedestrian pathways along LOVR during Project construction in lieu of closing bicycle lanes
or sidewalks during construction. The Project will be required to submit a Construction Traffic
Management Plan per MM TRANS-1, which will require review and approval by the City Public
Works Department. The City has adopted standards and guidelines for construction work zone
traffic control, which are consistent with applicable state and federal guidelines. Bicycle and
pedestrian safety are key priorities for the City in reviewing any construction area traffic control
plans. The City’s guidelines include specific policies and standard plans that require safe and
accessible paths of travel for pedestrians and cyclists through construction work areas. Full
closures of sidewalks or bike lanes will only be considered by the City where no other reasonable
options are feasible.
Comment Response I.2-2
This comment expresses concern regarding impacts to bicycle access and mobility in conjunction
with the proposed mitigation measures at the South Higuera/Prado intersection. The mitigation
measures identified for this intersection include fair-share contributions towards the City-led
capital improvement project, which includes replacement of the existing two-lane Prado Road
Bridge, and reconstruction of the South Higuera/Prado Road intersection. These improvements
include specific design measures that will significantly enhance safety and accessibility for
pedestrians and bicyclists. The replacement bridge will include physically separated pedestrian
and bicycle facilities, while the intersection improvement will include construction of a bicycle
protected intersection.
Comment Response I.2-3
This comment notes concern regarding degradation of pedestrian and bicycle conditions in
conjunction with the mitigation measures proposed for the South Higuera/Tank Farm intersection.
The Project will be directly implementing or participating via fair-share financial contributions
towards improvements that have already been planned and designed as a requirement of the Avila
Ranch development project. Designs, which have already been approved by the City, include
several features intended to improve bicycle and pedestrian safety and mobility at this location,
including: extension of the westbound bike lane to the intersection, installation of a bicycle left-
turn box for westbound and northbound approaches, enhanced pedestrian crosswalk markings,
traffic signal modifications to provide ADA-compliant pedestrian crossings, green bike lane
8-159
02008
markings through intersection crossings, and elimination of the “yield” westbound right-turn
movement. In addition, the Draft EIR mitigation measures require that the Project Applicant
coordinate with the City to implement lead pedestrian crossing intervals at each intersection
crossing to improve pedestrian crossing safety.
Comment Response I.2-4
This comment recommends that a mitigation measure be added to require the Project to pay fair-
share contributions or build Class IV bicycle infrastructure along South Higuera. Because there
are no bicycle segment impacts identified along this street segment, there is no impact to mitigate
or nexus requiring the Project to contribute towards mitigation improvements along this street
segment. In turn, the City’s currently adopted Bicycle Transportation Plan does not identify plans
for Class IV bikeways along South Higuera. However, the Bicycle Transportation Plan does plan
for future extensions of the Bob Jones Trail through the City, for which the Project is contributing
a fair-share contribution through participation in the Citywide Transportation Impact Fee Program.
Comment Response I.2-5
Thank you for your comments regarding the proposed FRSP. The proposed Project provided a 45-
day public review period in compliance with the California Environmental Quality Act Section
15105. Comments regarding your opposition to the proposed Project that do not directly pertain to
the analysis within the EIR will be included within the public record and will be made available to
the City decisionmakers for planning and policy considerations.
8-160
02009
MEETING DATE: 12/4/2019
ITEM NO: 2
Received
12/4/2019
SLO CITY CLERK
I.3-1
I.3-2
8-161
02010
8.4.4.3 Comment Letter I.3 – Jeff Whitener
Comment Response I.3-1
Thank you for your comments regarding the proposed FRSP. Potential Project-related impacts on
recreation, including public parks, are addressed in Section 3.12, Public Services and Recreation.
The EIR includes analysis of Alternative 1, which would relocate the public park to above the 150-
foot elevation line in the northwest corner of the site adjacent to the Irish Hills Natural Reserve.
Under Alternative 1, the public park would not be located adjacent to the Home Depot. Comments
regarding your opposition to the proposed Project, including the proposed park location, that do
not specifically pertain to the analysis of the EIR will be included within the public record and will
be made available to City decision makers for planning and policy considerations.
Comment Response I.3-2
The comment states the Project’s number of new units/residents to park space ratio should be
reevaluated to determine if enough park space has been reserved. Additionally, the comment states
it appears the Applicant is now proposing more units than in 2016. As described in the Section
3.11, Population and Housing, of the EIR, the Project is expected to generate new population
onsite by facilitating the construction of up to 174 multi-family units and 404 senior residential
units. This development would potentially increase population within the City by 1,231 residents,
including 825 residents of Villaggio and 406 residents of Madonna Froom Ranch. The City’s
General Plan PRE requires that neighborhood and community park facilities be provided at a ratio
of ten acres of parkland per 1,000 persons. As described in Section 3.12, Public Services and
Recreation, the Project would be required to provide up to 11.38 acres of public parkland within
the City’s Sphere of Influence inclusive of the 2.9 acres of public parkland proposed at the Project
site, which is consistent with the City’s General Plan Policies 3.13.1, 3.15.1, 5.0.1, and 5.0.2. With
the implementation of MM PS-1 and PS-2, the Project would not result in a considerable
contribution to cumulatively considerable impacts as the Project would mitigate its potential
impact and provide adequate parkland consistent with City standards along with payment of
development impact fees to accommodate the recreational needs of future Project residents.
8-162
02011
MEETING DATE: 12/10/2019
ITEM NO: 2
I.4-1I.4-1cont.8-16302012
8.4.4.4 Comment Letter I.4 – Judy Riener
Comment Response I.4-1
Thank you for your comments regarding the proposed FRSP and EIR. Comments regarding your
support of the Project that do not directly pertain to the analysis within the EIR will be included
within the public record and will be made available to the City decisionmakers for planning and
policy consideration.
8-164
02013
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I.5-2
I.5-3
I.5-4
I.5-5
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8-165
02014
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8-166
02015
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.4.5 Comment Letter I.5 – Kim Murry
Comment Response I.5-1
Thank you for your comments regarding the proposed FRSP and EIR. Regarding staff time
commitments to ensure mitigation monitoring and reporting, CEQA requires mitigations to specify
the timing, plan requirements, responsible party, and monitoring requirements. The EIR provides
these commitments and details for each mitigation measure, which will result in an enforceable
MMRP for Project implementation.
Comment Response I.5-2
This comment asks for clarity on how the City has approached traffic analysis for hotel uses. For
the Project EIR and for other previous development proposals, where the development proposal
clearly identifies a particular commercial site for hotel use, the transportation impact analysis
evaluates the project traffic generation using data for a hotel use.
Comment Response I.5-3
This comment questions how employee-related activity is captured for assisted living and memory
care facilities. Trip generation data used to project traffic demand generated by the proposed
assisted living and memory care uses is based on trip generation rates for that land use type
published by the Institute of Transportation Engineers (ITE). ITE trip generation rates are
developed based on field data collection at sites with similar uses. These field surveys capture
actual traffic entering and exiting sites with these land use types and inherently include trips
generated by both residents, visitors, and employees, as well as deliveries and other commercial
services related to the sites. Therefore, use of this ITE code for Villaggio land uses results in total
trip generation, including employee and operational activities.
Employment requirements for Villaggio are anticipated to generate 150 full-time equivalent jobs,
with a maximum of 95 employees onsite at any given time. The City’s LUCE requires EIRs to
estimate employment generation based on applying the existing factor of one job per 550 sf.1 When
this factor is applied to proposed retail commercial uses within Madonna Froom Ranch, it is
anticipated that retail commercial uses could generate approximately 182 jobs. Therefore, it is
assumed the Project would generate a total of 332 full-time equivalent jobs, including assisted
living and memory care personnel. For additional analysis and specifics on employee-related
activities, please refer to Section 3.11, Population and Housing.
1 LUCE Update EIR job factor.
8-167
02016
Comment Response I.5-4
Key Viewing Areas (KVA) of the proposed Project site were selected and represented in locations
clearly viewable by the public. A 3D model of the Project based on conceptual plans was
generated, including consideration of elevation for visual simulations of each KVA; therefore,
story poles were not utilized in the EIR analysis. Per City Council requirements, representative
story poles were erected during circulation of the Draft EIR. These poles were placed at heights
that reflected proposed finished grade (not natural grade). Please refer to Section 3.1, Aesthetics
and Visual Resources for a comprehensive analysis of the aesthetic-related impacts.
Comment Response I.5-5
The comment addresses why KVA 5 was selected in its particular location. KVAs are analysis
tools to isolate and analyze representative views of a project to demonstrate the potential visual
effects from different perspectives. As a representation, the impact analyzed in a KVA may
indicate a type or range of impacts not only for the specific KVA but also for the general
perspective or vantage point the KVA represents. KVA 5 was selected due to the proximity of an
existing scenic vista along a public trail area. Additionally, this KVA was selected because it
provides a view of the existing open space and adjacent land uses experienced from upper elevation
trails in the Irish Hills Natural Reserve. This KVA also represents the view from a comparable
location reflective of that identified in the General Plan COSE as a scenic vista. The KVA was not
taken at the exact location of the scenic vista identified in the General Plan COSE, as the chosen
KVA provides a greater view of the City and vista across the Project site, providing a high level
of contrast for evaluating Project impacts; however, the impact analysis provided for KVA 5 is
representative of impacts throughout the Irish Hills from this perspective. For further detail on the
selection process of KVAs for the proposed Project site, please refer to 3.1 Aesthetics and Visual
Resources.
Comment Response I.5-6
The comment requests more information related to the Airport Land Use Plan (ALUP) and the
approval process for the Project with the Airport Land Use Commission (ALUC). As described in
the EIR Section 3.9, Land Use and Planning, the proposed Project provides a comprehensive
analysis of the ALUP for the San Luis Obispo County Regional Airport and the City’s LUE
Chapter 7, Airport Area. The Project’s relation to potential airport risk hazards was
comprehensively analyzed and considered less than significant by the Airport Land Use
Compatibility Report in consideration of the above-mentioned policies.
8-168
02017
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
The Project area is currently subject to the requirements of the ALUP. Figure 3, Aviation Safety
Areas, of the current ALUP shows that portions of Airport Safety Areas S-1b and S-1c are in the
northeastern portion of the Project area. However, with the San Luis Ranch and Avila Ranch
Specific Plans, a corrected version of the analog map used in ALUP Figure 3 has been utilized in
review of these projects for consistency with the ALUP. The new map has corrected the locations
of the safety areas to the true GIS bearings of Runways 7-25 and 11-29.
When the Project site is overlain on the corrected safety areas map, it is located outside of both
Safety Areas S-1b and S-1c, but the northeastern corner is included in Safety Area S-2. The ALUC
conceptually reviewed the Project on April 19, 2017 and determined that the use of the corrected
map was appropriate. The ALUP is currently being updated. A draft Safety Areas map shows the
Project site entirely outside of the safety zone areas. For further detail on the applicable regulations
concerning the proposed Project, please refer to Section 3.9.2, Land Use Regulatory Setting.
Additional detail has been provided relative to this topic.
Comment Response I.5-7
The comment addresses the proposed 2.9-acre public park and potential impacts to recreation and
noise. As discussed in the EIR, MM PS-2, Public Parkland Requirements for Madonna Froom
Ranch states in subsection a: “The Applicant shall designate an additional area of up to 1.16 acres
of public facilities.” Therefore, the 1.16 acres of public parkland are described as additional to the
2.9 acres of public parkland as proposed by the Project and the additional 7.32 acres of public
parkland required under MM PS-1 described in the EIR, resulting in a total requirement of up to
11.38 acres of parkland (including 5.69 acres of neighborhood park) (refer to clarifications in MM
PS-1 and MM PS-2). The EIR provides a comprehensive consistency analysis of the Project’s
proposed park and recreation area with the City’s General Plan, which requires residential areas,
including the Project, to provide neighborhood parks at the rate of five acres per 1,000 residents
and at least ten acres of parkland for each 1,000 new residents. Information has been added to MM
PS-2 to clarify that the 1.16 parkland acres is in addition to the proposed 2.9 acres of parkland
proposed in the Project.
Potential noise impacts affecting the proposed park are discussed in EIR Section 3.10, Noise (refer
to Impact NO-4). The proposed park is identified as a sensitive receptor, and the EIR analysis
notes that intermittent exterior noise levels could reach up to 85 dBa within the park, resulting in
a potentially significant impact that would be mitigated by implementation of MM NO-4. EIR
Section 3.9 (Land Use and Planning), Table 3.9-4 (City General Plan Policy Consistency Analysis)
includes a preliminary consistency finding for applicable Parks and Recreation Element policies.
8-169
02018
Comment Response I.5-8
The comment addressed potential increased calls for service from the proposed senior residential
community. As discussed in the EIR, the proposed Project would cumulatively contribute to
citywide population growth and associated increases in demand for fire protection services of
SLOFD under the existing four fire stations that serve the area. The SLOFD considers certain
development and uses, including senior residential development, to be uses which would result in
a higher than normal amount of calls for service compared to other types of development. The City
does not currently charge for service response to care facilities. Senior residential uses in the City
have historically generated higher levels of calls for service. Section 3.12, Public Services and
Recreation addresses potential impacts to emergency response services (e.g., fire, police),
including Impact PS-2, which assesses fire protection services in the context of SLOFD’s adequate
response time and anticipated number of calls for emergency services based on the type of
development proposed under the Project, including proposed senior residential communities. In
consultation with SLOFD as part of EIR preparation, SLOFD confirmed that the Project would
not result in a significant increase in demand for fire or emergency response services, and that
adequate resources and staff exist to serve the proposed development, including the senior
residences. The City has a system of required developer impact fees and dedications established
to address direct demand for new facilities associated with new development, while potential
increases in property tax revenue associated with valuation of new residential units, businesses,
and other revenues (e.g., sales tax) would help offset the increased ongoing cost of provision of
public services to new residential and commercial uses. The Project site is located within close
proximity (0.5 mile) from the nearest SLOFD fire station and is located well within the three-
minute response time. In addition, the 2016 Fire Department Master Plan includes planning efforts
for a fifth fire station based on expanded residency in the City resulting less than significant
impacts and benefit services to the Project site. The Project would comply with payment of
required development impact fees to offset a development’s increased demand on fire services
responses.
Comment Response I.5-9
The comment questions why the No Project Alternative would be more impactful to cultural
resources than the Project. To clarify, the impacts to historic buildings as CEQA cultural resources
would be more severe under the No Project Alternative. As discussed in the EIR in Section 5.0,
Alternatives, Project implementation would rehabilitate and preserve four historic structures and
resources and relocate the structures outside of the potential active fault zone to a more
geologically stable location. The No Project Alternative would not involve the physical alteration
8-170
02019
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
of any onsite historic structures affecting their significance or eligibility. Therefore, these historic
resources would not receive the same benefits of preservation and restoration as under the Project.
Eligible historic structures/resources would not be rehabilitated and preserved, nor would they be
relocated outside the potential active fault zone to more geologically stable locations. Additionally,
the resources would continue to be used for storage and construction business operations without
specialized maintenance or upkeep causing the potential for deterioration and/or failure. Of the
four structures eligible significant historic resources, the creamery has experienced heavy damage
and partial collapse, while the dairy barn and granary are aged, dilapidated, and may be structurally
unsound. Please refer to Section 5.0, Alternatives for further detail on the comprehensive analysis
of Cultural and Tribal Cultural Resources under the No Project Alternative. As discussed therein,
these structures may further deteriorate and continue to be at risk of failure or collapse if not
rehabilitated under the Project. Over time, the deterioration of the structures may result in a loss
of integrity while remaining on site and a loss of the resource value entirely when deterioration
results in collapse of the structures. Retention of these structures in their current place and status
would not result in any changes to the eligibility of the resources or the potential historic district
in the short-term, which would have less impacts compared to the Project, but in the long-term,
the No Project Alternative would inevitably result in negligence of the buildings and eventual loss
of eligible structures, which would be significant.
Comment Response I.5-10
This comment relates to the Project’s proposed annexation. To clarify Section 2.5 Project
Description-Required Approvals, the Applicant is proposing annexation of the Project site to the
City as part of the Project. City approval of the Project would initiate annexation as a component
of the FRSP adoption, but ultimately the Applicant is the Project proponent. Further, as discussed
in the EIR, for the Project to be approved, a General Plan amendment to amend LUCE SP-3 to
ensure consistency with the Specific Plan would be required. The City’s LUCE Update EIR and
General Plan have planned for the annexation of the site.
Comment Response I.5-11
The comment addresses the proposed Project open space and conservation components. The policy
discussion of 8.6.3-G in Section 3.9, Land Use and Planning identifies the presence of open space
resources within the Project site, and the first sentence of the discussion has been clarified to add
an additional reference to the presence of open space resources. An incorrect reference to payment
of in-lieu fees relative to the agricultural easement proposed for reconfiguration has been deleted
from the EIR.
8-171
02020
Comment Response I.5-12
This comment notes that it may be helpful to include discussion on how existing employer
transportation demand management programs have been implemented and lessons learned. A suite
of residential and employment-oriented transportation demand management strategies is identified
in MM AQ-4 and MM AQ-6 to help reduce traffic and parking demand within the Specific Plan
area. While there is some data available on efficacy of these types of measures, the ultimate
effectiveness often varies quite a bit on a project-to-project basis. In general, measures that involve
tangible actions, such as operating a shuttle system, developing a mix of land use types within a
site, providing dedicated parking for bicycles and carpool/vanpool, improving access to
multimodal transportation facilities, etc., provide fewer challenges in terms of implementation and
monitoring.
Comment Response I.5-13
This comment concerns the timing of Project construction identified in Section 2.6, Project
Construction, which estimates Project construction to occur in four phases between 2020 and 2024.
Initial occupancy of the Lower Area of Villaggio would occur in 2022 with full occupancy in 2025.
These schedule assumptions form the basis of the EIR’s assumptions about impact and mitigation
measure timing. The EIR analysis and mitigation measures are triggered by phases of Project
construction and occupancy and are not tied to a particular date or year. This means that the EIR
findings are temporally flexible to apply when the environmental impact actually occurs and that
the EIR findings are not tied to a particular date of construction or occupancy. As a planning
document, this approach is appropriate for the FRSP since it cannot be known precisely when
individual phases of the Project will actually reach construction approvals. Following adoption of
the FRSP and at the time of construction, each phase would be subject to permit review to ensure
conformity with the approved FRSP and consistency with applicable regulations and mitigation
measures. Future changes to the start date of each of the phases of the development would not
change the applicability of all required mitigation and associated triggers. Please also refer to
Section 8.0, Mitigation Monitoring and Reporting Program.
8-172
02021
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8-174
02023
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cont.
8-175
02024
8.4.4.6 Comment Letter I.6 – Lea Brooks
Comment Response I.6-1
Thank you for your comments regarding the proposed FRSP and EIR. Analysis of transportation,
including bicycle infrastructure, are comprehensively discussed in Section 3.13, Transportation
and Traffic, which provides a discussion of existing bicycle routes in the proposed Project vicinity
and analysis of potential Project-related effects. Comments regarding your opposition to the
proposed Project that do not specifically pertain to the analysis of the EIR will be included within
the public record and will be made available to the City decisionmakers for planning and policy
considerations.
Comment Response I.6-2
This comment expresses regret that a Bicycle Level of Traffic Stress Analysis has not been applied
to the Project. The transportation impact analysis for the Project utilizes analysis methodologies,
measures of performance, and impact thresholds consistent with the City’s adopted General Plan
Circulation Element and Transportation Impact Analysis Guidelines. These adopted policy
documents establish multimodal LOS as the approved metric for evaluating bicycle transportation
impacts; thus, this methodology is utilized for the purposes of analyzing Project transportation
impacts.
Comment Response I.6-3
This comment expresses frustration that the Project trip generation estimates by travel mode do
not match the future mode split targets identified in the City’s Circulation Element. See also
Comment Response O.3-3 for detailed explanation regarding transportation mode split
assumptions for the purposes of project-level CEQA analysis. The Project trip generation estimates
are developed based on data from professional surveys of similar types of land uses and based on
existing City mode share data as referenced from the American Community Survey and the City’s
biennial traffic data collection program. While the Project will be required construct infrastructure
(on- and offsite) and implement programs that are likely to facilitate increased progress towards
reaching the City’s long-term mode share targets, for the purposes of a focused transportation
impact analysis, it is important that the Project traffic generation estimates reflect an accurate, if
not conservative, estimate of multimodal traffic anticipated to be induced by the proposed
development.
8-176
02025
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response I.6-4
This comment expresses concern regarding clarity with timing and responsibility of mitigation
measures and notes disappointment regarding lack of protected bike lanes along LOVR. Per MM
TRANS-8 and TRANS-9, and TRANS-22, the Project is required to construct bicycle
improvements along LOVR consistent with the concept adopted in the Bob Jones Trail (Calle
Joaquin to Oceanaire) project, which includes installation of protected bike lanes along LOVR and
a bicycle protected intersection at the LOVR/Auto Park intersection. The transportation mitigation
language has also been refined in the Final EIR to provide further clarity regarding mitigation
responsibility and timing.
Comment Response I.6-5
This comment inquires as to how Project residents and visitors will access the existing Bob Jones
Trail segment and recommends additional design elements to improve conditions for cyclists
navigating LOVR at the U.S. 101 Interchange. Project residents, employees, and visitors would
access the existing Bob Jones Trail segment via sidewalks and bike lanes along LOVR, and
crossing LOVR at the trailhead entry via the existing pedestrian and bicycle crossing signals at the
LOVR/U.S. 101 Northbound Ramps intersection. As mentioned above, per MM TRANS-8,
TRANS-9 and TRANS-22, the Project will be required to construct additional multimodal
improvements along the LOVR corridor, including installation of protected bike lanes and
completing sidewalk gaps. Improvements will be designed per City Engineering Standards and
current best practices for safe bicycle infrastructure planning. With that said, the interchange is
within Caltrans jurisdiction and approval of any specific design elements will ultimately be at
Caltrans discretion.
Comment Response I.6-6
This comment notes concern regarding proposed mitigation improvements at the South
Higuera/Tank Farm intersection. See also Comment Response I.2-3 for detailed discussion of
mitigation strategies for this intersection. The Project will be directly implementing or
participating via fair-share financial contributions towards improvements that have already been
planned and designed as a requirement of the Avila Ranch development project.
Comment Response I.6-7
This comment states that safe routes to school must be described for school-age residents of the
Project. Pg. 3.13-69 of the Draft EIR includes a discussion of school-based trip distribution for
8-177
02026
Project residents. The Final EIR includes expanded discussion within Section 3.13, Transportation
& Traffic to describe specific walking and bicycling routes to school.
Comment Response I.6-8
This comment notes concern regarding lack of vehicular connectivity between the Project site and
the adjacent Irish Hills Plaza. While this was explored, a reciprocal vehicular access agreement
was not approved by the Irish Hills Plaza property owner. The Project circulation plan retains
pedestrian and bicycle access between the adjacent sites, which is likely to increase bike and walk
trips between the adjacent sites over less efficient trips by automobile.
This comment also expresses concerns regarding bicycle and pedestrian access and safety during
construction and perceived traffic signal timings unfairly penalizing pedestrians and bicyclists. See
Comment Response I.2-1 regarding construction traffic management for bicyclists and
pedestrians. The Project will be required to submit a Construction Traffic Management Plan per
MM TRANS-1, which will require review and approval by the City Public Works Department.
Regarding traffic signal timings, the City of San Luis Obispo Transportation Division endeavors
to establish traffic signal timing and phasing plans that balance modal priorities. San Luis Obispo
was one of the first cities in California to install dedicated bicycle signals. Any proposed signal
timing optimizations proposed in conjunction with the Project will continue to embrace this effort
to balance priorities among road users, establishing minimum clearance times, pedestrian crossing
sequences, pedestrian lead intervals, cycle lengths, and signal phasing strategies that provide for
safe and efficient operations for all road users.
8-178
02027
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cont.
8-180
02029
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.4.7 Comment Letter I.7 – Neil Havlik (1)
Comment Response I.7-1
Thank you for your comments regarding the proposed FRSP and EIR. This comment provides
general support for certain aspects of the EIR, including analysis of impacts to cultural and historic
resources and the description analyzed in Alternative 1 – Clustered Development Below the 150-
foot Elevation Line. Comments regarding favor for a Project component or alternative that do not
specifically pertain to the analysis of the EIR will be included within the public record and will be
made available to the City decisionmakers for planning and policy considerations. Additionally,
Section 3.9, Land Use and Planning provides an evaluation of the consistency of the proposed
Project with the City’s 2014 LUE. The EIR recognizes the proposed Project would be potentially
inconsistent with the City’s hillside protection policies regarding the limitation to development
above the 150-foot elevation line, so to address this potential inconsistency, analysis of alternatives
is comprehensively discussed in Section 5.0, Alternatives. Alternative 1 is identified as the
Environmentally Superior Alternative and would be more consistent with hillside protection
policies as proposed Project development would be located below the 150-foot elevation line, with
the exception of the proposed public trailhead park.
8-181
02030
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I.8-1
8-182
02031
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.4.8 Comment Letter I.8 – Neil Havlik (2)
Comment Response I.8-1
Thank you for your comments regarding the FRSP and EIR. Comments regarding opposition to
the Project, including timeline of City review, that do not specifically pertain to the analysis of the
EIR will be included within the public record and will be made available to the City
decisionmakers for planning and policy considerations. Additionally, Section 3.9, Land Use and
Planning provides an evaluation of the consistency of the proposed Project with the City’s 2014
LUE. The EIR recognizes the proposed Project would be potentially inconsistent with the City’s
hillside protection policies regarding the limitation to development above the 150-foot elevation
line, so to address this potential inconsistency, analysis of alternatives is comprehensively
discussed in Section 5.0, Alternatives. Alternative 1 is identified as the Environmentally Superior
Alternative and would be more consistent with hillside protection policies as proposed Project
development would be located below the 150-foot elevation line, with the exception of the
proposed public trailhead park.
8-183
02032
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I.9-1
I.9-2
8-184
02033
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I.9-2
cont.
I.9-3
8-185
02034
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(Postscript and Disclosure: After my retirement as City Natural Resources Manager in July
2012, the City did me the honor of naming the trail near this boundary after me, as Neil Havlik
Way. While I am gratified by this honor, I can assure your Commission that this designation has
no influence on my attitude toward the proposed development adjacent to this sensitive area. I
am concerned solely with protecting the integrity of Irish Hills Natural Reserve to the best of my
ability, and making it the best it can be.—N.H.)
I.9-3
cont.
I.9-4
cont.
I.9-5
8-186
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.4.9 Comment Letter I.9 – Neil Havlik (3)
Comment Response I.9-1
Thank you for your comments regarding the proposed FRSP and EIR. Section 3.9, Land Use and
Planning provides an evaluation of the consistency of the proposed Project with the City’s 2014
LUE. The EIR recognizes the proposed Project would be inconsistent with the City’s hillside
protection policies regarding the limitation to development to the 150-foot elevation line, so to
address this inconsistency, analysis of alternatives is comprehensively discussed in Section 5.0,
Alternatives. Alternative 1 – Clustered Development Below the 150-foot Elevation is identified as
the Environmentally Superior Alternative and is more consistent with hillside protection policies
as proposed Project development would be located below 150-foot elevation line, with the
exception of the proposed public trailhead park. For additional analysis and specifics on
Alternative 1, please refer to Section 5.0, Alternatives.
Comment Response I.9-2
The comment states the San Luis Obispo Tribune carried an article stating the Applicant would
not pursue development above the 150-foot elevation; this does not seem fully accurate to the
commenter. To clarify, the EIR evaluated the proposed Project, which include development above
150 feet in elevation in the Irish Hills and three alternatives that consider different site
configuration and development intensities that would eliminate residential development above 150
feet in elevation. These alternatives are available for consideration by City decision makers and
the Applicant through Project review and approval. For additional analysis and specifics on
Alternative 1, please refer to Section 5.0, Alternatives.
Comment Response I.9-3
The comment expresses support of the relocation of historic buildings and designation of the public
park area under Alternative 1 evaluated and described in the EIR, and that such a proposal would
better align with City General Plan policies. These comments will be included within the public
record and will be made available to the City decisionmakers for planning and policy
consideration.
Comment Response I.9-4
The comment addresses the need for buffers from the Irish Hills Natural Reserve. The EIR
addresses biological resource setbacks and buffers required by regulations and EIR mitigation
measures, including biological resources in the Irish Hills, in Section 3.4, Biological Resources.
The EIR also addresses the potential adverse effects of fuel management buffers around structures
8-187
02036
that may affect Irish Hills resources in Section 3.7, Hazards, Hazardous Materials, and Wildfire.
City General Plan COSE Policy 8.3.2 states that “[w]hen activities close to open space resources
within or outside the urban area could harm them, the City will require buffers between the
activities and the resources.” In Section 5.0, Alternatives, Alternative 1 – Clustered Development
Below the 150-foot Elevation is identified as the Environmentally Superior Alternative and is more
consistent with City policies to buffer the Irish Hills from development as proposed development
would be located below the 150-foot elevation line, with the exception of the proposed public park.
As discussed in Section 3.9, Land Use and Planning and Section 5.0, Alternatives, the Project
would incorporate a buffer between development in much of the areas adjacent to the Irish Hills
Natural Reserve through the designation of open space. The buffer between proposed development
and the Irish Hills Natural Reserve would be further widened under Alternative 1 by clustering
development below the 150-foot elevation line and relocating the public park adjacent to the Irish
Hills.
However, the Project and Alternative 1 could impact open space resources within the Irish Hills
Natural Reserve through creation of vegetation management fire buffers within the Reserve and
disruption of or impacts to sensitive wildlife movement. MM HAZ-2 requires preparation of a
Community Fire Protection Plan that would, in addition to other requirements, outline the removal
and control of invasive, non-native vegetation, conserve sensitive habitats and rare species, and
require approval by the City’s Natural Resources Manager and Fire Department. Alternative 1
would result in greater consistency with General Plan COSE Policy 8.3.2. For additional analysis
and specifics on Alternative 1, please refer to Section 5.0, Alternatives.
Comment Response I.9-5
This comment repeats comments made in O.1 and in I.9-1 through I.9-4. Please refer to responses
above in Comment Response O.1-1 through O.1-12 and in I.9-1 through I.9-4.
8-188
02037
8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
8.4.5 Applicant
[Insert Comment Letter A.1, RRM Design Group, page 1 of 47]
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 1 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϬ͘Ϭ y hd/s ^hDDZzŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϬ͘Ϭ džĞĐƵƚŝǀĞ^ƵŵŵĂƌLJϭ WĂŐĞ ^ͲϮ͕WƌŽũĞĐƚŽǀĞƌǀŝĞǁʹ͞ŝŶĂĐƚŝǀĞƌĞĚƌŽĐŬƋƵĂƌƌLJ͟dŚĞƋƵĂƌƌLJŝƐŶŽƚŝŶĂĐƚŝǀĞ͘/ƚƌĞŵĂŝŶƐŝŶĂĐƚŝǀĞƵƐĞĨŽƌĂǀĂƌŝĞƚLJŽĨƵƐĞƐƌĞůĂƚĞĚƚŽĐŽŶƐƚƌƵĐƚŝŽŶĂĐƚŝǀŝƚŝĞƐĂŶĚŵĂƚĞƌŝĂůƐ͘Ϯ WĂŐĞ ^Ͳϰ͕ĞƐƚŚĞƚŝĐƐĂŶĚsŝƐƵĂůZĞƐŽƵƌĐĞƐʹ^ƚĂƚĞ^ĐĞŶŝĐ,ŝŐŚǁĂLJEŽ^ƚĂƚĞĚĞƐŝŐŶĂƚĞĚ^ĐĞŶŝĐ,ŝŐŚǁĂLJǀŝĞǁƐĂƌĞĂĨĨĞĐƚĞĚďLJƚŚĞƉƌŽũĞĐƚ͘h^ϭϬϭŝƐŶŽƚ^ƚĂƚĞĚĞƐŝŐŶĂƚĞĚŝŶƚŚŝƐƌĞĂĐŚŽĨ,ŝŐŚǁĂLJϭϬϭ͘ϯ WĂŐĞ ^Ͳϭϰϳ͕ůƚĞƌŶĂƚŝǀĞηϯ͕ŝŶĐƌĞĂƐĞĚĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐ/ƚŝƐƵŶĐůĞĂƌŚŽǁǁŝƚŚƚŚŝƐůƚĞƌŶĂƚŝǀĞ͞ŝŶĐƌĞĂƐĞĚĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐ͟ǁŽƵůĚďĞĂĐŚŝĞǀĞĚ͍&ƌŽŽŵƌĞĞŬǁŽƵůĚƌĞŵĂŝŶĂƐƵďƐƚĂŶƚŝĂůďĂƌƌŝĞƌƚŽĨŝƌĞĨŝŐŚƚŝŶŐĞƋƵŝƉŵĞŶƚĂĐĐĞƐƐŝŶŐƚŚĞ/ƌŝƐŚ,ŝůůƐŝŶƚŚŝƐĂƌĞĂ͘ϰ WĂŐĞ ^Ͳϭϰϵ͕dĂďůĞ ^ͲϮ͕ůƚηϯ͕WŽƉƵůĂƚŝŽŶĂŶĚ,ŽƵƐŝŶŐ͘/ƚŝƐƵŶĐůĞĂƌŚŽǁůƚηϯŝƐ͞ůĞƐƐ͟ĂƐŝƚĚŽĞƐŶŽƚƉƌŽǀŝĚĞƐĞŶŝŽƌŚŽƵƐŝŶŐͲĂŶŝĚĞŶƚŝĨŝĞĚŶĞĞĚŝŶƚŚĞŝƚLJ,ŽƵƐŝŶŐ ůĞŵĞŶƚ͘A.1-2A.1-3A.1-4A.1-58-190
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 2 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϭ͘Ϭ/EdZKhd/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϭ͘Ϭ/ŶƚƌŽĚƵĐƚŝŽŶϭ ϭ͘ϭKǀĞƌǀŝĞǁ͕ƉĂŐĞϭͲϭ͕ϮŶĚƉĂƌĂŐƌĂƉŚĚĞƐĐƌŝƉƚŝŽŶŽĨϮϬϭϰ>h ^WƌĞĂƵƐĞƐ͞ƐŵĂůůƐĐĂůĞĐŽŵŵĞƌĐŝĂůƵƐĞƐ͟dŚĞ>h ĚĞƐĐƌŝƉƚŝŽŶŽĨ^WƌĞĂηϯ;>h ƉĂŐĞϭͲϴϵͿĚŽĞƐŶŽƚĚĞƐĐƌŝďĞĐŽŵŵĞƌĐŝĂůƵƐĞƐĂƐ͞ƐŵĂůůͲƐĐĂůĞĐŽŵŵĞƌĐŝĂůƵƐĞƐ͘͟dŚĞ>h ĂůůŽǁƐƵƉƚŽϯϬϬ͕ϬϬϬƐĨŽĨĐŽŵŵĞƌĐŝĂů͘dŚŝƐǁŽƵůĚŶŽƚďĞƐŵĂůůͲƐĐĂůĞ͘Ϯ ϭ͘ϭKǀĞƌǀŝĞǁ͕ƉĂŐĞϭͲϮ͕ƚŽƉŽĨƉĂŐĞ͕ĐŚĂƌĂĐƚĞƌŝnjĂƚŝŽŶŽĨƋƵĂƌƌLJĂƐ͞ŝŶĂĐƚŝǀĞ͟dŚĞƋƵĂƌƌLJŝƐŶŽƚ͞ŝŶĂĐƚŝǀĞ͘͟A.1-6A.1-78-191
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 3 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϮ͘ϬWZK: d ^Z/Wd/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϮ͘ϬWƌŽũĞĐƚĞƐĐƌŝƉƚŝŽŶϭ WĂŐĞϮͲϭ͕/ŶƚƌŽĚƵĐƚŝŽŶƉĂƌĂŐƌĂƉŚ dŚŝƐƉĂƌĂŐƌĂƉŚŝŶĚŝĐĂƚĞƐƚŚĂƚĂĐĐŽƌĚŝŶŐƚŽƚŚĞŝƚLJ'ĞŶĞƌĂůWůĂŶĚĞǀĞůŽƉŵĞŶƚĂďŽǀĞƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶŝƐ͞ƉƌŽŚŝďŝƚĞĚ͘͟dŚŝƐŝƐŶŽƚĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞůĂŶŐƵĂŐĞŽĨƚŚĞϮϬϭϰ>h ͘dŚĞĂĐƚƵĂůůĂŶŐƵĂŐĞŽĨƚŚĞ>h ŝƐĂƐĨŽůůŽǁƐ͗+7KH,ULVK+LOOVDUHDVKRXOGVHFXUHSHUPDQHQWRSHQVSDFHZLWKQREXLOGLQJVLWHVDERYHWKHIRRWHOHYDWLRQLQFRQMXQFWLRQZLWKDQ\VXEGLYLVLRQRUGHYHORSPHQWRIWKHORZHUDUHDV 6HHDOVR6HFWLRQ6SHFLDO)RFXV$UHDV Ϯ WĂŐĞϮͲϳ͕ĞƐĐƌŝƉƚŝŽŶŽĨƐƵƌƌŽƵŶĚŝŶŐƵƐĞƐ͘ůƚŚŽƵŐŚŵĂŶLJŽĨƚŚĞƐƵƌƌŽƵŶĚŝŶŐƵƐĞƐĂƌĞƐŝŶŐůĞƐƚŽƌLJ͕ƚŚĞƌĞĂƌĞƐĞǀĞƌĂůďƵŝůĚŝŶŐƐŝŶƚŚĞŶĞĂƌďLJǀŝĐŝŶŝƚLJƚŚĂƚĂƉƉƌŽĂĐŚϯϱͲϰϬĨĞĞƚŝŶŚĞŝŐŚƚŝŶĐůƵĚŝŶŐŽƐƚĐŽ͕,ŽŵĞĞƉŽƚĂŶĚŽƚŚĞƌƐ͘dŚĞŶĞǁŚŽƚĞůŽŶĂůůĞ:ŽĂƋƵŝŶƵŶĚĞƌĐŽŶƐƚƌƵĐƚŝŽŶǁŝůůďĞϰϱĨĞĞƚƚĂůů͘ϯ WĂŐĞϮͲϭϬ͕ŵŝĚͲƉĂŐĞ͕ƋƵĂƌƌLJĐŚĂƌĂĐƚĞƌŝnjĞĚĂƐ͞ŝŶĂĐƚŝǀĞ͟dŚĞƋƵĂƌƌLJŝƐŶŽƚŝŶĂĐƚŝǀĞ͘ϰ ^ĞĐƚŝŽŶϮ͘ϯ͕ƉĂŐĞϮͲϭϭ͕WƌŽũĞĐƚŽďũĞĐƚŝǀĞƐdŚĞĂƉƉůŝĐĂŶƚƐƵďŵŝƚƚĞĚƉƌŽũĞĐƚŽďũĞĐƚŝǀĞƐƚŽƚŚĞŝƚLJŽŶϵͲϬϳͲϮϬϭϳ͘KďũĞĐƚŝǀĞϭϬĂƐƌĞͲǁƌŝƚƚĞŶŝŶƚŚĞ /ZĐŽŶĐĞƌŶƐƚŚĞĂƉƉůŝĐĂŶƚĂƐŝƚĐŽŵŵŝƚƐƚŚĞĂƉƉůŝĐĂŶƚƚŽ͞ĞdžĐĞĞĚ͟ƚŚĞƌĞƋƵŝƌĞŵĞŶƚƐŽĨdŝƚůĞϮϰĂŶĚ ;WĂƌƚϲͿŝŶĞĨĨĞĐƚĂƚƚŚĞƚŝŵĞ͘/ƚĚŽĞƐŶŽƚĞƐƚĂďůŝƐŚĂŶĂŵŽƵŶƚďLJǁŚŝĐŚƚŚĞƐĞƐƚĂŶĚĂƌĚƐŵƵƐƚďĞĞdžĐĞĞĚĞĚ͘ƐǁƌŝƚƚĞŶ͕ŝƚŝƐĂŶŽƉĞŶͲĞŶĚĞĚĐŽŵŵŝƚŵĞŶƚĂŶĚĚĞƉĞŶĚŝŶŐŽŶƚŚĞĂŵŽƵŶƚŽĨĞdžĐĞĞĚĂŶĐĞƌĞƋƵŝƌĞĚŵĂLJďĞŝŶĨĞĂƐŝďůĞ͘ϱ ^ĞĐƚŝŽŶϮ͘ϰ͘ϭ͕ƉĂŐĞϮͲϭϳ͕ƉƌŽƉŽƐĞĚůĂŶĚƵƐĞ͕ƚŽƉŽĨƚŚĞƉĂŐĞʹ͞ϱϵ͘ϬĂĐƌĞƐŽĨĚĞĚŝĐĂƚĞĚŽƉĞŶƐƉĂĐĞ͟dŚĞǁŽƌĚŝŶŐŽĨƚŚŝƐĐŽŵŵĞŶƚŝƐĂǁŬǁĂƌĚĂƐŝƚŝŵƉůŝĞƐĂĨĞĞĚĞĚŝĐĂƚŝŽŶŽĨŽƉĞŶƐƉĂĐĞƚŚĂƚŚĂƐŶŽƚďĞĞŶŽĨĨĞƌĞĚƚŽƚŚĞŝƚLJʹŝƚǁŽƵůĚďĞŵŽƌĞĐůĞĂƌŝĨŝƚƐĂŝĚ͞ĚĞĚŝĐĂƚĞĚĨŽƌƵƐĞĂƐŽƉĞŶƐƉĂĐĞ͟ŽƌĚĞůĞƚĞƚŚĞǁŽƌĚ͞ĚĞĚŝĐĂƚĞĚ͟ϲ ^ĞĐƚŝŽŶϮ͘ϰͲϭ͕ƉĂŐĞϮͲϮϭ͕&ŝŐƵƌĞϮͲϲ͘ dŚĞĂƉƉůŝĐĂŶƚŚĂƐƉƌĞǀŝŽƵƐůLJĐŽŵŵĞŶƚĞĚ͕ĂŶĚŝƚLJͬtŽŽĚĐŽŶĐƵƌƌĞĚƚŚĂƚƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶůŝŶĞŽŶƚŚŝƐĚƌĂǁŝŶŐƐŚŽƵůĚďĞĚĞůĞƚĞĚ͘dŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶŝƐĂŐƌŽƵŶĚĞůĞǀĂƚŝŽŶŽŶƚŚĞ/ƌŝƐŚ,ŝůůƐƚŽĚĞƚĞƌŵŝŶĞƚŚĞĞdžƚĞŶƚŽĨƚŚĞĚĞǀĞůŽƉŵĞŶƚĂƌĞĂ͖ŝƚŝƐŶŽƚĂŚĞŝŐŚƚůŝŵŝƚĨŽƌĚĞǀĞůŽƉŵĞŶƚďĞůŽǁƚŚĞϭϱϬĨƚŐƌŽƵŶĚĞůĞǀĂƚŝŽŶ͘ϳ ^ĞĐƚŝŽŶϮ͘ϰ͘ϭ͘ϯ͕ƉĂŐĞϮͲϮϯ ^ĞĞĐŽŵŵĞŶƚηϱĂďŽǀĞ͘A.1-8A.1-9A.1-10A.1-11A.1-12A.1-13A.1-148-192
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 4 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϮ͘ϬWZK: d ^Z/Wd/KEϴ ^ĞĐƚŝŽŶϮ͘ϰ͘Ϯ͘Ϯ͕ƉĂŐĞϮͲϮϱ ^ĞĞĐŽŵŵĞŶƚηϰĂďŽǀĞ͘ϵ͘ ^ĞĐƚŝŽŶϮ͘ϰ͘Ϯ͘ϯ͕ƉĂŐĞϮͲϮϳĂŶĚϮϴ͕ĨŽŽƚŶŽƚĞϭdŚĞƉƌŽũĞĐƚƉƌŽƉŽƐĞƐƚŚĂƚƚŚĞƌĞƐƚŽƌĞĚŚŝƐƚŽƌŝĐďƵŝůĚŝŶŐƐďĞƉůĂĐĞĚŝŶƚŚĞWƵďůŝĐWĂƌŬ͘ƐƐƵĐŚƚŚĞďƵŝůĚŝŶŐƐǁŽƵůĚďĞŵĂŝŶƚĂŝŶĞĚďLJƚŚĞŝƚLJĂƐƉĂƌƚŽĨƚŚĞWƵďůŝĐWĂƌŬ͘A.1-15A.1-168-193
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 5 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭ ^d, d/^Es/^h>Z ^KhZ ^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹ^ĞĐƚŝŽŶϯ͘ϭĞƐƚŚĞƚŝĐƐĂŶĚsŝƐƵĂůZĞƐŽƵƌĐĞƐϭ ^ĞĐƚŝŽŶϯ͘ϭ͘ϭ͘Ϯ͕ƉĂŐĞϯ͘ϭͲϯ͕ǀŝĐŝŶŝƚLJĚĞƐĐƌŝƉƚŝŽŶʹƚŽƉŽĨƉĂŐĞdŚŝƐƉĂƌĂŐƌĂƉŚĚĞƐĐƌŝďĞƐDŽƵŶƚĂŝŶďƌŽŽŬŚƵƌĐŚĂƐĂƐŝŶŐůĞͲƐƚŽƌLJďƵŝůĚŝŶŐ͖ŚŽǁĞǀĞƌ͕ŝƚĚŽĞƐŶŽƚƐƉĞĐŝĨLJƚŚĂƚƚŚĞďƵŝůĚŝŶŐŝƐϯϱĨĞĞƚƚĂůů͘dŚŝƐƐĞĐƚŝŽŶĨĂŝůƐƚŽŵĞŶƚŝŽŶƚŚĞŶĞĂƌďLJ<^zĨĂĐŝůŝƚLJ͘Ϯ ^ĞĐƚŝŽŶϯ͘ϭ͘ϭ͘ϰ͕ƉĂŐĞϯ͘ϭͲϴ͕ďƵůůĞƚƐϭĂŶĚϮŽŶƚŚŝƐƉĂŐĞdŚĞƐĞďƵůůĞƚƐĨĂŝůƚŽŵĞŶƚŝŽŶƚŚĂƚƌŽƵŐŚůLJƉĂƌĂůůĞůƚŽƚŚĞƚƌĂŝů;<sηϰͿĂŶĚĂƉƉƌŽdžŝŵĂƚĞůLJϰϬϬͲϲϬϬĨƚĂǁĂLJĂƌĞƚŚĞĨŽůůŽǁŝŶŐĨĞĂƚƵƌĞƐ͗ŽƐƚĐŽůŽĂĚŝŶŐĚŽĐŬƐ͕ŽƐƚĐŽĨƵĞůƐƚĂƚŝŽŶ͕ĂŶĚ,ŽŵĞĞƉŽƚůŽĂĚŝŶŐĚŽĐŬƐ͘dŚĞĨĞĂƚƵƌĞƐĂƌĞĐůĞĂƌůLJǀŝƐŝďůĞĂŶĚĂƵĚŝďůĞĨƌŽŵƚŚĞƚƌĂŝů͘ϯ ^ĞĐƚŝŽŶϯ͘ϭ͘ϭ͘ϰ͕ůŽĐĂůƌŽĂĚǁĂLJƐ͕ƉĂŐĞϯ͘ϭͲϵdŚŝƐƐĞĐƚŝŽŶĚŝƐĐƵƐƐĞƐƚŚĞůĞŶŐƚŚƐŽĨďƌĞĂŬƐŝŶǀĞŐĞƚĂƚŝŽŶĂŶĚǀŝĞǁƐĂĨĨŽƌĚĞĚďLJƚŚĞďƌĞĂŬƐŝŶƚŚĞǀĞŐĞƚĂƚŝŽŶŚŽǁĞǀĞƌƚŚĞĚƵƌĂƚŝŽŶŽĨƚŚĞƐĞǀŝĞǁƐŝƐŶŽƚƋƵĂŶƚŝĨŝĞĚ͘ďƌĞĂŬŽĨϮϱϬĨƚĂůŽŶŐ>KsZǁŽƵůĚĂĨĨŽƌĚƚŚĞĨŽůůŽǁŝŶŐǀŝĞǁŝŶŐƚŝŵĞĨŽƌĚƌŝǀĞƌƐĂůŽŶŐ>KsZʹƚŚĞǀŝĞǁǁŽƵůĚůĂƐƚĂƉƉƌŽdžŝŵĂƚĞůLJϮƐĞĐŽŶĚƐĂƐƐƵŵŝŶŐƚŚĞĚƌŝǀĞƌĚŝǀĞƌƚĞĚĂƚƚĞŶĚŝŶŐĨƌŽŵĚƌŝǀŝŶŐ͘ϰ ^ĞĐƚŝŽŶϯ͘ϭ͘ϭ͘ϰ͕ůŽĐĂůƌŽĂĚǁĂLJƐ͕ƉĂŐĞϯ͘ϭͲϵdŚĞǀŝĞǁĨƌŽŵƚŚĞ>KsZďƌŝĚŐĞĨŽƌϯϬϬĨƚǁŽƵůĚůĂƐƚĂƉƉƌŽdžŝŵĂƚĞůLJϮ͘ϮƐĞĐŽŶĚƐ͘ϱ͘ dĂďůĞϯ͘ϭ͘ϭ͕ƉĂŐĞϯ͘ϭͲϮϰ͕sŝƐͲϭ sŝƐͲϭĚĞƐĐƌŝďĞƐĐŚĂŶŐŝŶŐŽĨǀŝĞǁƐĨƌŽŵĂ͞^ƚĂƚĞ^ĐĞŶŝĐ,ŝŐŚǁĂLJ͘͟h^ϭϬϭŝƐŶŽƚĂĚĞƐŝŐŶĂƚĞĚ^ƚĂƚĞ^ĐĞŶŝĐ,ŝŐŚǁĂLJ͘tŚĂƚ^ƚĂƚĞ^ĐĞŶŝĐ,ŝŐŚǁĂLJŝƐďĞŝŶŐƌĞĨĞƌƌĞĚƚŽ͍ϲ͘ dĂďůĞϯ͘ϭ͘ϭ͕ƉĂŐĞϯ͘ϭͲϮϰ͕sŝƐͲϮ <sηϰŝƐŶŽƚƐŚŽǁŶĂƐƉĂƌƚŽĨƚŚĞŝƚLJK^ &ŝŐƵƌĞηϭϭ^ĐĞŶŝĐZŽĂĚǁĂLJƐĂŶĚsŝƐƚĂƐDĂƉƉŝŶŐ͘ůƐŽƐĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘ϳ͘ ^ĞĐƚŝŽŶϯ͘ϭ͘ϯ͘ϯ͕/ŵƉĂĐƚƐĂŶĚDŝƚŝŐĂƚŝŽŶDĞĂƐƵƌĞƐ͕ƉĂŐĞϯ͘ϭͲϮϳ͕<sηϮ/ŶƚŚĞďŽƚƚŽŵsŝƐ^ŝŵǁŚĂƚŝƐƚŚĞďƵŝůĚŝŶŐŝŶƚŚĞĐĞŶƚĞƌŽĨƚŚĞǀŝƐƐŝŵŽƉƉŽƐŝƚĞƚŚĞƌŽƵŶĚĂďŽƵƚ͍ϴ͘ DŝƚŝŐĂƚŝŽŶDĞĂƐƵƌĞƐ͕WĂŐĞϯ͘ϭͲϯϭ͕DDsŝƐͲϭ͕ƌĞƋƵŝƌĞŵĞŶƚƐĂŶĚƚŝŵŝŶŐ,ĂǀŝŶŐůĂŶĚƐĐĂƉĞƉůĂŶƚŝŶŐĂŶĚŝƌƌŝŐĂƚŝŽŶ͞ŝŶƉůĂĐĞ͟ƉƌŝŽƌƚŽŝƐƐƵĂŶĐĞŽĨďƵŝůĚŝŶŐƉĞƌŵŝƚƐŝƐŶŽƚƉƌĂĐƚŝĐĂďůĞŽƌĚĞƐŝƌĂďůĞĂƐƚŚĞLJŵĂLJďĞĚĂŵĂŐĞĚďLJĐŽŶƐƚƌƵĐƚŝŽŶ͘dŝŵŝŶŐƐŚŽƵůĚďĞƉƌŝŽƌƚŽŽĐĐƵƉĂŶĐLJŽĨĞĂĐŚƉŚĂƐĞ͘ϵ͘ sŝƐͲϮŝƐĐƵƐƐŝŽŶ͕ƉĂŐĞϯ͘ϭͲϯϰ͘ŽƚƚŽŵŽĨƚŚĞƉĂŐĞĚĞƐĐƌŝƉƚŝŽŶŽĨϯƐƚŽƌLJďƵŝůĚŝŶŐƐdŚŝƐĚŝƐĐƵƐƐŝŽŶĨĂŝůƐƚŽŶŽƚĞƚŚĂƚŶŽŶĞŽĨƚŚĞƉƌŽƉŽƐĞĚďƵŝůĚŝŶŐƐǁŽƵůĚĞdžĐĞĞĚƚŚĞŚĞŝŐŚƚŽĨƚŚĞĞdžŝƐƚŝŶŐDŽƵŶƚĂŝŶďƌŽŽŬŚƵƌĐŚďƵŝůĚŝŶŐ͕ĂƐƐƉĞĐŝĨŝĞĚŝŶ&Z^WdĂďůĞϮͲϮ͕&ŽŽƚŶŽƚĞϱ͘A.1-17A.1-18A.1-19A.1-20A.1-21A.1-22A.1-23A.1-24A.1-258-194
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 6 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭ ^d, d/^Es/^h>Z ^KhZ ^ϭϬ͘ sŝƐͲϮŝƐĐƵƐƐŝŽŶ͕ƉĂŐĞϯ͘ϭͲϯϱ͘dŽƉŽĨƉĂŐĞ͘ƵŝůĚŝŶŐƐĂďŽǀĞƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶ͘dŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶŝƐŶŽƚĂďƵŝůĚŝŶŐŚĞŝŐŚƚůŝŵŝƚĂƚŝŽŶ͘/ƚŝƐĂŐƌŽƵŶĚĞůĞǀĂƚŝŽŶƚŽƉŽŐƌĂƉŚŝĐĂůƌĞĨĞƌĞŶĐĞƚŽůŝŵŝƚƚŚĞĞdžƚĞŶƚŽĨĚĞǀĞůŽƉŵĞŶƚĂƌĞĂ͘ϭϭ͘ sŝƐͲϮŝƐĐƵƐƐŝŽŶ͕ƉĂŐĞϯ͘ϭͲϯϲ͕dƌĂŝůǀŝĞǁƐĚŝƐĐƵƐƐŝŽŶdŚĞĚĞƐĐƌŝƉƚŝŽŶŽǀĞƌƐƚĂƚĞƐƚŚĞƋƵĂůŝƚLJŽĨƚŚĞǀŝĞǁĚĞƉŝĐƚĞĚŝŶ<sηϰƐĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘ϭϮ͘ sŝƐͲϮ͕ŝƐĐƵƐƐŝŽŶ͕ƉĂŐĞϯ͘ϭ͘Ͳϯϳ DŽƵŶƚĂŝŶďƌŽŽŬŚƵƌĐŚŝƐŝĚĞŶƚŝĨŝĞĚĂƐƚŚĞŽŶůLJĚĞǀĞůŽƉŵĞŶƚĂďŽǀĞƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶŝŶƚŚŝƐǀŝĐŝŶŝƚLJ͘<^zƐƚƵĚŝŽƐĂƌĞŝŶƚŚĞǀŝĐŝŶŝƚLJĂŶĚůŽĐĂƚĞĚĂďŽǀĞƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶ͘ϭϯ͘ sŝƐͲϮ͕ƉĂŐĞϯ͘ϭͲϯϳ͕<sϱ͕ƉŝĐƚƵƌĞĂŶĚsŝƐ^ŝŵdŚĞǀŝƐƐŝŵĂƉƉĞĂƌƐƚŽŚĂǀĞƚŚĞƉƌŽƉŽƐĞĚďƵŝůĚŝŶŐƐŝŶƚŚĞĐĞŶƚĞƌŽĨƚŚĞƵƉƉĞƌƚĞƌƌĂĐĞƉůĂĐĞĚƚŽŽŚŝŐŚ͘dŚĞĂƉƉůŝĐĂŶƚƐƚŝƉƵůĂƚĞĚŝŶƚŚĞ&Z^WƚŚĂƚŶŽďƵŝůĚŝŶŐŽŶƚŚĞƵƉƉĞƌƚĞƌƌĂĐĞǁŝůůĞdžĐĞĞĚƚŚĞŚĞŝŐŚƚŽĨƚŚĞĞdžŝƐƚŝŶŐDŽƵŶƚĂŝŶďƌŽŽŬŚƵƌĐŚ;ĞůĞǀĂƚŝŽŶϮϯϴͿ͘ϭϰ sŝƐͲϮ͕ƉĂŐĞϯ͘ϭͲϯϴ͕<sϱĚŝƐĐƵƐƐŝŽŶʹ͞ZĞĐƌĞĂƚŝŽŶĂůŝƐƚƐĐƵƌƌĞŶƚůLJĞdžƉĞĐƚƐĐĞŶŝĐǀŝĞǁƐŽĨŚŝŐŚͲƋƵĂůŝƚLJŶĂƚƵƌĂůŚĂďŝƚĂƚƐ͟/ƐƚŚĞƌĞĂŶLJƋƵĂŶƚŝƚĂƚŝǀĞĞǀŝĚĞŶĐĞƌĞŐĂƌĚŝŶŐƚƌĂŝůƐŝŶ^ĂŶ>ƵŝƐKďŝƐƉŽƚŽƐƵƉƉŽƌƚƚŚŝƐƐƚĂƚĞŵĞŶƚ͍dŚŝƐƐŽƵŶĚƐůŝŬĞŽƉŝŶŝŽŶŽƌƐƉĞĐƵůĂƚŝŽŶ͘ƐŶŽƚĞĚĂƚƚŚĞƌĞĐĞŶƚWůĂŶŶŝŶŐŽŵŵŝƐƐŝŽŶŚĞĂƌŝŶŐŽĨƚŚĞ /ZƚŚĞƌĞŝƐĚŝƐĂŐƌĞĞŵĞŶƚĂďŽƵƚƚŚŝƐƐƚĂƚĞŵĞŶƚ͘dŚĞĂƉƉůŝĐĂŶƚĂŶĚĂƚůĞĂƐƚϮŵĞŵďĞƌƐŽĨƚŚĞWůĂŶŶŝŶŐŽŵŵŝƐƐŝŽŶĚŝƐĂŐƌĞĞƚŚĂƚƚŚŝƐŝƐĂƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞŝŵƉĂĐƚ͘ϭϱ͘ sŝƐͲϯ͕ƉĂŐĞϯ͘ϭͲϯϵ͕ƵŵƵůĂƚŝǀĞ/ŵƉĂĐƚƐ͕ďŽƚƚŽŵŽĨƚŚĞƉĂŐĞʹůĂƐƚůŝŶĞdŚŝƐůŝŶĞƐĂLJƐƚŚĞƉƌŽũĞĐƚǁŽƵůĚ͞ŽďƐƚƌƵĐƚƐĐĞŶŝĐǀŝĞǁƐŽĨŽƉĞŶƐƉĂĐĞƐĨƌŽŵƚŚĞŝƚLJĂŶĚ/ƌŝƐŚ,ŝůůƐEĂƚƵƌĂůZĞƐĞƌǀĞ͘͟dŚŝƐŝƐŶŽƚĐŽƌƌĞĐƚĂŶĚŝƐŝŶĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞ /ZĂŶĂůLJƐŝƐƚŚĂƚĚŽĞƐŶŽƚƐŚŽǁĂŶLJ͞ŽďƐƚƌƵĐƚŝŽŶ͘͟KďƐƚƌƵĐƚŝŽŶŝƐĚĞĨŝŶĞĚĂƐďůŽĐŬĂŐĞ͘A.1-26A.1-27A.1-28A.1-29A.1-30A.1-318-195
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 7 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘Ϯ'Z/h>dhZ>Z ^KhZ ^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϮŐƌŝĐƵůƚƵƌĂůZĞƐŽƵƌĐĞƐϭ dĂďůĞϯ͘ϮͲϮ͕ƉĂŐĞϯ͘ϮͲϱŽƚŚĞĂĐƌĞĂŐĞƐŝŶƚŚĞWƌŽũĞĐƚ^ŝƚĞĂĐĐŽƵŶƚĨŽƌĚĞĚƵĐƚŝŽŶƐĨŽƌŝƚĞŵƐƐƵĐŚĂƐĐƌĞĞŬƐ͕ƉƌŽƚĞĐƚĞĚƉůĂŶƚƐƉĞĐŝĞƐ͕ĞƚĐ͘ƚŚĂƚǁŽƵůĚŶŽƚďĞĨĂƌŵĂďůĞ͘A.1-328-196
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 8 &ZKKDZE, /ZWZ E^^K/d ^Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϯ/ZYh>/dzE','ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϯŝƌYƵĂůŝƚLJĂŶĚ'ƌĞĞŶŚŽƵƐĞ'ĂƐ ŵŝƐƐŝŽŶƐϭ WĂŐĞϯ͘ϯͲϯϯ͕DŝƚŝŐĂƚŝŽŶDĞĂƐƵƌĞYͲϯ dŚĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞŝƐǁƌŝƚƚĞŶǁŝƚŚƚŚĞƉƌĞƐƵŵƉƚŝŽŶƚŚĂƚŽĨĨͲƐŝƚĞŵŝƚŝŐĂƚŝŽŶƐƚƌĂƚĞŐLJǁŝůůďĞƌĞƋƵŝƌĞĚĨŽƌĐŽŶƐƚƌƵĐƚŝŽŶƌĞůĂƚĞĚĞƋƵŝƉŵĞŶƚĞŵŝƐƐŝŽŶƐ͖ŚŽǁĞǀĞƌ͕dĂďůĞϯ͘ϯͲϳŝŶĚŝĐĂƚĞƐƚŚĂƚƚŚĞWƌŽũĞĐƚ͛ƐŵŝƚŝŐĂƚĞĚĐŽŶƐƚƌƵĐƚŝŽŶĞŵŝƐƐŝŽŶƐǁŽƵůĚŶŽƚĞdžĐĞĞĚƚŚĞW͛ƐdŝĞƌϮƋƵĂƌƚĞƌůLJƚŚƌĞƐŚŽůĚĨŽƌEKdžнZK'ƐĞŵŝƐƐŝŽŶƐŽƌWDĞŵŝƐƐŝŽŶƐ͘/ĨƚŚĞWƌŽũĞĐƚĚŽĞƐŶŽƚĞdžĐĞĞĚƚŚĞW͛ƐdŝĞƌϮƋƵĂƌƚĞƌůLJƚŚƌĞƐŚŽůĚƐ͕ƚŚĞŶŶŽŵŝƚŝŐĂƚŝŽŶƉĂLJŵĞŶƚƐǁŽƵůĚďĞƌĞƋƵŝƌĞĚ͘dŚĞŽŶƐƚƌƵĐƚŝŽŶĐƚŝǀŝƚLJDĂŶĂŐĞŵĞŶƚWůĂŶǁŝůůďĞƐƵďŵŝƚƚĞĚŝŶĂĐĐŽƌĚĂŶĐĞǁŝƚŚDDYͲϭƚŽĞŶƐƵƌĞƚŚĂƚƚŚŝƐŝƐƚŚĞĐĂƐĞ͘WůĞĂƐĞƌĞǀŝƐĞDDYͲϯƚŽŝŶĚŝĐĂƚĞƚŚĂƚƚŚĞŽĨĨƐŝƚĞŵŝƚŝŐĂƚŝŽŶƐƚƌĂƚĞŐLJŵĂLJŶŽƚďĞƌĞƋƵŝƌĞĚ͘Ϯ WĂŐĞϯ͘ϯͲϰϲ͕/ŵƉĂĐƚYͲϮdŚĞƌĞƐŝĚƵĂůŝŵƉĂĐƚĚŝƐĐƵƐƐŝŽŶŝƐĐŽŶĨƵƐŝŶŐƌĞŐĂƌĚŝŶŐŽƉĞƌĂƚŝŽŶĂůZK'ĂŶĚEKdžĞŵŝƐƐŝŽŶƐ͘dŚĞ /ZƐƚĂƚĞƐƚŚĂƚƚŚĞŝŵƉĂĐƚǁŽƵůĚďĞĐŽŶƐŝĚĞƌĞĚůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚďLJƚŚĞWƉĞƌƚŚĞW͛Ɛ YŝƌYƵĂůŝƚLJ,ĂŶĚŬŝĨĂůůƐƚĂŶĚĂƌĚŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐĂƌĞŝŵƉůĞŵĞŶƚĞĚ͘,ŽǁĞǀĞƌ͕ƚŚĞ /ZƚŚĞŶƐƚĂƚĞƐƚŚĂƚƚŚĞŽƉĞƌĂƚŝŽŶĂůĞŵŝƐƐŝŽŶƐƌĞĚƵĐƚŝŽŶƐďLJŝŵƉůĞŵĞŶƚŝŶŐƚŚĞW͛ƐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐĐĂŶŶŽƚďĞƋƵĂŶƚŝĨŝĞĚĂŶĚƚŚĞŝŵƉĂĐƚŝƐƚŚĞƌĞďLJĚĞƚĞƌŵŝŶĞĚƚŽďĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘dŚĞ /ZƐŚŽƵůĚďĞĂďůĞƚŽĂƐƐŝŐŶĞŵŝƐƐŝŽŶƐƌĞĚƵĐƚŝŽŶĨĂĐƚŽƌƐƚŽƚŚĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐĂŶĚƋƵĂŶƚŝĨLJƚŚĞŵŝƚŝŐĂƚŝŽŶƉƌŽũĞĐƚĞŵŝƐƐŝŽŶƐ͘ϯ WĂŐĞϯ͘ϯͲϰϵ͕/ŵƉĂĐƚYͲϰdŚĞ /ZŝƐƵŶĐůĞĂƌĂƐƚŽƚŚĞůĞǀĞůŽĨƐĞǀĞƌŝƚLJĨŽƌƚŚŝƐŝŵƉĂĐƚ͘KŶƉĂŐĞϯ͘ϯͲϰϵƵŶĚĞƌƚŚĞ/ŵƉĂĐƚ^ƚĂƚĞŵĞŶƚƚŚĞŝŵƉĂĐƚŝƐůŝƐƚĞĚĂƐ>ĞƐƐƚŚĂŶ^ŝŐŶŝĨŝĐĂŶƚǁŝƚŚDŝƚŝŐĂƚŝŽŶ͖ŚŽǁĞǀĞƌ͕ǁŝƚŚŝŶƚŚĞZĞƐŝĚƵĂů/ŵƉĂĐƚĚŝƐĐƵƐƐŝŽŶŽŶƉĂŐĞϯ͘ϯͲϱϱƚŚĞŝŵƉĂĐƚŝƐůŝƐƚĞĚĂƐƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘dŚŝƐĚŝƐĐƌĞƉĂŶĐLJƐŚŽƵůĚďĞĐŽƌƌĞĐƚĞĚ͘ϰ WĂŐĞϯ͘ϯͲϱϱ͕/ŵƉĂĐƚYͲϰZĞƐŝĚƵĂů/ŵƉĂĐƚƐdŚĞ /ZƐƚĂƚĞƐƚŚĂƚƚŚĞĞŵŝƐƐŝŽŶƐƌĞĚƵĐƚŝŽŶƐƚŚƌŽƵŐŚŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨƌĞƋƵŝƌĞĚ','ŵŝƚŝŐĂƚŝŽŶĐĂŶŶŽƚďĞƋƵĂŶƚŝĨŝĞĚ͘dŚĞ /ZĚŽĞƐŶ͛ƚĂƚƚĞŵƉƚƚŽƋƵĂŶƚŝĨLJƚŚĞƐĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐŽƌŽƚŚĞƌĐŝƚLJͲůĞĂĚ','ƌĞĚƵĐƚŝŽŶƐƚŚĂƚĂƌĞĂůƌĞĂĚLJŝŶƉƌŽŐƌĞƐƐ͕ƐƵĐŚĂƐƚŚĞŝƚLJ͛ƐƉĂƌƚŝĐŝƉĂƚŝŽŶŝŶƚŚĞDŽŶƚĞƌĞLJĂLJŽŵŵƵŶŝƚLJWŽǁĞƌƉĂƌƚŶĞƌƐŚŝƉ͕ŽƌƚŚĞƵƐĞŽĨƚŚĞĂŶĂĞƌŽďŝĐĚŝŐĞƐƚĞƌĨŽƌƉƌŽĐĞƐƐŝŶŐŽƌŐĂŶŝĐǁĂƐƚĞŝŶƚŽĐůĞĂŶĞŶĞƌŐLJ͘dŚĞ /ZƐŚŽƵůĚďĞƌĞǀŝƐĞĚƚŽƌĞĨůĞĐƚƚŚĞĐƵƌƌĞŶƚ','ĞŵŝƐƐŝŽŶƐƌĞĚƵĐƚŝŽŶƉƌŽŐƌĂŵƐĂůƌĞĂĚLJŝŶĞĨĨĞĐƚƚŚĂƚĂƌĞŶŽƚŝŶĐůƵĚĞĚŝŶƚŚĞĚĞĨĂƵůƚĂů DŽĚŵŽĚĞů͘ϱWĂŐĞϯ͘ϯͲϱϳ͕/ŵƉĂĐƚYͲϱ dŚĞ /ZŝŶĐůƵĚĞƐǀĞŚŝĐůĞƌĞůĂƚĞĚƚƌĂĨĨŝĐŐĞŶĞƌĂƚŝŽŶƌĂƚĞƐƚŚĂƚŵĂLJŶŽƚƌĞĨůĞĐƚƚŚĞƉƌŽƉŽƐĞĚƵƐĞƐŽŶͲƐŝƚĞ͘/ƚƐĞĞŵƐŝŵƉƌŽďĂďůĞƚŚĂƚƚŚĞsDdƐŐĞŶĞƌĂƚĞĚďLJƚŚĞA.1-33A.1-34A.1-35A.1-36A.1-378-197
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 9 &ZKKDZE, /ZWZ E^^K/d ^Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϯ/ZYh>/dzE','WƌŽũĞĐƚǁŽƵůĚďĞϮϴƉĞƌĐĞŶƚŚŝŐŚĞƌƚŚĂŶƚŚĞĂǀĞƌĂŐĞĨŽƌƚŚĞŝƚLJ͛ƐƐƉŚĞƌĞŽĨŝŶĨůƵĞŶĐĞ͘dŚĞsDdĨĂĐƚŽƌƐƵƐĞĚƐŚŽƵůĚďĞƌĞǀŝĞǁĞĚƌĞǀŝƐĞĚĂƐŶĞĐĞƐƐĂƌLJ͘ƌĞĚƵĐƚŝŽŶŝŶƚŚĞsDdƌĂƚĞƐƵƐĞĚǁŽƵůĚĂůƐŽƌĞƐƵůƚŝŶƌĞĚƵĐƚŝŽŶƐŽĨŽƉĞƌĂƚŝŽŶĂůĞŵŝƐƐŝŽŶƐĨŽƌƚŚĞWƌŽũĞĐƚ͘ϲ WĂŐĞϯ͘ϯͲϱϰ͕DDYͲϲdŚŝƐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƌĞƋƵŝƌĞƐƚŚĂƚƚŚĞƉƉůŝĐĂŶƚǁŽƌŬǁŝƚŚƚŚĞŝƚLJĂŶĚWƚŽƌĞĚƵĐĞ','ĞŵŝƐƐŝŽŶƐƚŽƚŚĞŵĂdžŝŵƵŵĞdžƚĞŶƚĨĞĂƐŝďůĞ͘/ƚƐŚŽƵůĚďĞŶŽƚĞĚƚŚĂƚƚŚĞůĂƌŐĞƐƚƐŽƵƌĐĞŽĨŽƉĞƌĂƚŝŽŶĂůĞŵŝƐƐŝŽŶƐǁŝůůďĞǀĞŚŝĐůĞƐ͕ǁŚŝĐŚĂƌĞŶŽƚƌĞŐƵůĂƚĞĚĚŝƌĞĐƚůLJďLJƚŚĞŝƚLJŽƌW͕ďƵƚĂƚĂƐƚĂƚĞĂŶĚĨĞĚĞƌĂůůĞǀĞů͘dŚĞŵŝƚŝŐĂƚŝŽŶƉƌŽŐƌĂŵǁŝůůŶĞĞĚƚŽĂĐŬŶŽǁůĞĚŐĞƚŚĞůŝŵŝƚĂƚŝŽŶƐŝŶĂĐŚŝĞǀŝŶŐŶĞƚnjĞƌŽ','ĞŵŝƐƐŝŽŶƐĂŶĚƚŚĞƉƉůŝĐĂŶƚƐŚŽƵůĚŶŽƚďĞƉĞŶĂůŝnjĞĚĨŽƌŵŽďŝůĞƐŽƵƌĐĞĞŵŝƐƐŝŽŶƐƚŚĂƚĂƌĞƌĞŐƵůĂƚĞĚĂƚƚŚĞƐƚĂƚĞĂŶĚĨĞĚĞƌĂůůĞǀĞů͘A.1-37cont.A.1-388-198
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 10 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϯ/ZYh>/dzE','ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϯŝƌYƵĂůŝƚLJĂŶĚ'ƌĞĞŶŚŽƵƐĞ'ĂƐ ŵŝƐƐŝŽŶƐϭ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϭϲ /ƚŝƐŝŶĨĞĂƐŝďůĞĨŽƌƚŚĞĚĞǀĞůŽƉĞƌƚŽŽƉĞƌĂƚĞĂ,hͬEŽĚĞŽĨƚŚĞďŝĐLJĐůĞͲƐŚĂƌĞƉƌŽŐƌĂŵĂƐŚĞͬƐŚĞŵĂLJŶŽƚďĞĂƉƌŽƉĞƌƚLJŽǁŶĞƌŽƌďƵƐŝŶĞƐƐŽƉĞƌĂƚŽƌƵƉŽŶĐŽŵƉůĞƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘Ϯ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϭϳ ƌĞnjĞƌŽĞŵŝƐƐŝŽŶƐŚƵƚƚůĞǀĞŚŝĐůĞƐĐƵƌƌĞŶƚůLJĨĞĂƐŝďůĞĂŶĚĂǀĂŝůĂďůĞ͍ϯ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϭϵ tŚŽǁŝůůŽƉĞƌĂƚĞƚŚŝƐƐĞƌǀŝĐĞ͍dŚĞĚĞǀĞůŽƉŵĞŶƚĐŽŶƐŝƐƚƐŽĨƐĞǀĞƌĂůƐĞƉĂƌĂƚĞůLJŽǁŶĞĚĂŶĚŽƉĞƌĂƚĞĚĐŽŵƉŽŶĞŶƚƐ͘ϰ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϮϭ tŚŽǁŝůůŽƉĞƌĂƚĞƚŚŝƐƐĞƌǀŝĐĞ͍dŚĞĚĞǀĞůŽƉŵĞŶƚĐŽŶƐŝƐƚƐŽĨƐĞǀĞƌĂůƐĞƉĂƌĂƚĞůLJŽǁŶĞĚĂŶĚŽƉĞƌĂƚĞĚĐŽŵƉŽŶĞŶƚƐ͘ϱ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϮϯ dŚĞ&Z^WƵƉŽŶŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŝůůŶŽƚďĞĂƐŝŶŐůĞŽǁŶĞƌƐŚŝƉĂďůĞƚŽŝŵƉůĞŵĞŶƚƚŚŝƐƐĞƌǀŝĐĞ͘ϲ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϮϱ dŚĞ&Z^WƵƉŽŶŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŝůůŶŽƚďĞĂƐŝŶŐůĞŽǁŶĞƌƐŚŝƉĂďůĞƚŽŝŵƉůĞŵĞŶƚƚŚŝƐƐĞƌǀŝĐĞ͘ϳ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϮϵ dŚĞ&Z^WƵƉŽŶŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŝůůŶŽƚďĞĂƐŝŶŐůĞŽǁŶĞƌƐŚŝƉĂďůĞƚŽŝŵƉůĞŵĞŶƚƚŚŝƐƐĞƌǀŝĐĞ͘ϴ dĂďůĞϯ͘ϯͲϵ͕ƉĂŐĞϯ͘ϯͲϰϬ͕DĞĂƐƵƌĞηϯϳ ƵĞƚŽƚŚĞŵŝdžŽĨƵƐĞƐƚŚĞĂƉƉůŝĐĂŶƚĚŽĞƐŶ͛ƚďĞůŝĞǀĞƚŚŝƐŝƐĨĞĂƐŝďůĞ͘ϵ ZĞƐŝĚƵĂů/ŵƉĂĐƚĚŝƐĐƵƐƐŝŽŶ͕ƉĂŐĞϯ͘ϯͲϰϲ͕ŝƐĐƵƐƐŝŽŶŽĨƌĞƐŝĚƵĂůŝŵƉĂĐƚƐdŚŝƐůĂĐŬŽĨƋƵĂŶƚŝĨŝĂďůĞŝŶĨŽƌŵĂƚŝŽŶƌĞŐĂƌĚŝŶŐƉŽƚĞŶƚŝĂůŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐƉƵƚƐƚŚĞĚŝƐĐƵƐƐŝŽŶŝŶƚŽƚŚĞƌĞĂůŵŽĨƐƉĞĐƵůĂƚŝŽŶƌĞŐĂƌĚŝŶŐĂĐŚŝĞǀŝŶŐĂĐƚƵĂůƌĞĚƵĐƚŝŽŶƐ͘DĂŶLJŽĨƚŚĞƐƵŐŐĞƐƚĞĚŵĞĂƐƵƌĞƐĂƌĞŶŽƚĨĞĂƐŝďůLJĂĐŚŝĞǀĂďůĞ͘^ĞĞĐŽŵŵĞŶƚηϭͲηϴĂďŽǀĞ͘ϭϬ WĂŐĞϯ͘ϯͲϱϯ͕DDYͲϱdŚĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞĂƐǁƌŝƚƚĞŶĚŽĞƐŶŽƚĂƉƉĞĂƌƚŽďĞĨĞĂƐŝďůĞƚŽĂĐŚŝĞǀĞ͘&ŽƌĞdžĂŵƉůĞ͕ƚŚĞŚĞĂůƚŚĐĂƌĞĨĂĐŝůŝƚLJǁŝůůƌĞƋƵŝƌĞďĂĐŬƵƉƉŽǁĞƌĂŶĚĐƵƌƌĞŶƚďĂƚƚĞƌLJƚĞĐŚŶŽůŽŐLJĚŽĞƐŶŽƚĂƉƉĞĂƌƚŽŚĂǀĞƚŚĞĐĂƉĂĐŝƚLJƚŽŽƉĞƌĂƚĞƚŚĞĨĂĐŝůŝƚLJĨŽƌƚŚĞƉŽƚĞŶƚŝĂůŶĞĞĚĞĚĚƵƌĂƚŝŽŶ͘/ƚŝƐƵŶĐůĞĂƌǁŚLJƚŚĞƐĞŵĞĂƐƵƌĞƐǁŽƵůĚďĞŝŶĐůƵĚĞĚŽŶƚŚĞƐƵďĚŝǀŝƐŝŽŶŵĂƉĂƐƚŚĞŵĂƉĚŽĞƐŶŽƚŝŶĐůƵĚĞĐŽŶƐƚƌƵĐƚŝŽŶŽĨƐŽůĂƌĨĂĐŝůŝƚŝĞƐŽƌďƵŝůĚŝŶŐƐ͍ϭϭ WĂŐĞϯ͘ϯͲϱϰ͕DDYͲϲ͕ϰƚŚďƵůůĞƚ ,ŽǁǁŽƵůĚĐĂƌƐŚĂƌŝŶŐŽƉƉŽƌƚƵŶŝƚŝĞƐďĞƉƌŽǀŝĚĞĚǁŝƚŚŝŶƚŚĞDĂĚŽŶŶĂƉŽƌƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚ͍dŚĞƐĞŵĂLJďĞƵŶŝƚƐƐŽůĚƚŽƚŚĞƉƵďůŝĐǁŝƚŚŽƵƚĂŶ,K͘ϭϮ WĂŐĞϯ͘ϯͲϱϰ͕DDYͲϲ͕ϱƚŚďƵůůĞƚ dŚŝƐĂƉƉĞĂƌƐƚŽďĞĂ͞ďůĂŶŬĐŚĞĐŬ͟ŵŝƚŝŐĂƚŝŽŶĂƉƉƌŽĂĐŚǁŝƚŚŶŽƋƵĂŶƚŝĨŝĞĚŵŝƚŝŐĂƚŝŽŶĐŽƐƚŽƌĨĞĂƐŝďŝůŝƚLJĚĞƚĞƌŵŝŶĂƚŝŽŶ͘tŚŽĚĞƚĞƌŵŝŶĞƐǁŚĂƚŝƐĨĞĂƐŝďůĞ͍A.1-39A.1-40A.1-41O.8-42A.1-43A.1-44A.1-45A.1-46A.1-47A.1-48A.1-49A.1-508-199
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 11 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϯ/ZYh>/dzE','ϭϯ WĂŐĞϯ͘ϯͲϱϱ͕DDYͲϲ͕ZĞƋƵŝƌĞŵĞŶƚƐĂŶĚƚŝŵŝŶŐtŚLJǁŽƵůĚƚŚĞƐĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐďĞŝŶĐůƵĚĞĚŽŶƚŚĞsdD͍dŚĞLJĂƌĞŶŽƚĂƉƉƌŽƉƌŝĂƚĞŽŶĂƐƵďĚŝǀŝƐŝŽŶŵĂƉ͘tŚŽĚĞƚĞƌŵŝŶĞƐǁŚĂƚŝƐĨĞĂƐŝďůĞ͍ϭϰ WĂŐĞϯ͘ϯͲϱϱ͕ZĞƐŝĚƵĂů/ŵƉĂĐƚƐdŚŝƐĚŝƐĐƵƐƐŝŽŶůĂĐŬƐƐƉĞĐŝĨŝĐŝƚLJĂŶĚͬŽƌƋƵĂŶƚŝĨŝĐĂƚŝŽŶĂŶĚĂƉƉĞĂƌƐƚŽĞŶŐĂŐĞŝŶƐƉĞĐƵůĂƚŝŽŶƌĞŐĂƌĚŝŶŐƚŚĞĞĨĨĞĐƚŝǀĞŶĞƐƐŽĨƚŚĞƌĞƋƵŝƌĞĚŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐĂŶĚĨŝŶĂůůLJĂƉƉĞĂƌƐƚŽĐŽŶĐůƵĚĞŝƚĐĂŶŶŽƚďĞƐŽůǀĞĚƐŽŝƚŵƵƐƚďĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘͞ĐŽŶƚŝŶƵĞĚƉŽƚĞŶƚŝĂůĨŽƌĞdžĐĞĞĚĂŶĐĞ͟ŝƐŶŽƚĂŶĂƉƉƌŽƉƌŝĂƚĞƚŚƌĞƐŚŽůĚĨŽƌĚĞƚĞƌŵŝŶĂƚŝŽŶŽĨƐŝŐŶŝĨŝĐĂŶĐĞ͘ϭϱ WĂŐĞƐϯ͘ϯͲϱϲĂŶĚϱϳ͕WŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶĐŽŶƐŝƐƚĞŶĐLJǁŝƚŚƚŚĞůĞĂŶŝƌWůĂŶ/ŶŝƚĞŵηϭŽŶƉĂŐĞϯ͘ϯͲϱϲƚŚĞƚĞdžƚƐƚĂƚĞƐ͞dŚĞŝŶĐƌĞĂƐĞŽĨĂƉƉƌŽdžŝŵĂƚĞůLJϭ͕ϮϯϭƉĞƌƐŽŶƐďLJƚŚĞƉƌŽũĞĐƚŝƐǁŝƚŚŝŶƚŚĞƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶƐƵŶĚĞƌƚŚĞůĞĂŶŝƌWůĂŶ͘͟,ŽǁĞǀĞƌ͕ŽŶƉĂŐĞϯ͘ϯͲϱϳŝŶƚŚĞŝƚĞŵηϮĚŝƐĐƵƐƐŝŽŶƚŚĞƐƚĂƚĞƐ͞dŚĞƉŽƉƵůĂƚŝŽŶŐƌŽǁƚŚĨƌŽŵƚŚĞƉƌŽũĞĐƚǁŽƵůĚĞdžĐĞĞĚƚŚĞůĞĂŶŝƌWůĂŶƉƌŽũĞĐƚŝŽŶƐ͘͟͟dŚĞƐĞƐƚĂƚĞŵĞŶƚƐĐŽŶĨůŝĐƚ͘ϭϲ WĂŐĞϯ͘ϯͲϱϲ͕ŝƚĞŵηϭĚŝƐĐƵƐƐŝŽŶ dŚĞĚŝƐĐƵƐƐŝŽŶŝŶĚŝĐĂƚĞƐƚŚĞƉƌŽũĞĐƚŝƐŝŶĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞ>h ĂƐŝƚĐŽŶƚĂŝŶƐŵŽƌĞƚŚĂŶϯϱϬĚǁĞůůŝŶŐƵŶŝƚƐ͘,ŽǁĞǀĞƌ͕ƚŚĞĚŝƐĐƵƐƐŝŽŶĚŽĞƐŶŽƚƐƚĂƚĞƚŚĂƚƚŚĞƉƌŽƉŽƐĞĚĐŽŵŵĞƌĐŝĂůƵƐĞŝƐĨĂƌůĞƐƐƚŚĂŶƚŚĞŵĂdžŝŵƵŵĂůůŽǁĞĚƵƐĞŽĨϯϱϬ͕ϬϬϬƐĨ;ϭϬϬ͕ϬϬϬƉƌŽƉŽƐĞĚͿ͘/ŶƚŚĞĐŽŶƚĞdžƚŽĨĂŝƌƋƵĂůŝƚLJ͕ƚŚĞƌĞĚƵĐƚŝŽŶŽĨĐŽŵŵĞƌĐŝĂůƐƉĂĐĞŝƐƐŝŐŶŝĨŝĐĂŶƚ͘ϭϳ WĂŐĞϯ͘ϯͲϱϲ͕ŝƚĞŵηϭĚŝƐĐƵƐƐŝŽŶ dŚĞĚŝƐĐƵƐƐŝŽŶƐƚĂƚĞƐ͞dŚĞ>h ŽďũĞĐƚŝǀĞƐĂƌĞŝŶƚĞŶĚĞĚƚŽĞŶƐƵƌĞƚŚĂƚƚŚĞƉƌŽũĞĐƚƐŝƚĞŝƐĚĞǀĞůŽƉĞĚƉƌŝŵĂƌŝůLJǁŝƚŚĂĐŽŵƉĂĐƚŵŝdžĞĚͲƵƐĞƉƌŽũĞĐƚ͘͟dŚĞƉƌŽũĞĐƚĐŽŵƉůŝĞƐǁŝƚŚƚŚŝƐŽďũĞĐƚŝǀĞ͘ϭϴ WĂŐĞϯ͘ϯͲϱϳ͕ŝƚĞŵηϮĚŝƐĐƵƐƐŝŽŶŽĨsDd ƚĨĂĐĞǀĂůƵĞƚŚĞsDdĚŝƐĐƵƐƐŝŽŶĂŶĚĐŽŶĐůƵƐŝŽŶƐƐĞĞŵĂƚŽĚĚƐǁŝƚŚƚŚĞŚĞĂǀLJǁĞŝŐŚƚŝŶŐŽĨƚŚĞƉƌŽũĞĐƚƉŽƉƵůĂƚŝŽŶƚŽǁĂƌĚƐĞŶŝŽƌƐĂŶĚƚŚĞƉƌŽǀŝƐŝŽŶŽĨƐŚƵƚƚůĞƐĞƌǀŝĐĞƐĨŽƌƐĞŶŝŽƌƐĂƚsŝůůĂŐŐŝŽ͘dŚĞsDdĐĂůĐƵůĂƚŝŽŶƐŵŝƐĐŚĂƌĂĐƚĞƌŝnjĞƚŚĞĐŽŵŵĞƌĐŝĂůƵƐĞĂƐĂ͞ƌĞŐŝŽŶĂůƐŚŽƉƉŝŶŐĐĞŶƚĞƌ͟ĞǀĞŶƚŚŽƵŐŚŝƚŝƐŽŶůLJĂƉƉƌŽdžŝŵĂƚĞůLJϯϬ͕ϬϬϬƐĨ͘ϭϵ WĂŐĞϯ͘ϯͲϱϴ͕dƌĂŶƐĐŽŶƚƌŽůŵĞĂƐƵƌĞƐ͕ƚŽƉŽĨƉĂŐĞdŚĞĚŝƐĐƵƐƐŝŽŶƐƚĂƚĞƐ͞ĚƵƌŝŶŐĞĂƌůLJƉŚĂƐĞƐŽĨWƌŽũĞĐƚĚĞǀĞůŽƉŵĞŶƚƚƌĂŶƐŝƚƐĞƌǀŝĐĞƐŵĂLJŶŽƚďĞĨƵůůLJŝŶƉůĂĐĞ͘͟dŚŝƐŝƐŝŶĐŽƌƌĞĐƚ͘dŚĞWŚĂƐĞϮĐŽŶƐƚƌƵĐƚŝŽŶŝŶĐůƵĚĞƐƚŚĞĨƌŽŶƚĂŐĞŝŵƉƌŽǀĞŵĞŶƚƐĂůŽŶŐ>KsZŝŶĐůƵĚŝŶŐƉƌŽǀŝƐŝŽŶŽĨĂďƵƐƐƚŽƉĨŽƌƉƵďůŝĐƚƌĂŶƐŝƚ͘dŚŝƐƐƚŽƉŝƐŽŶĂŶĂůƌĞĂĚLJĞdžŝƐƚŝŶŐƉƵďůŝĐƚƌĂŶƐŝƚƌŽƵƚĞ͘ϮϬ WĂŐĞϯ͘ϯͲϱϴ͕ŵŝĚĚůĞŽĨƚŚĞƉĂŐĞ dŚĞĚŝƐĐƵƐƐŝŽŶƐƚĂƚĞƐ͞dŚĞĂŶƚŝĐŝƉĂƚĞĚƉŽƉƵůĂƚŝŽŶŐƌŽǁƚŚĂŶĚŝŶĐƌĞĂƐĞŝŶǀĞŚŝĐůĞƚƌŝƉƐŝƐƉŽƚĞŶƚŝĂůůLJŝŶĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞůĞĂŶŝƌWůĂŶ͘͟dŚŝƐĐŽŶĨůŝĐƚƐǁŝƚŚƚŚĞĐŽŶĐůƵƐŝŽŶŽŶƉĂŐĞϯ͘ϯͲϱϲƚŚĂƚƚŚĞƉƌŽũĞĐƚŝƐǁŝƚŚŝŶƚŚĞƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶƐ͘A.1-51A.1-52A.1-53A.1-54A.1-55A.1-56A.1-57A.1-588-200
02049
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 12 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϯ/ZYh>/dzE','Ϯϭ WĂŐĞϯ͘ϯͲϱϴďŽƚƚŽŵŽĨƉĂŐĞĂŶĚϱϵƚŽƉŽĨƉĂŐĞ^ƚĂƚĞƐƉƌŽũĞĐƚƉŽƉƵůĂƚŝŽŶĞdžĐĞĞĚƐƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶƐŽĨW͘^ĞĞŝƚĞŵηϭϱĂďŽǀĞ͘A.1-598-201
02050
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 13 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϰŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐϭ WĂŐĞϯ͘ϰͲϲ&ŝŐƵƌĞϯ͘ϰͲϭtĞƚůĂŶĚDŝƚŝŐĂƚŝŽŶZĞƋƵŝƌĞŵĞŶƚƐĨŽƌƚŚĞ/ƌŝƐŚ,ŝůůƐWůĂnjĂ;/,WͿĂƐŝŶtŽŽĚĞƐƚŝŵĂƚĞƐϮ͘ϬĂĐƌĞƐŽĨǁĞƚůĂŶĚƐŝŶƚŚĞ/,WĂƐŝŶ͘dŚŝƐŝƐĂĐŽŶƐĞƌǀĂƚŝǀĞĞƐƚŝŵĂƚĞĂŶĚŝƐůŝŬĞůLJůĂƌŐĞƌƚŚĂŶǁŚĂƚƚƌƵůLJĞdžŝƐƚƐ͘ĚĚŝƚŝŽŶĂůůĂŶŐƵĂŐĞƐŚŽƵůĚďĞƉƌŽǀŝĚĞĚŝŶƚŚĞŝŵƉĂĐƚƐĂŶĚŵŝƚŝŐĂƚŝŽŶƐĞĐƚŝŽŶƚŽƌĞƋƵŝƌĞ;ĂůůŽǁͿƚŚĞĂƉƉůŝĐĂŶƚƚŽĚĞůŝŶĞĂƚĞƚŚĞĞdžƚĞŶƚŽĨƚŚĞďĂƐŝŶǁĞƚůĂŶĚŚĂďŝƚĂƚƉƌŝŽƌƚŽŝƐƐƵĂŶĐĞŽĨŐƌĂĚŝŶŐƉĞƌŵŝƚ͘ĂƐŝŶǁĞƚůĂŶĚƐĂƌĞŝŶĂĐŽŶƐƚƌƵĐƚĞĚĨĞĂƚƵƌĞǁŝƚŚĂƌƚŝĨŝĐŝĂůŚLJĚƌŽůŽŐLJĂŶĚƐŚŽƵůĚďĞƐĞƉĂƌĂƚĞĚŝŶƚŚĞŝŵƉĂĐƚĚŝƐĐƵƐƐŝŽŶĨƌŽŵŶĂƚƵƌĂůůLJŽĐĐƵƌƌŝŶŐǁĞƚůĂŶĚƐŽŶƐŝƚĞ͘ŵŽƌĞĂƉƉƌŽƉƌŝĂƚĞŵŝƚŝŐĂƚŝŽŶƌĂƚŝŽĨŽƌďĂƐŝŶǁĞƚůĂŶĚƐƐŚŽƵůĚďĞϭ͗ϭ;ĨŽƌĞĂĐŚĂĐƌĞŝŵƉĂĐƚĞĚƚŚĞƐĂŵĞĂŵŽƵŶƚǁŽƵůĚďĞĐƌĞĂƚĞĚͿƌĂƚŚĞƌƚŚĂŶϯ͗ϭƌĂƚŝŽƉƌĞƐĐƌŝďĞĚĨŽƌǁĞƚůĂŶĚƐ͘tĞƚůĂŶĚƐŝŶƚŚĞ/,WĂƐŝŶǁŽƵůĚďĞƌĞƉůĂĐĞĚŝŶƚŚĞƉƌŽƉŽƐĞĚŽĨĨƐŝƚĞďĂƐŝŶǁŝƚŚƚŚĞĐĂǀĞĂƚƚŚĂƚƉĞƌŝŽĚŝĐŵĂŝŶƚĞŶĂŶĐĞŝƐƉƌĞƐƵŵĞĚƚŽŽĐĐƵƌ͕ǁŚŝĐŚǁŝůůƌĞŵŽǀĞĂĐĐƵŵƵůĂƚĞĚƐĞĚŝŵĞŶƚĂŶĚĂŶLJǀĞŐĞƚĂƚŝŽŶ͕ĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞĐƵƌƌĞŶƚďĂƐŝŶƌĞƋƵŝƌĞŵĞŶƚƐ͕͘ϮWĂŐĞϯ͘ϰ͘ϭϲϯ͘ϰ͘ϭ͘ϱŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐʹ^ƉĞĐŝĂů^ƚĂƚƵƐ^ƉĞĐŝĞƐdĂďůĞϯ͘ϰͲϮͲ^ƉĞĐŝĂůͲ^ƚĂƚƵƐWůĂŶƚƐǁŝƚŚ,ŝŐŚWŽƚĞŶƚŝĂůƚŽKĐĐƵƌŝŶƚŚĞWƌŽũĞĐƚ^ŝƚĞƌĞǁĞƌ͛ƐƐƉŝŶĞĨůŽǁĞƌŚĂƐĂŶŝŶĐŽƌƌĞĐƚƐĐŝĞŶƚŝĨŝĐŶĂŵĞŝŶƚŚĞƚĂďůĞ͘ϯ WĂŐĞϯ͘ϰ͘ϭϳϯ͘ϰ͘ϭ͘ϱŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐʹ^ƉĞĐŝĂů^ƚĂƚƵƐ^ƉĞĐŝĞƐdĂďůĞϯ͘ϰͲϮͲ^ƉĞĐŝĂůͲ^ƚĂƚƵƐWůĂŶƚƐǁŝƚŚ,ŝŐŚWŽƚĞŶƚŝĂůƚŽKĐĐƵƌŝŶƚŚĞWƌŽũĞĐƚ^ŝƚĞDŽƵƐĞŐƌĂLJƵĚůĞLJĂǁĂƐŽďƐĞƌǀĞĚŽŶƐŝƚĞ͘dŚĞ /ZĐŽŶƐƵůƚĂŶƚŚĂƐŝƚĂƐŚŝŐŚƉŽƚĞŶƚŝĂůĂŶĚŝŶŽƚŚĞƌĂƌĞĂƐŽĨƚŚĞƚĞdžƚŝƚŝƐůŝƐƚĞĚĂƐŵŽĚĞƌĂƚĞƚŽŚŝŐŚƉŽƚĞŶƚŝĂůƚŽďĞƉƌĞƐĞŶƚŽŶƐŝƚĞ͘dŚĞƐƉĞĐŝĞƐǁĂƐŽďƐĞƌǀĞĚŽŶƐŝƚĞĂŶĚŝƐƐŚŽǁŶŽŶ&ŝŐƵƌĞϳͲƚŚĞ^ƉĞĐŝĂů^ƚĂƚƵƐWůĂŶƚKĐĐƵƌƌĞŶĐĞƐDĂƉŽĨƚŚĞZ/͘ϰ WĂŐĞϯ͘ϰͲϮϰϯ͘ϰ͘ϭ͘ϱŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐͲ^ƉĞĐŝĂů^ƚĂƚƵƐ^ƉĞĐŝĞƐdŽƉŽĨƉĂŐĞϯ͘ϰͲϮϰƐƚĂƚĞƐƚŚĂƚ͞ŵƵĐŚŽĨ&ƌŽŽŵƌĞĞŬŝƐŵĂƉƉĞĚĂƐĐƌŝƚŝĐĂůŚĂďŝƚĂƚĨŽƌZ>&͘͟dŚŝƐŝƐŝŶĐŽƌƌĞĐƚ͘EŽh^&t^ĚĞƐŝŐŶĂƚĞĚĐƌŝƚŝĐĂůŚĂďŝƚĂƚĨŽƌĂůŝĨŽƌŶŝĂZĞĚ>ĞŐŐĞĚ&ƌŽŐ;Z>&ͿŝƐŽŶƐŝƚĞŽƌŝŶƚŚĞŝŵŵĞĚŝĂƚĞƉƌŽũĞĐƚĂƌĞĂ͘A.1-60A.1-61A.1-62A.1-638-202
02051
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 14 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'z^ƉĞĐŝĂůͲ^ƚĂƚƵƐZĞƉƚŝůĞĂŶĚŵƉŚŝďŝĂŶ^ƉĞĐŝĞƐZĞĨĞƌƚŽ&ŝŐƵƌĞϴŝŶZ/ĨŽƌƚŚĞĞdžƚĞŶƚŽĨĐƵƌƌĞŶƚZ>&ĐƌŝƚŝĐĂůŚĂďŝƚĂƚŝŶĨŝǀĞͲŵŝůĞƌĂĚŝƵƐ͘WƌĞǀŝŽƵƐĚŝƐĐƵƐƐŝŽŶŽĨĐƌŝƚŝĐĂůŚĂďŝƚĂƚŽŶƉĂŐĞϯ͘ϰͲϭϰĐŽƌƌĞĐƚůLJƐƚĂƚĞƐƚŚĂƚZ>&ĐƌŝƚŝĐĂůŚĂďŝƚĂƚŝƐůŽĐĂƚĞĚϮ͘ϭŵŝůĞƐƚŽƚŚĞŶŽƌƚŚŽĨƐŝƚĞ͘ϱ ŽĂƐƚĂůĂŶĚsĂůůĞLJ&ƌĞƐŚǁĂƚĞƌDĂƌƐŚ;tĞƚůĂŶĚͿ͕WĂŐĞϯ͘ϰ͘ϭϬ/ŶƌĞůĂƚŝŽŶƚŽƚŚĞZ>&ĂŶĂůLJƐŝƐ͕ŶŽƌĞĨĞƌĞŶĐĞƚŽŝŶǀĂƐŝǀĞƉůĂŶƚƐĂŶĚƚŚĞƉƌĞĚĂƚŽƌƐ;ŝ͘Ğ͕͘ĐƌĂLJĨŝƐŚͿŽďƐĞƌǀĞĚŝŶŽŶƐŝƚĞĂƋƵĂƚŝĐŚĂďŝƚĂƚĂůŽŶŐĂůůĞ:ŽĂƋƵŝŶǁĞƌĞŝĚĞŶƚŝĨŝĞĚŝŶƚŚĞ /ZĂŶĂůLJƐŝƐ;ƌĞĨĞƌƚŽZ>&^ŝƚĞƐƐĞƐƐŵĞŶƚͿ͘dŚĞĂŵŽƵŶƚŽĨĐƌĂLJĨŝƐŚŝŶƚŚĞĂƋƵĂƚŝĐŚĂďŝƚĂƚĂůŽŶŐĂůůĞ:ŽĂƋƵŝŶŐƌĞĂƚůLJƌĞĚƵĐĞƐƚŚĞƋƵĂůŝƚLJŽĨƚŚĞŽŶƐŝƚĞǁĞƚůĂŶĚͬĂƋƵĂƚŝĐŚĂďŝƚĂƚ͕ĂŶĚǁŚŝůĞZ>&ĐŽƵůĚĐŽͲŽĐĐƵƌ͕ŝƚŝƐůĞƐƐůŝŬĞůLJ͘ /ZĐŽŶƐƵůƚĂŶƚƐƚĂƚĞƐƚŚĂƚƚŚĞƉŽŶĚĞĚǁĂƚĞƌƉƌŽǀŝĚĞƐŚŝŐŚƋƵĂůŝƚLJŚĂďŝƚĂƚĨŽƌƐĞǀĞƌĂůƉůĂŶƚĂŶĚĂŶŝŵĂůƐƉĞĐŝĞƐ͕ďƵƚĚŽĞƐŶŽƚĚŝƐĐƵƐƐƚŚĞĞdžƚĞŶƐŝǀĞŽĐĐƵƌƌĞŶĐĞƐŽĨƌĞĞĚĨĞƐĐƵĞ;ĂŶŽŶͲŶĂƚŝǀĞƉůĂŶƚƐŚŽǁŶŽŶ&ŝŐƵƌĞϰŽĨƚŚĞZ/ĂƐ/ŶƚƌŽĚƵĐĞĚWĞƌĞŶŶŝĂů'ƌĂƐƐůĂŶĚͿƚŚĂƚŝƐƚĂŬŝŶŐŽǀĞƌƚŚĞǁĞƚůĂŶĚĂƌĞĂŶŽƌĚŽĞƐŝƚĚŝƐĐƵƐƐƚŚĞŝŵƉůŝĐĂƚŝŽŶƐŽĨŚŝŐŚĚĞŶƐŝƚLJŽĐĐƵƌƌĞŶĐĞŽĨĐƌĂLJĨŝƐŚĂŶĚƚŚĞŝƌĂĚǀĞƌƐĞŝŵƉĂĐƚƐƚŽŶĂƚŝǀĞĂŵƉŚŝďŝĂŶƐ͘ϲ WĂŐĞϯ͘ϰͲϯϴ/ŵƉĂĐƚʹ/Kϭ͗WƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŝŵƉĂĐƚƐĞŶƐŝƚŝǀĞƌŝƉĂƌŝĂŶ͕ǁĞƚůĂŶĚ͕ĂŶĚŶĂƚŝǀĞŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐŝĚĞŶƚŝĨŝĞĚĂƐƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐƵŶĚĞƌƐƚĂƚĞĂŶĚŝƚLJƉŽůŝĐLJ͘/ŵƉĂĐƚ/KͲϭƐŚŽƵůĚŶŽƚďĞůŝƐƚĞĚĂƐƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘&ƵĞůŵŽĚŝĨŝĐĂƚŝŽŶŝŵƉĂĐƚƐĂƌĞŽǀĞƌƐƚĂƚĞĚĂƐŵƵĐŚŽĨƚŚĞĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶĂƌŽƵŶĚďŽƚŚsŝůůĂŐŐŝŽĂŶĚƚŚĞDĂĚŽŶŶĂƉƌŽũĞĐƚĂƌĞĂƐǁŽƵůĚŽĐĐƵƌŝŶŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚ͘&ƵĞůŵŽĚŝĨŝĐĂƚŝŽŶďƵĨĨĞƌƐŝŶŐƌĂƐƐůĂŶĚƐĂƌŽƵŶĚƐŝƚĞĚĞǀĞůŽƉŵĞŶƚĐĂŶďĞŵŽǁĞĚŽƌŐƌĂnjĞĚŽŶĂƐĞĂƐŽŶĂůďĂƐŝƐ͘ϳ WĂŐĞϯ͘ϰͲϲϬZĞƐŝĚƵĂů/ŵƉĂĐƚƐ͗dŚĞWƌŽũĞĐƚǁŽƵůĚĂůƐŽƌĞƐƵůƚŝŶƚŚĞĚŝƌĞĐƚůŽƐƐŽĨƐĞƌƉĞŶƚŝŶĞďƵŶĐŚŐƌĂƐƐŐƌĂƐƐůĂŶĚƐĐŽƌƌĞƐƉŽŶĚŝŶŐƚŽƚŚĞEĂƐƐĞůůĂƉƵůĐŚƌĂ,ĞƌďĂĐĞŽƵƐůůŝĂŶĐĞƚŚƌŽƵŐŚWƌŽũĞĐƚĚĞǀĞůŽƉŵĞŶƚŽƌƚŚƌŽƵŐŚƌĞŵŽǀĂůŽĨǀĞŐĞƚĂƚŝŽŶĂƐĂƌĞƐƵůƚŽĨŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨtĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚƌĞƐƚŽƌĂƚŝŽŶŚĂǀĞďĞĞŶƉƌŽǀĞŶƚŽŵŝƚŝŐĂƚĞŝŵƉĂĐƚƐƚŽƚŚĞƐĞƚLJƉĞƐŽĨŚĂďŝƚĂƚƐŽŶŽƚŚĞƌƉƌŽũĞĐƚƐ͘dŚĞĂƉƉůŝĐĂŶƚǁŝůůďĞĂďůĞƚŽŵŝƚŝŐĂƚĞŝŵƉĂĐƚƐƚŽǁĞƚůĂŶĚƐĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚ͕ĞƐƉĞĐŝĂůůLJŝŶƚŚĞŶĞǁĐƌĞĞŬĂůŝŐŶŵĞŶƚĂŶĚŽƚŚĞƌůŽĐĂƚŝŽŶƐƚŚĂƚĐĂŶďĞƉƌŽƉŽƐĞĚŽŶƐŝƚĞ͘ŶLJŝŵƉĂĐƚƐƚŽƐĞƌƉĞŶƚŝŶĞďƵŶĐŚŐƌĂƐƐŐƌĂƐƐůĂŶĚĐĂŶďĞŵŝƚŝŐĂƚĞĚŽŶƐŝƚĞ͘ džŝƐƚŝŶŐĂŶŶƵĂůŐƌĂƐƐůĂŶĚĂƌĞĂƐĐĂŶďĞĞŶŚĂŶĐĞĚĂŶĚƌĞƐƚŽƌĞĚƚŚƌŽƵŐŚƐĞĞĚŝŶŐĂŶĚƉůĂŶƚŝŶŐŽĨŶĂƚŝǀĞŐƌĂƐƐĞƐĂŶĚƚĞŵƉŽƌĂƌŝůLJĚŝƐƚƵƌďĞĚĂƌĞĂƐĐĂŶďĞƌĞͲǀĞŐĞƚĂƚĞĚǁŝƚŚĂŶĂƚŝǀĞƐĞĞĚŵŝdžĐŽŵƉŽƐĞĚŽĨĂŵŝdžŽĨŐƌĂƐƐĞƐĂŶĚA.1-63cont.A.1-64A.1-65A.1-668-203
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 15 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zĚĞĨĞŶƐŝďůĞƐƉĂĐĞƌĞƋƵŝƌĞŵĞŶƚƐ͘dŚĞĚŝĨĨŝĐƵůƚLJŝŶƐƵĐĐĞƐƐĨƵůůLJĞƐƚĂďůŝƐŚŝŶŐŽƌĞǀĞŶƌĞƐƚŽƌŝŶŐĂƐĞƌƉĞŶƚŝŶĞďƵŶĐŚŐƌĂƐƐŐƌĂƐƐůĂŶĚĐŽŵŵƵŶŝƚLJŝƐǁĞůůĚŽĐƵŵĞŶƚĞĚ͘ƐƐƵĐŚ͕ƐƵĐĐĞƐƐĨƵůĐŽŵƉĞŶƐĂƚŽƌLJƌĞƉůĂĐĞŵĞŶƚĂŶĚƌĞƐƚŽƌĂƚŝŽŶŽĨƚŚĞEĂƐƐĞůůĂWƵůĐŚƌĂ,ĞƌďĂĐĞŽƵƐůůŝĂŶĐĞŽĨĞƋƵĂůŽƌŐƌĞĂƚĞƌƋƵĂůŝƚLJƚŚĂŶƚŚĂƚǁŚŝĐŚĞdžŝƐƚƐŽŶƐŝƚĞŝƐĐŽŶƐŝĚĞƌĞĚƵŶůŝŬĞůLJ͕ƌĞƐƵůƚŝŶŐŝŶƚŚĞŝŶĂďŝůŝƚLJƚŽƐƵĐĐĞƐƐĨƵůůLJŵŝƚŝŐĂƚĞĂƐƐŽĐŝĂƚĞĚŝŵƉĂĐƚƐ͘dŚĞƌĞĨŽƌĞ͕ŝŵƉĂĐƚƐƚŽƚŚĞƐĞƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐĨƌŽŵWƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚďĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘ĨŽƌďƐ͘dŚĞĂŶŶƵĂůŐƌĂƐƐůĂŶĚĂƌĞĂƐĚŽŵŝŶĂƚĞĚďLJŶŽŶͲŶĂƚŝǀĞƐƉĞĐŝĞƐƐƵĐŚĂƐ/ƚĂůŝĂŶƌLJĞŐƌĂƐƐĐĂŶďĞĞŶŚĂŶĐĞĚďLJƐĞĂƐŽŶĂůůLJƚŝŵĞĚŐƌĂnjŝŶŐĂŶĚͬŽƌŵŽǁŝŶŐĨŽůůŽǁĞĚďLJƐĞĞĚŝŶŐĂŶĚƉůĂŶƚŝŶŐŽĨŶĂƚŝǀĞƐƉĞĐŝĞƐƐƵĐŚĂƐƉƵƌƉůĞŶĞĞĚůĞŐƌĂƐƐƚŽƉƌŽŵŽƚĞĂŵŽƌĞŶĂƚŝǀĞĚŽŵŝŶĂƚĞĚŐƌĂƐƐůĂŶĚ͘dŚĞŝŵƉĂĐƚĂŶĂůLJƐŝƐĂŶĚƐƵďƐĞƋƵĞŶƚŵŝƚŝŐĂƚŝŽŶƐŚŽƵůĚƉƌŽǀŝĚĞƐŽŵĞĨůĞdžŝďŝůŝƚLJĨŽƌƚŚĞĂƉƉůŝĐĂŶƚƚŽŝŵƉůĞŵĞŶƚĂŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵĂŶĚŚĂǀĞĂĚĂƉƚŝǀĞŵĂŶĂŐĞŵĞŶƚƐƚƌĂƚĞŐŝĞƐƚŚĂƚĐĂŶďĞƵƐĞĚƚŽƌĞĚƵĐĞŝŵƉĂĐƚƐƚŽƐĞƌƉĞŶƚŝŶĞďƵŶĐŚŐƌĂƐƐŐƌĂƐƐůĂŶĚƚŽĂůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚůĞǀĞůǁŝƚŚŵŝƚŝŐĂƚŝŽŶĂƉƉůŝĞĚ͘ϴ WĂŐĞϯ͘ϰͲϯϴϯ͘ϰŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐ/ŵƉĂĐƚʹ/Kϭ͗WƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŝŵƉĂĐƚƐĞŶƐŝƚŝǀĞƌŝƉĂƌŝĂŶ͕ǁĞƚůĂŶĚ͕ĂŶĚŶĂƚŝǀĞŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐŝĚĞŶƚŝĨŝĞĚĂƐƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐƵŶĚĞƌƐƚĂƚĞĂŶĚŝƚLJƉŽůŝĐLJ͘WĂŐĞϯ͘ϰͲϳϯ/ŵƉĂĐƚʹ/Kϯ͗WƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŚĂǀĞĂƐƵďƐƚĂŶƚŝĂůĂĚǀĞƌƐĞŝŵƉĂĐƚŽŶƐƚĂƚĞĂŶĚĨĞĚĞƌĂůůLJƉƌŽƚĞĐƚĞĚǁĞƚůĂŶĚƐ;^ŝŐŶŝĨŝĐĂŶƚĂŶĚhŶĂǀŽŝĚĂďůĞͿ͘dŚĞ/ƌŝƐŚ,ŝůůƐĚĞƚĞŶƚŝŽŶďĂƐŝŶƐŚŽƵůĚŶŽƚďĞŝĚĞŶƚŝĨŝĞĚĂƐĂǁĞƚůĂŶĚŚĂďŝƚĂƚĂŶĚƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚŝƐŶŽƚƉƌŽƉŽƐĞĚƚŽďĞŝŵƉĂĐƚĞĚ͘dŚĞŶĞǁ&ƌŽŽŵƌĞĞŬĐŚĂŶŶĞůŝŶƚŚĞůŽǁĞƌƉĂƌƚŽĨƚŚĞƐŝƚĞǁŝůůďĞĐůŽƐĞƌƚŽŐƌŽƵŶĚǁĂƚĞƌ͕ĂŶĚǁŝůůŝŶĐůƵĚĞǁĞƚůĂŶĚǀĞŐĞƚĂƚŝŽŶŝŶƚŚĞĐŚĂŶŶĞůďŽƚƚŽŵ͕ĂŶĚƌŝƉĂƌŝĂŶƚƌĞĞƐĂŶĚƐŚƌƵďƐŽŶƚŚĞďĂŶŬƐĂŶĚƚŽƉŽĨďĂŶŬĂƌĞĂƐǁŝůůďĞĂďůĞƚŽƚĂƉŝŶƚŽƚŚŝƐŐƌŽƵŶĚǁĂƚĞƌĂŶĚďĞĐŽŵĞĞƐƚĂďůŝƐŚĞĚƐŝŵŝůĂƌƚŽŽƚŚĞƌƌŝƉĂƌŝĂŶĂŶĚǁĞƚůĂŶĚĂƌĞĂƐŝŶƚŚĞĂƌĞĂ͘WůĂŶƚƐƐƵĐŚĂƐďůĂĐŬǁĂůŶƵƚ͕ĐŽƚƚŽŶǁŽŽĚ͕ƐLJĐĂŵŽƌĞ͕ĂŶĚǁŝůůŽǁƐǁŝůůďĞĂďůĞƚŽďĞƉůĂŶƚĞĚĂŶĚŝƌƌŝŐĂƚĞĚ͕ĂŶĚƐƵĐĐĞƐƐĨƵůůLJĞƐƚĂďůŝƐŚƚŚƌŽƵŐŚŽƵƚƚŚĞƌĞĂůŝŐŶĞĚĐƌĞĞŬĂƌĞĂƐŝŵŝůĂƌƚŽŽƚŚĞƌůŽĐĂƚŝŽŶƐŝŶƚŚŝƐŐĞŶĞƌĂůĂƌĞĂ;ŝ͘Ğ͕͘ƚŚĞƐĞƉĂƌĂƚĞĚǁĞƚůĂŶĚŽŶƚŚĞĞĂƐƚƐŝĚĞŽĨĂůůĞ:ŽĂƋƵŝŶŚĂƐĞdžƚĞŶƐŝǀĞǁĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚͿ͘dŚĞĂŵŽŶͲ'ĂƌĐŝĂ^ƉŽƌƚƐŽŵƉůĞdžƉƌŽũĞĐƚŝƐĂŶĞdžĂŵƉůĞŽĨǁŚĞƌĞĂƌĞĂůŝŐŶĞĚĐƌĞĞŬĐŚĂŶŶĞůǁĂƐƐƵĐĐĞƐƐĨƵůůLJƌĞƐƚŽƌĞĚǁŝƚŚǁĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚ͘A.1-66cont.A.1-678-204
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 16 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zϵ WĂŐĞϯ͘ϰͲϰϬ^ĞŶƐŝƚŝǀĞZŝƉĂƌŝĂŶ,ĂďŝƚĂƚ /ZƐƚĂƚĞƐƚŚĂƚĐƌĞĞŬƌĞĂůŝŐŶŵĞŶƚ͞ŵĂLJŵŝƚŝŐĂƚĞƐŽŵĞŽĨƚŚĞůŽƐƐĞƐ͟ďƵƚĐŽŶĐůƵĚĞƐƚŚĂƚƚŚĞĞƐƚĂďůŝƐŚŵĞŶƚĂŶĚůŽŶŐͲƚĞƌŵƐƵƌǀŝǀĂůŽĨƌŝƉĂƌŝĂŶŚĂďŝƚĂƚŝŶƚŚĞƌĞĂůŝŐŶĞĚ&ƌŽŽŵƌĞĞŬ͞ŵĂLJďĞĐŚĂůůĞŶŐŝŶŐ͘͟dŚŝƐĐŽŶĐůƵƐŝŽŶŝƐƉƌĞĚŝĐĂƚĞĚŽŶƚŚĞĞdžŝƐƚŝŶŐĐŚĂŶŶĞů͛ƐůĂĐŬŽĨǁĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚ͘dŚĞĂƉƉůŝĐĂŶƚƚĞĂŵďĞůŝĞǀĞƚŚŝƐĂŶĂůLJƐŝƐƐŚŽƵůĚŶŽƚƵƐĞƚŚĞĞdžŝƐƚŝŶŐĐƌĞĞŬĐŚĂŶŶĞůĐŽŶĚŝƚŝŽŶĂƐĂƌĞĨĞƌĞŶĐĞĨŽƌƚŚĞĐƌĞĂƚŝŽŶŽĨƌŝƉĂƌŝĂŶĂŶĚǁĞƚůĂŶĚŚĂďŝƚĂƚŝŶƚŚĞŶĞǁĐŚĂŶŶĞů͘ZĞĂůŝŐŶŵĞŶƚŽĨƚŚĞĐƌĞĞŬĐŚĂŶŶĞůǁŝůůŵŽƌĞĐůŽƐĞůLJĨŽůůŽǁƚŚĞŚŝƐƚŽƌŝĐĂůŝŐŶŵĞŶƚĂŶĚǁŝůůďĞŶĞĨŝƚĨƌŽŵĐůŽƐĞƌƉƌŽdžŝŵŝƚLJƚŽƚŚĞƵŶĚĞƌŐƌŽƵŶĚƌŝǀĞƌďĞĚĂŶĚƐƵďƚĞƌƌĂŶĞĂŶĨůŽǁŽĨǁĂƚĞƌ͘dŚĞŶĞǁĐŚĂŶŶĞůŝŶƚŚĞůŽǁĞƌĞůĞǀĂƚŝŽŶƉĂƌƚŽĨƚŚĞƐŝƚĞĐŽŵƉĂƌĞĚƚŽƚŚĞĞdžŝƐƚŝŶŐĐŚĂŶŶĞůƉĞƌĐŚĞĚĂƚƚŚĞƚŽĞŽĨƚŚĞŚŝůůǁŝůůďĞĐůŽƐĞƌƚŽŐƌŽƵŶĚǁĂƚĞƌĂŶĚƉƌŽǀŝĚĞĚĞĞƉƌŽŽƚĞĚƌŝƉĂƌŝĂŶƚƌĞĞƐĂŶĚƐŚƌƵďƐƚŚĞĂďŝůŝƚLJƚŽƚĂƉŝŶƚŽƚŚŝƐŐƌŽƵŶĚǁĂƚĞƌĂŶĚƉĞƌƐŝƐƚŽǀĞƌƚŝŵĞǁŝƚŚŽƵƚĂƌƚŝĨŝĐŝĂůŝƌƌŝŐĂƚŝŽŶ͘dŚĞƉƌŽũĞĐƚǁŝůůĞƐƚĂďůŝƐŚǁĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚŝŶƚŚĞŶĞǁĐƌĞĞŬĐŚĂŶŶĞů͕ĂŶĚǁŝůůƵůƚŝŵĂƚĞůLJƌĞůŽĐĂƚĞƚŚĞƐĞŚĂďŝƚĂƚƐŽŶƐŝƚĞƌĂƚŚĞƌƚŚĂŶĞůŝŵŝŶĂƚĞƚŚĞŵ͘/ƚ͛ƐĂƌĞͲƉŽƐŝƚŝŽŶŝŶŐƐŽƚŽƐƉĞĂŬ͘KƚŚĞƌǁĂƚĞƌƋƵĂůŝƚLJƉƌŽƚĞĐƚŝŽŶŵĞĂƐƵƌĞƐƐƵĐŚĂƐƉƌĞƉĂƌĂƚŝŽŶĂŶĚŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨDWƐĂƐƐŽĐŝĂƚĞĚǁŝƚŚƚŚĞ^tWWWǁŝůůƉƌĞǀĞŶƚĐŽŶƚĂŵŝŶĂƚŝŽŶŽĨƚŚĞĚƌĂŝŶĂŐĞĨĞĂƚƵƌĞƐĂŶĚĂƐƐŽĐŝĂƚĞĚĂƋƵĂƚŝĐƌĞƐŽƵƌĐĞƐ͘ŽŶƐƚƌƵĐƚŝŽŶƐĞƚďĂĐŬƐĨƌŽŵƚŚĞĐƌĞĞŬĐŚĂŶŶĞůƐǁŝůůĂůƐŽŚĞůƉƉƌĞǀĞŶƚŝŵƉĂĐƚƐ͘/ƚŝƐĂůƐŽŝŵƉŽƌƚĂŶƚƚŽŶŽƚĞƚŚĂƚĞdžƚĞŶƐŝǀĞĐŽǀĞƌŽĨĂŶŽŶͲŶĂƚŝǀĞƐƉĞĐŝĞƐ͕ƌĞĞĚĨĞƐĐƵĞ͕ŝƐŽǀĞƌƚĂŬŝŶŐƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐ͕ĂŶĚƚŚŝƐƐƉĞĐŝĞƐǁŽƵůĚďĞƌĞŵŽǀĞĚĂŶĚƚŚĞĞŶƚŝƌĞĂƌĞĂĞŶŚĂŶĐĞĚĂƐƉĂƌƚŽĨƚŚĞĂƉƉůŝĐĂŶƚ͛ƐƌĞƐƚŽƌĂƚŝŽŶƉƌŽŐƌĂŵ͕ĂŶĚƚŚŝƐƐŚŽƵůĚĂůƐŽŚĞůƉƌĞĚƵĐĞƉƌŽũĞĐƚƌĞůĂƚĞĚŝŵƉĂĐƚƐƚŽƐĞŶƐŝƚŝǀĞǁĞƚůĂŶĚͬƌŝƉĂƌŝĂŶŚĂďŝƚĂƚƚŽůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚǁŝƚŚƚŚĞŝŶĐŽƌƉŽƌĂƚŝŽŶŽĨŵŝƚŝŐĂƚŝŽŶ͘A.1-688-205
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 17 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zϭϬ WĂŐĞϯ͘ϰͲϯϴϯ͘ϰŝŽůŽŐŝĐĂůZĞƐŽƵƌĐĞƐ/ŵƉĂĐƚʹ/Kϭ͗WƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŝŵƉĂĐƚƐĞŶƐŝƚŝǀĞƌŝƉĂƌŝĂŶ͕ǁĞƚůĂŶĚ͕ĂŶĚŶĂƚŝǀĞŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐŝĚĞŶƚŝĨŝĞĚĂƐƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐƵŶĚĞƌƐƚĂƚĞĂŶĚŝƚLJƉŽůŝĐLJ͘ /ZĐŽŶƐƵůƚĂŶƚŝĚĞŶƚŝĨŝĞĚĐŽŶĐĞƌŶƐǁŝƚŚƉŽƚĞŶƚŝĂůĞƌŽƐŝŽŶŽĨƚŚĞƌĞĂůŝŐŶĞĚĐƌĞĞŬĐŚĂŶŶĞů͕ĂŶĚƐĞĚŝŵĞŶƚĂƚŝŽŶĂŶĚŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐĂŶĚĚŽǁŶƐƚƌĞĂŵƌĞƐŽƵƌĐĞƐ͘dŚŝƐƐĞĞŵƐƐƉĞĐƵůĂƚŝǀĞƚŚĂƚ͞ůĂƌŐĞǀŽůƵŵĞƐŽĨƐĞĚŝŵĞŶƚŝŶƉƵƚĐŽƵůĚĐŽŵƉƌŽŵŝƐĞƌŝƉĂƌŝĂŶĂŶĚǁĞƚůĂŶĚŚĂďŝƚĂƚŝŶ&ƌŽŽŵƌĞĞŬĂŶĚ^>KƌĞĞŬĚŽǁŶƐƚƌĞĂŵ͕ĂƐǁĞůůĂƐĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐ͘͟ƐƚŚĞĂƉƉůŝĐĂŶƚŚĂƐƉƌŽƉŽƐĞĚ͕ƚŚĞĐŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞŶĞǁĐŚĂŶŶĞůǁŝůůŽĐĐƵƌŝŶĂƉŚĂƐĞĚĂƉƉƌŽĂĐŚ͘dŚĞŶĞǁĐŚĂŶŶĞůǁŽƵůĚďĞĐŽŶƐƚƌƵĐƚĞĚ͕ĂŶĚƚŚĞŶƐĞĞĚĞĚͬƉůĂŶƚĞĚĂŶĚŝƌƌŝŐĂƚĞĚĨŽƌĂďŽƵƚĂLJĞĂƌƉƌŝŽƌƚŽƌĞŵŽǀŝŶŐƚŚĞŽůĚĐŚĂŶŶĞů͘dŚĞŐŽĂůǁŝůůďĞƚŽŐĞƚƚŚĞǀĞŐĞƚĂƚŝŽŶĞƐƚĂďůŝƐŚĞĚĂŶĚŐƌŽǁŝŶŐŝŶƚŚĞŶĞǁĐŚĂŶŶĞůƉƌŝŽƌƚŽŽƉĞŶŝŶŐƚŚĞĐŽŶŶĞĐƚŝŽŶĂŶĚĂůůŽǁŝŶŐǁĂƚĞƌƚŽĨůŽǁ͘ŽďďůĞǁŝůůďĞĐŽůůĞĐƚĞĚĨƌŽŵƚŚĞĞdžŝƐƚŝŶŐďĞĚŽĨƚŚĞĐŚĂŶŶĞůƚŚĂƚǁŝůůďĞĨŝůůĞĚ͕ĂŶĚĂƉƉůŝĞĚƚŚƌŽƵŐŚŽƵƚƚŚĞďĞĚŽĨƚŚĞƌĞĂůŝŐŶĞĚĐŚĂŶŶĞů͕ĞƐƉĞĐŝĂůůLJŝŶƚŚĞƵƉƉĞƌƌĞĂĐŚǁŚĞƌĞĨůŽǁƐŚĂǀĞƚŚĞƉŽƚĞŶƚŝĂůƚŽďĞŵŽƌĞĞƌŽƐŝǀĞ͘dŚĞĐŚĂŶŶĞůǁŽƵůĚƐĞŐƵĞŝŶƚŽĂŵŽƌĞĞĂƌƚŚĞŶĐůĂLJďĞĚĚŽǁŶůŽǁĐůŽƐĞƌƚŽĂůůĞ:ŽĂƋƵŝŶ͘/ƚŝƐĂůƐŽůŝŬĞůLJƚŚĂƚŶĂƚŝǀĞĐŽďďůĞĂŶĚďŽƵůĚĞƌƐƌĞŵŽǀĞĚĨƌŽŵƚŚĞĞdžŝƐƚŝŶŐĐŚĂŶŶĞůǁŝůůďĞĂƉĂƌƚŽĨƚŚĞďĞƌŵƉƌŽƉŽƐĞĚƚŽƐĞƉĂƌĂƚĞƚŚĞůŽǁĨůŽǁĐŚĂŶŶĞůĨƌŽŵĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐ͘ϭϭ WĂŐĞϯ͘ϰͲϯϴ/ŵƉĂĐƚ/KͲϭ͗WƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŝŵƉĂĐƚƐĞŶƐŝƚŝǀĞƌŝƉĂƌŝĂŶ͕ǁĞƚůĂŶĚ͕ĂŶĚŶĂƚŝǀĞŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐŝĚĞŶƚŝĨŝĞĚĂƐƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐƵŶĚĞƌƐƚĂƚĞĂŶĚŝƚLJƉŽůŝĐLJ;^ŝŐŶŝĨŝĐĂŶƚĂŶĚhŶĂǀŽŝĚĂďůĞͿ͘>ĞŶŐƚŚĞŶŝŶŐĂŶĚǁŝĚĞŶŝŶŐƚŚĞĐƌĞĞŬǁŽƵůĚŚĞůƉƐůŽǁĨůŽǁƐĂŶĚĂůůŽǁƐƵƐƉĞŶĚĞĚƐĞĚŝŵĞŶƚĂŶĚŵĂƚĞƌŝĂůƐƚŽďĞĚĞƉŽƐŝƚĞĚŝŶƚŚĞƵƉƉĞƌƌĞĂůŝŐŶĞĚƌĞĂĐŚŽĨƚŚĞĐŚĂŶŶĞů͘dŚĞŶĞǁĐŚĂŶŶĞůǁŽƵůĚƵƐĞĞdžŝƐƚŝŶŐĐŽďďůĞƐĂŶĚďŽƵůĚĞƌƐƚŽĐƌĞĂƚĞĂƐŝŵŝůĂƌďĞĚƚŚĂƚƉƌŽƚĞĐƚƚŚĞďĂŶŬƐĚƵƌŝŶŐŚŝŐŚĨůŽǁĞǀĞŶƚƐ͘ϭϮ /ŵƉĂĐƚ/KͲϭ͗WĂŐĞϯ͘ϰͲϯϵWƌŽũĞĐƚŝŵƉůĞŵĞŶƚĂƚŝŽŶǁŽƵůĚŝŵƉĂĐƚƐĞŶƐŝƚŝǀĞƌŝƉĂƌŝĂŶ͕ǁĞƚůĂŶĚ͕ZĞŐĂƌĚŝŶŐƉŽƚĞŶƚŝĂůŝŵƉĂĐƚƐƚŽƐĞŶƐŝƚŝǀĞŚĂďŝƚĂƚƐĨƌŽŵĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶ͕ŵĂdžŝŵƵŵĨůĞdžŝďŝůŝƚLJƐŚŽƵůĚďĞƉƌŽǀŝĚĞĚƚŽƚŚĞĂƉƉůŝĐĂŶƚƚŽŝŵƉůĞŵĞŶƚĂƉƉƌŽƉƌŝĂƚĞĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶŵĞƚŚŽĚƐĂƐŶĞǁŝŶĨŽƌŵĂƚŝŽŶŝƐůĞĂƌŶĞĚ͘^ĞĂƐŽŶĂůůLJͲƚŝŵĞĚŐƌĂnjŝŶŐĂŶĚŵŽǁŝŶŐŝŶŐƌĂƐƐůĂŶĚƐĂŶĚƐĞůĞĐƚŝǀĞƚŚŝŶŶŝŶŐĂŶĚůŝŵďŝŶŐŝŶŽƚŚĞƌƚƌĞĞͬƐŚƌƵďŚĂďŝƚĂƚƐƐŚŽƵůĚďĞĂůůŽǁĞĚ͕ĂŶĚƚŚĞ /ZĨŝŶĚŝŶŐƐŽĨůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚǁŝƚŚŝŶĐŽƌƉŽƌĂƚŝŽŶŽĨŵŝƚŝŐĂƚŝŽŶƐŚŽƵůĚďĞA.1-68 cont. A.1-69A.1-708-206
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 18 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zĂŶĚŶĂƚŝǀĞŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐŝĚĞŶƚŝĨŝĞĚĂƐƐĞŶƐŝƚŝǀĞŶĂƚƵƌĂůĐŽŵŵƵŶŝƚŝĞƐƵŶĚĞƌƐƚĂƚĞĂŶĚŝƚLJƉŽůŝĐLJ;^ŝŐŶŝĨŝĐĂŶƚĂŶĚhŶĂǀŽŝĚĂďůĞͿ͘ŵĂĚĞ͘DŝƚŝŐĂƚŝŽŶĐŽƵůĚŝŶĐůƵĚĞĂĚĚŝƚŝŽŶĂůƌĞƉůĂŶƚŝŶŐŽĨŶĂƚŝǀĞƐƉĞĐŝĞƐŽƵƚƐŝĚĞĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶnjŽŶĞƐŽƌŚĂďŝƚĂƚĞŶŚĂŶĐĞŵĞŶƚŝŶŽƚŚĞƌĂƌĞĂƐŽĨƚŚĞƐŝƚĞĂǁĂLJĨƌŽŵĚĞǀĞůŽƉŵĞŶƚ͘dŚĞĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶƉƌŽŐƌĂŵƐŚŽƵůĚŶŽƚďĞĂůůĐůĞĂƌŝŶŐŽĨĨƵĞůƐ͕ďƵƚƐĞůĞĐƚŝǀĞƚŚŝŶŶŝŶŐĂŶĚƐŽŵĞŝƌƌŝŐĂƚĞĚůĂŶĚƐĐĂƉŝŶŐĐŽƵůĚĂůƐŽďĞƵƐĞĚĞĨĨĞĐƚŝǀĞůLJƚŽĞŶƐƵƌĞĨƵĞůŵŽĚŝĨŝĐĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚƐĂƌĞŵĞƚ͘ϭϯ WĂŐĞϯ͘ϰͲϰϯ͘>KsZĚŝƚĐŚĚŽĞƐŶŽƚƉƌŽǀŝĚĞĂƌĞŐƵůĂƌƐŽƵƌĐĞŽĨŝŶĨůŽǁƚŽĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐ͕ďƵƚƌĂƚŚĞƌĂƐĞĂƐŽŶĂůƐŽƵƌĐĞ͘ƵƌŝŶŐĚƌŽƵŐŚƚLJĞĂƌƐ͕ǀĞƌLJůŝƚƚůĞǁĂƚĞƌŵĂLJĞŶƚĞƌƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐƚŚƌŽƵŐŚƚŚŝƐĚŝƚĐŚ͕ĂŶĚŝƚŝƐƐƚŝůůĂďůĞƚŽƉĞƌƐŝƐƚĨƌŽŵŐƌŽƵŶĚǁĂƚĞƌ͘ϭϰ WĂŐĞϯ͘ϰͲϰϭ/ŵƉĂĐƚ/KͲϭϯ͘ϰͲϰϰ^ĞŶƐŝƚŝǀĞtĞƚůĂŶĚ,ĂďŝƚĂƚ /ZĐŽŶƐƵůƚĂŶƚƐƚĂƚĞƐ͞ ŶƐƵƌŝŶŐůŽŶŐͲƚĞƌŵŵĂŝŶƚĞŶĂŶĐĞŽĨƌĞƐƚŽƌĞĚ&ƌŽŽŵƌĞĞŬƌŝƉĂƌŝĂŶŚĂďŝƚĂƚŵƵƐƚďĞĐŽŶƐŝĚĞƌĞĚƐƉĞĐƵůĂƚŝǀĞ͕ĂŶĚĂƐƐƵĐŚĐĂŶŶŽƚďĞĐŽŶƐŝĚĞƌĞĚĨĞĂƐŝďůĞůŽŶŐͲƚĞƌŵŵŝƚŝŐĂƚŝŽŶĚƵĞƚŽƚŚĞƉŽƚĞŶƚŝĂůĨŽƌƐĐŽƵƌĂŶĚĚĞŶƵĚĂƚŝŽŶǁŝƚŚŝŶƚŚĞ&ƌŽŽŵƌĞĞŬĐŽƌƌŝĚŽƌ͘͟dŚĞĂƉƉůŝĐĂŶƚ͛ƐƚĞĂŵďĞůŝĞǀĞƐƚŚŝƐŝƐŶŽƚĐŽƌƌĞĐƚ͘dŚĞƉƌŽƉŽƐĞĚĚĞƐŝŐŶǁŝůůĂĚĚƌĞƐƐĐŽŶĐĞƌŶƐǁŝƚŚĐƌĞĞŬďĂŶŬĞƌŽƐŝŽŶŽǀĞƌƚŝŵĞĂƐǁĂƐĚŽŶĞǁŝƚŚƚŚĞĂŵŽŶͲ'ĂƌĐŝĂ^ƉŽƌƚƐ&ŝĞůĚƐĐƌĞĞŬƌĞĂůŝŐŶŵĞŶƚĂŶĚƌĞƐƚŽƌĂƚŝŽŶ͘ϭϱ WĂŐĞϯ͘ϰͲϰϰ^ƚĂƚĞŵĞŶƚƐŝŶƚŚĞ /ZƚŚĂƚĚĞǀĞůŽƉŵĞŶƚǁŽƵůĚĞŶĐƌŽĂĐŚǁŝƚŚŝŶϮϬĨĞĞƚŽĨŽŶƐŝƚĞĚƌĂŝŶĂŐĞƐĂƉƉĞĂƌƐŝŶĐŽƌƌĞĐƚ͘ƌĂŝŶĂŐĞƐĞƚďĂĐŬƐǁŽƵůĚĨŽůůŽǁŝƚLJƉŽůŝĐLJĂŶĚĂůůŚŽƌƌŽƌĞĞŬďŽŐƚŚŝƐƚůĞŽĐĐƵƌƌĞŶĐĞƐǁŽƵůĚďĞďƵĨĨĞƌĞĚďLJĂŵŝŶŝŵƵŵŽĨϱϬĨĞĞƚĨƌŽŵĂŶLJĚĞǀĞůŽƉŵĞŶƚ͘ϭϲ WĂŐĞϯ͘ϰͲϱϬDDͲ/KͲϮdŚĞŵŝƚŝŐĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚƐŚŽƵůĚďĞĐůĂƌŝĨŝĞĚƚŚĂƚĚĂŝůLJŵŽŶŝƚŽƌŝŶŐďLJƚŚĞƋƵĂůŝĨŝĞĚďŝŽůŽŐŝƐƚǁŽƵůĚŽĐĐƵƌĚƵƌŝŶŐŝŶŝƚŝĂůƐŝƚĞĚŝƐƚƵƌďĂŶĐĞĂŶĚĨŽƌĂŶLJǁŽƌŬǁŝƚŚŝŶĂƌĞĂƐŽĨƐĞŶƐŝƚŝǀĞŚĂďŝƚĂƚƐŝŶĐůƵĚŝŶŐƚŚĞĚƌĂŝŶĂŐĞĨĞĂƚƵƌĞƐ͕ƌĞĂůŝŐŶĞĚ&ƌŽŽŵƌĞĞŬ͕ĞƚĐ͘KŶĐĞƚŚĞƵƉůĂŶĚƉŽƌƚŝŽŶƐŽĨƚŚĞƐŝƚĞŚĂǀĞďĞĞŶŐƌĂĚĞĚ͕ŵŽŶŝƚŽƌŝŶŐďLJƚŚĞƋƵĂůŝĨŝĞĚďŝŽůŽŐŝƐƚǁŽƵůĚŶŽƚďĞƌĞƋƵŝƌĞĚŽŶĂĚĂŝůLJďĂƐŝƐ͕ĂŶĚƚŚĞďŝŽůŽŐŝƐƚǁŽƵůĚĐŽŶĚƵĐƚǁĞĞŬůLJ͕ĂƐͲŶĞĞĚĞĚ͕ŽƌƉĞƌŝŽĚŝĐƐƉŽƚĐŚĞĐŬƐĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞĂŐƌĞĞĚƵƉŽŶŵŽŶŝƚŽƌŝŶŐĨƌĞƋƵĞŶĐLJĚĞĨŝŶĞĚŝŶƚŚĞDDW͕ǁŚŝĐŚǁŝůůďĞĂƉƉƌŽǀĞĚďLJƚŚĞŝƚLJ͘ϭϳ WĂŐĞϯ͘ϰͲϱϱDDͲ/KͲϱZĞƋƵŝƌĞƐĂůůƚĞŵƉŽƌĂƌLJĂŶĚƉĞƌŵĂŶĞŶƚŝŵƉĂĐƚƐƚŽƐĞŶƐŝƚŝǀĞŚĂďŝƚĂƚƐďĞŝĚĞŶƚŝĨŝĞĚĂŶĚĚĞƚĂŝůĞĚŝŶƚŚĞDDW͘dŚĞĨŽůůŽǁŝŶŐŵŝƚŝŐĂƚŝŽŶƌĂƚŝŽƐĂƌĞŝĚĞŶƚŝĨŝĞĚ͗ƚĞŵƉŽƌĂƌLJŝŵƉĂĐƚƐĂƚĂϭ͗ϭƌĂƚŝŽ͖ƉĞƌŵĂŶĞŶƚŝŵƉĂĐƚƐƚŽƌŝƉĂƌŝĂŶA.1-71cont.A.1-73A.1-74A.1-75A.1-76A.1-728-207
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 19 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zĂŶĚŐƌĂƐƐůĂŶĚŚĂďŝƚĂƚƐĂƚĂϮ͗ϭƌĂƚŝŽ͖ĂŶĚƉĞƌŵĂŶĞŶƚŝŵƉĂĐƚƐƚŽǁĞƚůĂŶĚƐĂƚĂϯ͗ϭƌĂƚŝŽ;ƵŶůĞƐƐĂŐĞŶĐŝĞƐƌĞƋƵŝƌĞĂŚŝŐŚĞƌƌĂƚŝŽͿ͘dŚĞĂƉƉůŝĐĂŶƚŝƐĐŽŶĐĞƌŶĞĚǁŝƚŚƚŚĞĂŶĂůLJƐŝƐŽĨƚŚĞƉŽƚĞŶƚŝĂůŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐĨƌŽŵƚŚĞ&ƌŽŽŵƌĞĞŬƌĞĂůŝŐŶŵĞŶƚ͘dŚĞ /ZƐƚĂƚĞƐƚŚĂƚĂϮ͗ϭƌĂƚŝŽĨŽƌƉŽƚĞŶƚŝĂůŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐďĞŝŵƉůĞŵĞŶƚĞĚďĞĨŽƌĞŝƚŝƐĞǀĞŶŬŶŽǁŶŝĨƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚĂƌĞĂǁŝůůďĞĂĚǀĞƌƐĞůLJŝŵƉĂĐƚĞĚďLJƚŚĞĐƌĞĞŬƌĞĂůŝŐŶŵĞŶƚ͘dŚŝƐŝƐŚŝŐŚůLJƐƉĞĐƵůĂƚŝǀĞƚŚĂƚĂŶLJĂĚǀĞƌƐĞŝŵƉĂĐƚƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐǁŝůůĞǀĞŶŽĐĐƵƌ͕ĂŶĚŽŶĞŽĨƚŚĞŐŽĂůƐŽĨƚŚĞƌĞĂůŝŐŶŵĞŶƚƉƌŽũĞĐƚŝƐƚŽĐŽŶŶĞĐƚĐƌĞĞŬŚLJĚƌŽůŽŐLJǁŝƚŚƚŚĞǁĞƚůĂŶĚnjŽŶĞ͘dŚĞǁĞƚůĂŶĚŵŝƚŝŐĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚĞƋƵĂƚĞƐƚŽĂƚůĞĂƐƚϭϬ͘ϮϰĂĐƌĞƐŽĨǁĞƚůĂŶĚƐďĞĐƌĞĂƚĞĚ͕ĂŶĚŝƚŝƐƵŶůŝŬĞůLJƚŚĂƚƚŚŝƐĐŽƵůĚďĞĚŽŶĞŽŶƐŝƚĞ͘dŚĞĂƉƉůŝĐĂŶƚƌĞƋƵĞƐƚƐƚŚĂƚĐƌĞĂƚŝŶŐŽǀĞƌϭϬĂĐƌĞƐŽĨǁĞƚůĂŶĚƐĨŽƌƉŽƚĞŶƚŝĂůŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐďĞƌĞŵŽǀĞĚĂŶĚĂŵŽŶŝƚŽƌŝŶŐƌĞƋƵŝƌĞŵĞŶƚďĞĚĞǀĞůŽƉĞĚƚŽĚĞƚĞƌŵŝŶĞŝĨŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚŽĐĐƵƌĨƌŽŵĐŚĂŶŶĞůƌĞĂůŝŐŶŵĞŶƚ͘/ĨƚŚĞLJĚŽ͕ƚŚĞŶĂƌĞĂƐŽŶĂďůĞĂƉƉƌŽĂĐŚ;ĂƐƉĂƌƚŽĨƚŚĞĂĚĂƉƚŝǀĞŵĂŶĂŐĞŵĞŶƚƐƚƌĂƚĞŐLJͿǁŽƵůĚďĞĚĞǀĞůŽƉĞĚďLJƚŚĞĂƉƉůŝĐĂŶƚŝŶĐŽŶĐĞƌƚǁŝƚŚƚŚĞĐŝƚLJĂŶĚĂƉƉƌŽƉƌŝĂƚĞƌĞŐƵůĂƚŽƌLJĂŐĞŶĐŝĞƐƚŽƐŽůǀĞƚŚĞƉƌŽďůĞŵ͘DŝƚŝŐĂƚŝŽŶĨŽƌŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐĐŽƵůĚŝŶĐůƵĚĞƵƐĞŽĨďŝŽƚĞĐŚŶŝĐĂůĞƌŽƐŝŽŶĐŽŶƚƌŽůŵĞĂƐƵƌĞƐ͕ĂĚĚŝƚŝŽŶĂůƉůĂŶƚŝŶŐƐŝŶƚŚĞĐƌĞĞŬĐŽƌƌŝĚŽƌŽƌǁĞƚůĂŶĚĂƌĞĂƐ͕ĂŶĚƵůƚŝŵĂƚĞůLJŽĨĨƐŝƚĞŚĂďŝƚĂƚĐƌĞĂƚŝŽŶŽƌĞŶŚĂŶĐĞŵĞŶƚŝĨŽŶƐŝƚĞƌĞƐƚŽƌĂƚŝŽŶǁĂƐĚĞĞŵĞĚŝŶĨĞĂƐŝďůĞ͘/ƚŝƐŝŵƉŽƌƚĂŶƚƚŽŶŽƚĞƚŚĂƚƚŚŝƐƉĂƌƚŽĨƚŚĞƐŝƚĞǁŝůůďĞĂǀĞƌLJůĂƌŐĞĂŶĚǁŝĚĞŶĂƚƵƌĂůĂƌĞĂĐĂƉĂďůĞŽĨŚĂŶĚůŝŶŐƐĞĂƐŽŶĂůĨůŽǁƐĂŶĚƉƌŽǀŝĚŝŶŐƐƉĂĐĞƚŽĐƌĞĂƚĞĂŶĚĞŶŚĂŶĐĞǁĞƚůĂŶĚĂŶĚƌŝƉĂƌŝĂŶŚĂďŝƚĂƚ͘LJƌĞƋƵŝƌŝŶŐŽǀĞƌϭϬĂĐƌĞƐŽĨǁĞƚůĂŶĚƐďĞĐƌĞĂƚĞĚĨŽƌƉŽƚĞŶƚŝĂůŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐ͕ŝƚǁŝůůƚƌŝŐŐĞƌĂĚĚŝƚŝŽŶĂůǁŽƌŬůŝŬĞůLJĂƚĂŶŽĨĨƐŝƚĞůŽĐĂƚŝŽŶ͕ǁŚŝĐŚĐŽƵůĚƌĞƐƵůƚŝŶƚLJƉĞĐŽŶǀĞƌƐŝŽŶŽĨŐƌĂƐƐůĂŶĚŽƌĂŶŽƚŚĞƌŚĂďŝƚĂƚƚLJƉĞƚŚĂƚĐŽƵůĚďĞŽĨĞƋƵĂůŽƌŚŝŐŚĞƌǀĂůƵĞƚŽǁŝůĚůŝĨĞ͘A.1-76cont.8-208
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 20 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'z/ƌƌŝŐĂƚŝŽŶƐŚŽƵůĚďĞƌĞƋƵŝƌĞĚŝŶƚŚĞĨŝƌƐƚϯLJĞĂƌƐŽĨƉůĂŶƚĞƐƚĂďůŝƐŚŵĞŶƚ͘ĂƐĞĚŽŶĞdžƉĞƌŝĞŶĐĞ͕ŝƌƌŝŐĂƚŝŽŶǁŽƵůĚďĞŐƌĂĚƵĂůůLJƌĞĚƵĐĞĚďĞƚǁĞĞŶLJĞĂƌƐϮĂŶĚϯ͘ϭϴ WĂŐĞϯ͘ϰͲϱϲDDͲ/KͲϲ&ŽƌĞĂƐĞŽĨƉƵďůŝĐƌĞǀŝĞǁ͕ŝƚƐĞĞŵƐƚŚĂƚƚŚŝƐŵĞĂƐƵƌĞĐŽƵůĚďĞǁŽǀĞŶŝŶƚŽ/KͲϭƚŽŵŝŶŝŵŝnjĞĂĚĚŝƚŝŽŶĂůŵĞĂƐƵƌĞƐƚŚĂƚĂƌĞƐŽŵĞǁŚĂƚĚƵƉůŝĐĂƚŝǀĞ͘/ŶĐŽŶƐŝƐƚĞŶĐŝĞƐǁŝƚŚƚŚĞŵŽŶŝƚŽƌŝŶŐƉĞƌŝŽĚǁĞƌĞĂůƐŽŶŽƚĞĚ͕ĂŶĚƚŚŝƐŵĞĂƐƵƌĞŝĚĞŶƚŝĨŝĞƐϳLJĞĂƌƐŽĨŵŽŶŝƚŽƌŝŶŐ͘ƐƐƚĂƚĞĚĂďŽǀĞ͕ƚŚĞŵŝƚŝŐĂƚŝŽŶŵŽŶŝƚŽƌŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐŚŽƵůĚďĞĂŵŝŶŝŵƵŵŽĨϱLJĞĂƌƐĂŶĚĞdžƚĞŶĚĞĚŽŶĂŶĂŶŶƵĂůďĂƐŝƐƵŶƚŝůƚŚĞĨŝŶĂůƐƵĐĐĞƐƐĐƌŝƚĞƌŝĂĚĞĨŝŶĞĚŝŶƚŚĞ,DDWĂƌĞŵĞƚ͘dŚŝƐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐƚĂƚĞƐŚĂďŝƚĂƚƌĞƐƚŽƌĂƚŝŽŶĂƌĞĂƐƐŚĂůůďĞŵĂŝŶƚĂŝŶĞĚǁĞĞŬůLJĨŽƌƚŚĞĨŝƌƐƚƚŚƌĞĞLJĞĂƌƐ͕ĂŶĚƚŚĞŶƋƵĂƌƚĞƌůLJƚŚĞƌĞĂĨƚĞƌ͘dŚĞĂƉƉůŝĐĂŶƚďĞůŝĞǀĞƐƚŚŝƐŝƐƚŽŽŝŶƚĞŶƐŝǀĞƚŽŚĂǀĞƌĞƋƵŝƌĞĚǁĞĞŬůLJŵĂŝŶƚĞŶĂŶĐĞĨŽƌƚŚƌĞĞLJĞĂƌƐ͕ĞƐƉĞĐŝĂůůLJĨŽƌĂŶĂƚƵƌĂůĂƌĞĂ͘/ƚŝƐĂŐƌĞĞĚƚŚĂƚŵĂŝŶƚĞŶĂŶĐĞǁŝůůďĞŝŶƚĞŶƐŝǀĞƚŚĞĨŝƌƐƚƚǁŽLJĞĂƌƐ͕ĂŶĚƐŚŽƵůĚŽĐĐƵƌǁĞĞŬůLJĚƵƌŝŶŐƚŚĞĨŝƌƐƚLJĞĂƌ͕ďƵƚƚŚĞŵĂŝŶƚĞŶĂŶĐĞĞĨĨŽƌƚƐŚŽƵůĚďĞĚŝƌĞĐƚĞĚďLJƚŚĞƋƵĂůŝĨŝĞĚďŝŽůŽŐŝƐƚďĂƐĞĚŽŶƚŚĞŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵƚŽďĞĚĞĨŝŶĞĚŝŶƚŚĞ,DDW͘dŚĞƋƵĂůŝĨŝĞĚďŝŽůŽŐŝƐƚĐĂŶŵŽŶŝƚŽƌƚŚĞƐŝƚĞŽŶĂǁĞĞŬůLJďĂƐŝƐĚƵƌŝŶŐƚŚĞĨŝƌƐƚLJĞĂƌ͕ĂŶĚĚŝƌĞĐƚŵĂŝŶƚĞŶĂŶĐĞĐƌĞǁƐĂĐĐŽƌĚŝŶŐůLJƚŽƌĞŵŽǀĞŶŽŶͲŶĂƚŝǀĞƐƉĞĐŝĞƐ͕ĐĂƌĞĨŽƌƐĞĞĚĞĚͬƉůĂŶƚĞĚǀĞŐĞƚĂƚŝŽŶ͕ĂŶĚƌĞŵŽǀĞĂĐĐƵŵƵůĂƚĞĚƚƌĂƐŚͬĚĞďƌŝƐ͘dŚĞŵŽŶŝƚŽƌŝŶŐĨƌĞƋƵĞŶĐLJĐŽƵůĚƚŚĞŶďĞƌĞĚƵĐĞĚƚŽŵŽŶƚŚůLJĨŽƌLJĞĂƌƐϮĂŶĚϯĂŶĚƚŚĞƉƌŽũĞĐƚďŝŽůŽŐŝƐƚĐĂŶĚŝƌĞĐƚŵĂŝŶƚĞŶĂŶĐĞĐƌĞǁƐĂƐĂƉƉƌŽƉƌŝĂƚĞďĂƐĞĚŽŶƚŚĞŵŽŶŝƚŽƌŝŶŐŽďƐĞƌǀĂƚŝŽŶƐ͘dŚĞƋƵĂůŝĨŝĞĚďŝŽůŽŐŝƐƚǁŽƵůĚĚŝƌĞĐƚŵĂŝŶƚĞŶĂŶĐĞĂĐƚŝǀŝƚŝĞƐƚŚƌŽƵŐŚŽƵƚƚŚĞϱͲLJĞĂƌŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵ͕ĂŶĚǁŽƌŬǁŝƚŚƚŚĞŝƚLJ͛ƐEĂƚƵƌĂůZĞƐŽƵƌĐĞƐDĂŶĂŐĞƌĂƐͲŶĞĞĚĞĚƚŽƚƌĂŶƐŝƚŝŽŶŝŶƚŽƚŚĞůŽŶŐͲƚĞƌŵŵŽŶŝƚŽƌŝŶŐƌĞƋƵŝƌĞŵĞŶƚƐ͘ϭϵ WĂŐĞϯ͘ϰͲϲϬ/ŵƉĂĐƚ/KͲϮ͗^ƉĞĐŝĂů^ƚĂƚƵƐ^ƉĞĐŝĞƐ;ƉůĂŶƚƐĂŶĚǁŝůĚůŝĨĞͿdŚĞƚŽŶĞŽĨƚŚŝƐĂŶĂůLJƐŝƐŝƐĞdžĐĞƐƐŝǀĞǁŝƚŚƐƚĂƚĞŵĞŶƚƐůŝŬĞ͞ŵŽďŝůĞƐƉĞĐŝĞƐůŝŬĞďŝƌĚƐǁŽƵůĚďĞĨŽƌĐĞĚŽƵƚŽĨƚŚĞĂƌĞĂĂŶĚƚŚĞŶǁŽƵůĚĐŽŵƉĞƚĞǁŝƚŚŽƚŚĞƌƐƉĞĐŝĞƐĨŽƌƌĞƐŽƵƌĐĞƐ͘͟dŚĞƉƌŽũĞĐƚĂƌĞĂŝƐŝŶĂƌĞŐŝŽŶǁŝƚŚĞdžƚĞŶƐŝǀĞŽƉĞŶƐƉĂĐĞĂƌĞĂƐ͕ĂŶĚŝƚŝƐůŝŬĞůLJƚŚĂƚĂŶLJďŝƌĚƐŽƌŵŽďŝůĞƐƉĞĐŝĞƐƚŚĂƚĂƌĞƵƐŝŶŐƚŚĞƐŝƚĞǁŝůůďĞĂďůĞƚŽĐŽŶƚŝŶƵĞƵƐŝŶŐŽƉĞŶƐƉĂĐĞĂƌĞĂƐŽŶƐŝƚĞĂŶĚŝŶƚŚĞŐĞŶĞƌĂůĂƌĞĂƉŽƐƚĚĞǀĞůŽƉŵĞŶƚ͘A.1-76cont.A.1-77A.1-788-209
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 21 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zDŽƵƐĞŐƌĂLJƵĚůĞLJĂŝƐŝŶĐŽƌƌĞĐƚůLJŝĚĞŶƚŝĨŝĞĚĂƐŚĂǀŝŶŐŵŽĚĞƌĂƚĞƚŽŚŝŐŚƉŽƚĞŶƚŝĂůƚŽŽĐĐƵƌŽŶƐŝƚĞ͘/ƚǁĂƐŽďƐĞƌǀĞĚŽŶƐŝƚĞ͕ĂŶĚƚŚĞůŽĐĂƚŝŽŶƐĂƌĞƐŚŽǁŶŽŶ&ŝŐƵƌĞϳʹ^ƉĞĐŝĂů^ƚĂƚƵƐWůĂŶƚKĐĐƵƌƌĞŶĐĞƐDĂƉŝŶƚŚĞZ/͘ /ZĐŽŶƐƵůƚĂŶƚƐƚĂƚĞƐZ>&ĂƌĞƉŽƚĞŶƚŝĂůůLJƉƌĞƐĞŶƚĂŶĚƉƌŽũĞĐƚƌĞůĂƚĞĚŝŵƉĂĐƚƐĂƌĞƐŝŐŶŝĨŝĐĂŶƚĐŽŵƉĂƌĞĚƚŽƐƚĞĞůŚĞĂĚǁŚŝĐŚĂƌĞůĞƐƐƚŚĂŶƐŝŐŶŝĨŝĐĂŶƚ͘dŚĞ^ŝƚĞƐƐĞƐƐŵĞŶƚĨŽƌZ>&ĚĞƚĞƌŵŝŶĞĚƚŚĂƚƚŚŝƐƐƉĞĐŝĞƐŝƐƵŶůŝŬĞůLJƚŽŽĐĐƵƌŽŶƐŝƚĞďĂƐĞĚŽŶƚŚĞůĂĐŬŽĨƐƵŝƚĂďůĞĂƋƵĂƚŝĐŚĂďŝƚĂƚŽĨƐƵĨĨŝĐŝĞŶƚĚĞƉƚŚĂŶĚƉƌĞƐĞŶĐĞŽĨĂƋƵĂƚŝĐƉƌĞĚĂƚŽƌƐƐƵĐŚĂƐĐƌĂLJĨŝƐŚŽĐĐƵƉLJŝŶŐƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚĂƌĞĂƐ͘tŚŝůĞƐĞǀĞƌĂůŝŶĚŝǀŝĚƵĂůZ>&ƐǁĞƌĞŽďƐĞƌǀĞĚĂƚƚŚĞŝƚLJ͛ƐǁĂƐƚĞǁĂƚĞƌƉŽŶĚŽŶƚŚĞĞĂƐƚƐŝĚĞŽĨ,ŝŐŚǁĂLJϭϬϭŽǀĞƌϭϬLJĞĂƌƐĂŐŽ͕ƚŚĞůĂƌŐĞŚŝŐŚǁĂLJĂůŽŶŐǁŝƚŚ>KsZĨŽƌŵƐŝŐŶŝĨŝĐĂŶƚďĂƌƌŝĞƌƐĨŽƌŵŽǀĞŵĞŶƚŽĨĂŵƉŚŝďŝĂŶƐƚŚĂƚŵĂLJďĞǁŝƚŚŝŶ^ĂŶ>ƵŝƐKďŝƐƉŽƌĞĞŬŽŶĂƐĞĂƐŽŶĂůďĂƐŝƐ͘&ƵƌƚŚĞƌ͕ƚŚĞŝŶĚŝǀŝĚƵĂůƐŽďƐĞƌǀĞĚŽŶƚŚĞtĂĚĚĞůůZĂŶĐŚĨƵƌƚŚĞƌƵƉŝŶƚŚĞŵŽƵŶƚĂŝŶƐƐŽƵƚŚǁĞƐƚŽĨƚŚĞƐŝƚĞĂƌĞŝŶĂŶĂƌĞĂǁŝƚŚƉĞƌŵĂŶĞŶƚĂƋƵĂƚŝĐŚĂďŝƚĂƚ͕ŝŶĐůƵĚŝŶŐĂůĂƌŐĞƉŽŶĚĂŶĚƐƉƌŝŶŐƐ͘&ŽĐƵƐĞĚƐƵƌǀĞLJƐŽĨƚŚĞƐŝƚĞŚĂǀĞŶŽƚŽďƐĞƌǀĞĚZ>&ŽŶƐŝƚĞ͕ĂŶĚƚŚĞƌĞĨŽƌĞŝƚŝƐƵŶůŝŬĞůLJƚŚĂƚƚŚĞƐƉĞĐŝĞƐǁŽƵůĚŽĐĐƵƌŽŶƐŝƚĞĂŶĚďĞĂĚǀĞƌƐĞůLJĂĨĨĞĐƚĞĚďLJĐŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚ͘ϮϬ WĂŐĞϯ͘ϰͲϲϴDDͲ/KͲϭϬŚŽƌƌŽƌĞĞŬďŽŐƚŚŝƐƚůĞŵĂŶĂŐĞŵĞŶƚ͘dŚĞĂƉƉůŝĐĂŶƚŚĂƐƉƌŽƉŽƐĞĚƚŽĂǀŽŝĚƚŚŝƐƐƉĞĐŝĞƐĂŶĚĂůůƉƌŽũĞĐƚĂĐƚŝǀŝƚŝĞƐĂŶĚĚĞǀĞůŽƉŵĞŶƚďĞďƵĨĨĞƌĞĚďLJĂƚůĞĂƐƚϱϬĨĞĞƚ͘WƌĞͲĐŽŶƐƚƌƵĐƚŝŽŶƐƵƌǀĞLJƐǁŝůůďĞĐŽŶĚƵĐƚĞĚƚŽĞŶƐƵƌĞƚŚĞƐƉĞĐŝĞƐŝƐĂǀŽŝĚĞĚĂŶĚďƵĨĨĞƌĞĚďLJĚĞǀĞůŽƉŵĞŶƚĂŶĚŝŶĚŝǀŝĚƵĂůƐŶŽƚŝŵƉĂĐƚĞĚĂƐƉĂƌƚŽĨƚŚĞƉƌŽũĞĐƚ͘Ϯϭ WĂŐĞϯ͘ϰͲϳϯ/ŵƉĂĐƚ/KͲϯ͗/ŵƉĂĐƚƐƚŽƐƚĂƚĞĂŶĚĨĞĚĞƌĂůǁĞƚůĂŶĚƐdŚĞ /ZŝŵƉĂĐƚĐĂůĐƵůĂƚŝŽŶƐĂƌĞĚŝĨĨŝĐƵůƚƚŽĨŽůůŽǁŝŶƐŽŵĞĂƌĞĂƐ͕ĂŶĚƚŚĞĂƉƉůŝĐĂŶƚďĞůŝĞǀĞƐƚŚĞŝƌĞƐƚŝŵĂƚĞŽĨϱ͘ϮϳĂĐƌĞƐŽĨŝŵƉĂĐƚĞĚǁĞƚůĂŶĚƐĂƌĞŽǀĞƌͲƐƚĂƚĞĚ͘&ƵƌƚŚĞƌ͕ŚƵŵĂŶŝŶĚƵĐĞĚŽƌĐŽŶƐƚƌƵĐƚĞĚǁĞƚůĂŶĚƐŝŶƚŚĞ/,WĂƐŝŶƐŚŽƵůĚŶŽƚďĞĂĨĨŽƌĚĞĚƚŚĞƐĂŵĞŵŝƚŝŐĂƚŝŽŶƌĂƚŝŽŶŽĨϯ͗ϭƌĞƋƵŝƌĞĚĨŽƌŶĂƚƵƌĂůůLJŽĐĐƵƌƌŝŶŐǁĞƚůĂŶĚƐƚŚĂƚǁŝůůďĞƌĞŐƵůĂƚĞĚƵŶĚĞƌƚŚĞůĞĂŶtĂƚĞƌA.1-78cont.A.1-79A.1-808-210
02059
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 22 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zĐƚ͘ĂƐŝŶǁĞƚůĂŶĚƐĂƌĞĨŽƌŵĞĚĨƌŽŵĂƌƚŝĨŝĐŝĂůŚLJĚƌŽůŽŐLJ͕ĂŶĚƐŚŽƵůĚďĞƌĞƉůĂĐĞĚĂƚĂϭ͗ϭƌĂƚŝŽ͘dŚĞĂƉƉůŝĐĂŶƚŝƐǀĞƌLJĐŽŶĐĞƌŶĞĚǁŝƚŚƚŚĞϮ͗ϭŵŝƚŝŐĂƚŝŽŶƌĂƚŝŽĨŽƌƉŽƚĞŶƚŝĂůŝŶĚŝƌĞĐƚŝŵƉĂĐƚƐƚŽĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐƚŚĂƚDzŽĐĐƵƌĨƌŽŵƚŚĞ&ƌŽŽŵƌĞĞŬƌĞĂůŝŐŶŵĞŶƚ͘dŚŝƐŝƐƐƉĞĐƵůĂƚŝǀĞƚŚĂƚŝŵƉĂĐƚƐƚŽƚŚĞĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚǁŽƵůĚŽĐĐƵƌĨƌŽŵƚŚĞƉƌŽũĞĐƚ͕ĂŶĚƚŚĞŵŝƚŝŐĂƚŝŽŶƌĞƋƵŝƌĞŵĞŶƚŝƐĞdžĐĞƐƐŝǀĞĨŽƌĂŶŝŵƉĂĐƚƚŚĂƚŵĂLJŶŽƚŽĐĐƵƌ͘DŝƚŝŐĂƚŝŽŶŝŶƚŚĞĨŽƌŵŽĨϭϬ͘ϮϰĂĐƌĞƐŽĨǁĞƚůĂŶĚĐƌĞĂƚŝŽŶĨŽƌĂƉŽƚĞŶƚŝĂůŝŵƉĂĐƚƐŚŽƵůĚŶŽƚďĞƌĞƋƵŝƌĞĚ͘ŵŽƌĞĂƉƉƌŽƉƌŝĂƚĞĂŶĚƌĞĂůŝƐƚŝĐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞǁŽƵůĚďĞƚŽĚĞǀĞůŽƉƐƉĞĐŝĨŝĐĐƌŝƚĞƌŝĂĂƐƉĂƌƚŽĨƚŚĞŵŽŶŝƚŽƌŝŶŐƉƌŽŐƌĂŵŝŶƚŚĞ,DDW͕ĂŶĚƋƵĂŶƚŝƚĂƚŝǀĞĂŶĚƋƵĂůŝƚĂƚŝǀĞĚĂƚĂĐŽƵůĚďĞĐŽůůĞĐƚĞĚƚŽĚĞƚĞƌŵŝŶĞŝĨŝŵƉĂĐƚƐƚŽĂůůĞ:ŽĂƋƵŝŶǁĞƚůĂŶĚƐŽĐĐƵƌĨƌŽŵĐƌĞĞŬƌĞĂůŝŐŶŵĞŶƚ͘/ĨŝŵƉĂĐƚƐƐƵĐŚĂƐƐĞĚŝŵĞŶƚĂƚŝŽŶŽƌĐŚĂŶŶĞůŵŝŐƌĂƚŝŽŶĂƌĞŽďƐĞƌǀĞĚƚŚĂƚĂƌĞĂĐƚƵĂůůLJĂĚǀĞƌƐĞůLJŝŵƉĂĐƚŝŶŐƚŚĞǁĞƚůĂŶĚŚĂďŝƚĂƚ͕ƚŚĞŶĂĚĂƉƚŝǀĞŵĂŶĂŐĞŵĞŶƚƐƚƌĂƚĞŐŝĞƐĐŽƵůĚďĞŝŶƉůĂĐĞƚŽƌĞŵĞĚLJƚŚĞƐĞŝŵƉĂĐƚƐďĞĨŽƌĞƚŚĞLJďĞĐŽŵĞƐŝŐŶŝĨŝĐĂŶƚ͘dŚĞ /ZĐŽŶƐƵůƚĂŶƚĂƉƉĞĂƌƐƚŽŚĂǀĞŝŶĐůƵĚĞĚ͞ŽƚŚĞƌǁĂƚĞƌƐ͟;ŝ͘Ğ͘ƚŚĞĞdžŝƐƚŝŶŐ&ƌŽŽŵƌĞĞŬĐŚĂŶŶĞůͿ͕ǁŚŝĐŚŝƐĂŶŝŶƚĞƌŵŝƚƚĞŶƚƐƚƌĞĂŵďĞĚ;ŶŽŶͲǁĞƚůĂŶĚͿŝŶƚŚĞǁĞƚůĂŶĚŝŵƉĂĐƚĐĂůĐƵůĂƚŝŽŶƐ͘dŚĞĂƌĞĂŽĨƚŚĞĞdžŝƐƚŝŶŐ&ƌŽŽŵƌĞĞŬĐŚĂŶŶĞůƐŚŽƵůĚŶŽƚďĞŵŝƚŝŐĂƚĞĚĂƚĂϯ͗ϭ͕ďƵƚĂƚĂϭ͗ϭƌĂƚŝŽƐŝŶĐĞŝƚŝƐĂŶŽŶͲǁĞƚůĂŶĚĚƌĂŝŶĂŐĞĨĞĂƚƵƌĞ͕ĂŶĚƚŚĞƌĞĂůŝŐŶŵĞŶƚŝƐŵŽƌĞŽĨĂƚĞŵƉŽƌĂƌLJŝŵƉĂĐƚ͘dŚĞŐŽĂůĨŽƌƚŚĞƉƌŽũĞĐƚŝƐƚŽŚĂǀĞĂůůǁĞƚůĂŶĚ͕ƌŝƉĂƌŝĂŶĂŶĚĐƌĞĞŬĐŚĂŶŶĞůŝŵƉĂĐƚƐŵŝƚŝŐĂƚĞĚĂĚĞƋƵĂƚĞůLJŽŶƐŝƚĞ͘ϮϮ WĂŐĞϯ͘ϰͲϳϳ/ŵƉĂĐƚ/KͲϰ͗tŝůĚůŝĨĞŵŽǀĞŵĞŶƚĂŶĚĐŽƌƌŝĚŽƌƐdŚĞ /ZĐŽŶƐƵůƚĂŶƚĚĞƚĞƌŵŝŶĞĚƚŚĂƚƚŚĞĐŽŶĨůƵĞŶĐĞŽĨ&ƌŽŽŵƌĞĞŬǁŝƚŚƌĂŝŶĂŐĞƐϭ͕Ϯ͕ĂŶĚϯŝƐǀĂůƵĂďůĞĨŽƌǁŝůĚůŝĨĞŵŽǀĞŵĞŶƚĂŶĚŝƐƌĞĐŽŵŵĞŶĚŝŶŐƚŚĞƌĞŵŽǀĂůŽĨĚĞǀĞůŽƉŵĞŶƚŝŶƚŚŝƐĂƌĞĂ͘dŚĞĂŶĂůLJƐŝƐƐŚŽƵůĚďĞĨƵƌƚŚĞƌĚĞƚĂŝůĞĚƚŽƐƵƉƉŽƌƚƚŚŝƐĐŽŶĐĞƉƚĂŶĚƚŚĞƌĞƋƵŝƌĞĚĚĞǀĞůŽƉŵĞŶƚƐĞƚďĂĐŬ͘ džƚĞŶƐŝǀĞŽƉĞŶƐƉĂĐĞĂƌĞĂƐĞdžŝƐƚŝŶƚŚĞƌĞŐŝŽŶĂŶĚĂŵƉůĞƌŽŽŵǁŝůůƉĞƌƐŝƐƚĨŽƌǁŝůĚůŝĨĞŵŽǀĞŵĞŶƚŝŶƚŚĞĂƌĞĂĞǀĞŶǁŝƚŚĚĞǀĞůŽƉŵĞŶƚŝŶƚŚŝƐůŽĐĂƚŝŽŶ͘tĂƚĞƌƐƵƉƉůŝĞƐĂƌĞƉƌĞƐĞŶƚĨƵƌƚŚĞƌƵƉŽŶƚŚĞƵƉƉĞƌƚĞƌƌĂĐĞĂƚƐƉƌŝŶŐƐĂůŽŶŐƚŚĞƉƌŽƉĞƌƚLJďŽƵŶĚĂƌLJǁŝƚŚƚŚĞ/ƌŝƐŚ,ŝůůƐEĂƚƵƌĂůWƌĞƐĞƌǀĞĂƐǁĞůůĂƐŽŶA.1-80cont.A.1-818-211
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 23 &ZKKDZE, /Z<DZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϰ/K>K'zŶĞŝŐŚďŽƌŝŶŐƉƌŽƉĞƌƚŝĞƐƚŽƚŚĞƐŽƵƚŚĂŶĚǁĞƐƚ͘/ŶĂĚĚŝƚŝŽŶ͕ŐŝǀĞŶĚĞǀĞůŽƉŵĞŶƚĂůŽŶŐĂůůĞ:ŽĂƋƵŝŶ;ŚŽƚĞůƐ͕ƚŚĞDŽƵŶƚĂŝŶďƌŽŽŬŚƵƌĐŚ͕ĂŶĚ<^zͿĂŶĚ,ŝŐŚǁĂLJϭϬϭ͕ǁŚŝĐŚŝƐĂƐŝŐŶŝĨŝĐĂŶƚďĂƌƌŝĞƌƚŽǁŝůĚůŝĨĞŵŽǀĞŵĞŶƚ͕ŝƚŝƐŶŽƚĐůĞĂƌŐŝǀĞŶƚŚĞĚŝƐĐƵƐƐŝŽŶĂŶĚĂŶĂůLJƐŝƐŝŶƚŚĞ /ZǁŚĞƚŚĞƌĂƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚƚŽǁŝůĚůŝĨĞŵŽǀĞŵĞŶƚǁŽƵůĚŽĐĐƵƌŝŶƚŚŝƐƉŽƌƚŝŽŶŽĨƚŚĞƐŝƚĞ͘Ϯϯ WĂŐĞƐϯ͘ϰͲϰϳƚŚƌŽƵŐŚϯ͘ϰͲϴϳDŽŶŝƚŽƌŝŶŐƉĞƌŝŽĚƐƌĞĨĞƌĞŶĐĞĚƚŚƌŽƵŐŚŽƵƚƚŚĞŵŝƚŝŐĂƚŝŽŶƐĞĐƚŝŽŶĂƌĞŶŽƚĐŽŶƐŝƐƚĞŶƚ͘/ŶŽŶĞůŽĐĂƚŝŽŶ͕ƚŚĞ /ZƐƚĂƚĞƐϳLJĞĂƌƐŽĨŵŽŶŝƚŽƌŝŶŐǁŝůůďĞƌĞƋƵŝƌĞĚ͕ƚŚĞŶŝŶĂŶŽƚŚĞƌϱLJĞĂƌƐǁŝƚŚƚŚĞƉŽƚĞŶƚŝĂůƚŽĞdžƚĞŶĚĂŶŽƚŚĞƌϮLJĞĂƌƐŝĨƚŚĞƐƵĐĐĞƐƐĐƌŝƚĞƌŝĂŚĂǀĞŶŽƚďĞĞŶŵĞƚ͘dŚĞ /ZƐŚŽƵůĚďĞĐŽŶƐŝƐƚĞŶƚƚŚĂƚŵŝƚŝŐĂƚŝŽŶŵŽŶŝƚŽƌŝŶŐƐŚŽƵůĚďĞĂŵŝŶŝŵƵŵŽĨϱLJĞĂƌƐĂŶĚǁŝůůĞdžƚĞŶĚŽŶĂŶĂŶŶƵĂůďĂƐŝƐĂƐŶĞĞĚĞĚƵŶƚŝůƚŚĞĨŝŶĂůƐƵĐĐĞƐƐĐƌŝƚĞƌŝĂĚĞĨŝŶĞĚŝŶƚŚĞ,DDWĂŶĚĂƉƉƌŽǀĞĚďLJƚŚĞƉĞƌŵŝƚƚŝŶŐĂŐĞŶĐŝĞƐŚĂǀĞďĞĞŶŵĞƚ͘A.1-81cont.A.1-828-212
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 24 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϱh>dhZ>EdZ/>Z ^KhZ ^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϱƵůƚƵƌĂůĂŶĚdƌŝďĂůZĞƐŽƵƌĐĞƐϭ͘ WĂŐĞϯ͘ϱͲϯϴ͕/ŵƉĂĐƚZͲϯ͕ďŽƚƚŽŵĨƵůůƉĂƌĂŐƌĂƉŚWƌŽũĞĐƚ,ŝƐƚŽƌŝĐƌĐŚŝƚĞĐƚĚŝƐĂŐƌĞĞƐ͘Ϯ͘ WĂŐĞϯ͘ϱͲϯϵ͕DŝĚĚůĞWĂƌĂŐƌĂƉŚƌĞŐĂƌĚŝŶŐĚĞŐƌĂĚĂƚŝŽŶŽĨƚŚĞŝŶƚĞŐƌŝƚLJŽĨƉŽƚĞŶƚŝĂůŝƐƚƌŝĐƚWƌŽũĞĐƚ,ŝƐƚŽƌŝĐƌĐŚŝƚĞĐƚĚŝƐĂŐƌĞĞƐĂŶĚƉƌŽǀŝĚĞĚƚŚĞŝƚLJǁŝƚŚĂŶĞdžĂŵƉůĞŽĨĂƉƌŽũĞĐƚĞůŝŐŝďůĞƚŽďĞĂŝƐƚƌŝĐƚĞǀĞŶƚŚŽƵŐŚďƵŝůĚŝŶŐƐǁĞƌĞƌĞůŽĐĂƚĞĚ͕ƌĞĐŽŶƐƚƌƵĐƚĞĚĂŶĚƐŽŵĞďƵŝůĚŝŶŐƐǁĞƌĞĞůŝŵŝŶĂƚĞĚ͘^ĂŵDĂůŽŽĨŽŵƉůĞdžůŽĐĂƚĞĚŝŶůƚĂ>ŽŵĂ͕͘ϯ͘ WĂŐĞϯ͘ϱͲϰϬ͕DDZͲϵ͕ZĞƋƵŝƌĞŵĞŶƚƐĂŶĚdŝŵŝŶŐEĞŝƚŚĞƌƚŚĞ,ŝƐƚŽƌŝĐƌĐŚŝƚĞĐƚŶŽƌƚŚĞĂƉƉůŝĐĂŶƚĐĂŶŐƵĂƌĂŶƚĞĞƉƵďůŝĐĂƚŝŽŶŽĨĂŶĂƌƚŝĐůĞŝŶĂƐĐŝĞŶƚŝĨŝĐũŽƵƌŶĂů͘ůůƚŚĞLJĐĂŶĂƐƐƵƌĞŝƐƐƵďŵŝƚƚĂůƚŽĂũŽƵƌŶĂů͘ϰ͘ WĂŐĞϯ͘ϱͲϰϮĂŶĚϰϯ͕DDZͲϭϯ͕ZĞƋƵŝƌĞŵĞŶƚƐĂŶĚdŝŵŝŶŐZĞƋƵŝƌŝŶŐĞƐŝŐŶ'ƵŝĚĞůŝŶĞƐĨŽƌĂŶĞǁďƵŝůĚŝŶŐƉƌŝŽƌƚŽĂƉƉƌŽǀĂůŽĨĞŶƚŝƚůĞŵĞŶƚƐĂŶĚŝƐƐƵĂŶĐĞŽĨWŚĂƐĞϭŐƌĂĚŝŶŐƉĞƌŵŝƚƐŝƐƉƌĞŵĂƚƵƌĞ͘dŚĞĐŽŵŵĞƌĐŝĂůƉŽƌƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚŝƐƉŽƚĞŶƚŝĂůůLJƐĞǀĞƌĂůLJĞĂƌƐůĂƚĞƌ͘ϱ͘ WĂŐĞϯ͘ϱͲϰϰ͕ZĞƐŝĚƵĂů/ŵƉĂĐƚ ,ŝƐƚŽƌŝĐƌĐŚŝƚĞĐƚĂŶĚĂƉƉůŝĐĂŶƚĚŝƐĂŐƌĞĞƚŚĂƚŝŵƉĂĐƚƐĂƌĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘ϲ͘ WĂŐĞϯ͘ϱͲϰϱ͕ƵŵƵůĂƚŝǀĞ/ŵƉĂĐƚƐ ^ĞĞĐŽŵŵĞŶƚƐηϮĂŶĚηϱĂďŽǀĞ͘A.1-83A.1-84A.1-86A.1-87A.1-88A.1-858-213
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 25 &ZKKDZE, /Z' K^K>hd/KE^Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϲ' K>K'zE^K/>^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϲ'ĞŽůŽŐLJĂŶĚ^ŽŝůƐϭ WĂŐĞϯ͘ϲͲϮϮ͕ƐĞĐŽŶĚƉĂƌĂŐƌĂƉŚ͙͘͟ĂůƚŚŽƵŐŚƚŚĞƐŝƚĞŝƐƚƌĂŶƐĞĐƚĞĚďLJĂĨĂƵůƚůŝŶĞ͕ƚŚĞƐŝƚĞŝƐŶŽƚůŽĐĂƚĞĚǁŝƚŚŝŶĂŶ ĂƌƚŚƋƵĂŬĞ&ĂƵůƚŽŶĞĂŶĚŝƐŶŽƚƐƵďũĞĐƚƚŽĂŵŽĚĞƌĂƚĞŽƌŚŝŐŚƚŚƌĞĂƚŽĨŐƌŽƵŶĚƐƵƌĨĂĐĞƌƵƉƚƵƌĞ͘͟dŚĞWƌĞůŝŵŝŶĂƌLJ ŶŐŝŶĞĞƌŝŶŐ'ĞŽůŽŐLJ/ŶǀĞƐƚŝŐĂƚŝŽŶƐƚĂƚĞƐŽŶƉĂŐĞϯ͞dŚĞƉŽƚĞŶƚŝĂůĨŽƌŐƌŽƵŶĚƌƵƉƚƵƌĞĂƚƚŚĞ^ŝƚĞĚƵƌŝŶŐŐƌŽƵŶĚƐŚĂŬŝŶŐŝƐĐŽŶƐŝĚĞƌĞĚŵŽĚĞƌĂƚĞ͙͘͟Ϯ WĂŐĞϯ͘ϲ͕ƐĞĐŽŶĚƉĂƌĂŐƌĂƉŚ͕͞ŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞWƌŽũĞĐƚƐŝƚĞǁŽƵůĚŝŶǀŽůǀĞůĂƌŐĞĂŵŽƵŶƚƐŽĨŐƌĂĚŝŶŐ͕ĞĂƌƚŚŵŽǀŝŶŐ͕ĂŶĚƚŚĞŝŵƉŽƌƚŽĨĞŶŐŝŶĞĞƌĞĚĨŝůůĨŽƵŶĚĂƚŝŽŶŝŶƚŚĞůŽǁĞƌͲĞůĞǀĂƚŝŽŶ͙͘͟dŚŝƐƐƚĂƚĞŵĞŶƚŝƐĂǁŬǁĂƌĚůLJǁƌŝƚƚĞŶǁŝƚŚƚŚĞǁŽƌĚƐ͞ĞŶŐŝŶĞĞƌĞĚĨŝůůĨŽƵŶĚĂƚŝŽŶ͘͟DĂLJďĞƐĂLJ͕͞ĂŶĚƚŚĞŝŵƉŽƌƚŽĨĨŝůůĨŽƌƵƐĞĂƐĞŶŐŝŶĞĞƌĞĚĨŝůůĨŽƌĨŽƵŶĚĂƚŝŽŶƐŝŶƚŚĞ͙͘͟dŚŝƐƐĞŶƚĞŶĐĞŝƐƌĞƉĞĂƚĞĚŝŶƚŚĞƐĂŵĞƉĂƌĂŐƌĂƉŚŝŶƚŚĞĨŝŶĂůƐĞŶƚĞŶĐĞǁŝƚŚƚǁŽƐƚĂƚĞŵĞŶƚƐ͗͞/ŶĐŽŵďŝŶĂƚŝŽŶǁŝƚŚƚŚĞƵƐĞŽĨĞŶŐŝŶĞĞƌĞĚĨŝůůĨŽƵŶĚĂƚŝŽŶŝŶƚŚĞůŽǁĞƌͲĞůĞǀĂƚŝŽŶĂƌĞĂŽĨƚŚĞWƌŽũĞĐƚƐŝƚĞ͕ƵŶŝĨŽƌŵĨŽƵŶĚĂƚŝŽŶƐ͙͘͟dŚĞƵƐĞŽĨƚŚĞƚĞƌŵ͞ƵŶŝĨŽƌŵĨŽƵŶĚĂƚŝŽŶƐ͟ŚĂƐŶŽŵĞĂŶŝŶŐ͘ϯ WĂŐĞϯ͘ϲͲϮϲ͕ƐĞĐŽŶĚƉĂƌĂŐƌĂƉŚ͞dŽƉƌĞǀĞŶƚŐƌŽƵŶĚǁĂƚĞƌĨƌŽŵĞŶƚĞƌŝŶŐŝŶƚŽĂŶĚƉŽƚĞŶƚŝĂůůLJĚĂŵĂŐŝŶŐƚŚĞWƌŽũĞĐƚ͕ƚŚĞWƌĞůŝŵŝŶĂƌLJ ŶŐŝŶĞĞƌŝŶŐ'ĞŽůŽŐLJ/ŶǀĞƐƚŝŐĂƚŝŽŶƌĞĐŽŵŵĞŶĚƐ͙͘͟dŚĞWƌĞůŝŵŝŶĂƌLJ ŶŐŝŶĞĞƌŝŶŐ'ĞŽůŽŐLJ/ŶǀĞƐƚŝŐĂƚŝŽŶĚŝĚŶŽƚƌĞĐŽŵŵĞŶĚƚŚĞƵƉƉĞƌϯϲŝŶĐŚĞƐŽĨƚŚĞĚĞǀĞůŽƉŵĞŶƚĂƌĞĂƐŚŽƵůĚĐŽŶƐŝƐƚŽĨĂƐĞůĞĐƚŝŵƉŽƌƚ͘dŚŝƐǁĂƐƚŚĞƉƌŽũĞĐƚ^ŽŝůƐ ŶŐŝŶĞĞƌŝŶŐZĞƉŽƌƚ͘A.1-89A.1-90A.1-918-214
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 26 &ZKKDZE, /Zs/>>''/KZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϳ,Z^Et/>&/Z ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϳ,ĂnjĂƌĚƐĂŶĚtŝůĚĨŝƌĞϭ WĂŐĞϯ͘ϳͲϮϳdŚŝƐƐĞĐƚŝŽŶƌĞůĂƚĞƐƚŽ ŵĞƌŐĞŶĐLJ ǀĂĐƵĂƚŝŽŶƉƌŽĐĞĚƵƌĞƐĂŶĚĞĨĨĞĐƚƐ͘/ŶƐƉĞĐŝĨŝĐ͕ŝƚƋƵŽƚĞƐ͗͞ŝƚŵĂLJďĞĚŝĨĨŝĐƵůƚĨŽƌƚŚĞŚĞĂůƚŚĐĂƌĞĐĞŶƚĞƌƚŽŐƵŝĚĞ͚ƉĂŶŝĐŬĞĚ͛ŝŶĚŝǀŝĚƵĂůƐƚŽĨŝƌĞŵĞĞƚŝŶŐƉŽŝŶƚƐĂŶĚƐŚĞůƚĞƌͲŝŶͲƉůĂĐĞůŽĐĂƚŝŽŶƐĂƐĚĞƚĂŝůĞĚǁŝƚŚŝŶƚŚĞƌĂĨƚ&Z^WWƌŽŐƌĂŵ͘͟>ŝĨĞWůĂŶĐŽŵŵƵŶŝƚŝĞƐĂƌĞŵĂŶĚĂƚĞĚďLJ^ƚĂƚĞZĞŐƵůĂƚŝŽŶƐƚŽŚĂǀĞĂǁĞůůͲƉůĂŶŶĞĚĂŶĚƉƌĂĐƚŝĐĞĚŝƐĂƐƚĞƌWůĂŶǁŝƚŚ ŵĞƌŐĞŶĐLJ ǀĂĐƵĂƚŝŽŶƉƌŽĐĞĚƵƌĞƐ͘dŚŝƐWůĂŶƌĞƋƵŝƌĞƐƚŚĞĐŽŵŵƵŶŝƚLJƚŽĐŽŶĚƵĐƚĚƌŝůůƐŽŶĞĂĐŚƐŚŝĨƚĞǀĞƌLJƋƵĂƌƚĞƌŽŶĂŶĂŶŶƵĂůďĂƐŝƐ͘dŚĞWůĂŶŵƵƐƚĂůƐŽďĞƌĞǀŝĞǁĞĚĂŶĚƵƉĚĂƚĞĚĂŶŶƵĂůůLJ͘ŽƚŚƐƚĂĨĨĂŶĚƌĞƐŝĚĞŶƚƐĂƌĞŵĂĚĞĨƵůůLJĂǁĂƌĞŽĨƚŚĞŝŵƉŽƌƚĂŶĐĞŽĨƚŚŝƐƌĞŐƵůĂƚŝŽŶĂŶĚƉĂƌƚŝĐŝƉĂƚŝŽŶŝŶƚŚĞĚƌŝůůƐŝƐŵĂŶĚĂƚŽƌLJ͘dŚĞWůĂŶĂůƐŽŝŶĐůƵĚĞƐƉŽůŝĐŝĞƐĨŽƌƐŚĞůƚĞƌŝŶŐͲŝŶͲƉůĂĐĞĂŶĚƚĞŵƉŽƌĂƌLJƐŚĞůƚĞƌŽĨĨͲƐŝƚĞ͘dŚĞƐĞƌĞŐƵůĂƚŝŽŶƐĐĂŶďĞƌĞĨĞƌĞŶĐĞĚŝŶ,ĞĂůƚŚ^ĂĨĞƚLJŽĚĞϭϱϲϵ͘ϲϵϱĂŶĚdŝƚůĞϮϮ^ĞĐƚŝŽŶϴϳϮϭϮ͘A.1-928-215
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 27 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϴ,zZK>K'zEtd ZYh>/dzŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϴ,LJĚƌŽůŽŐLJĂŶĚtĂƚĞƌYƵĂůŝƚLJϭ WŐ͘ϯ͘ϴͲϭϬ>ĂƐƚƐĞŶƚĞŶĐĞŽĨƚŚĞWĞĂŬ&ůŽǁƐĂŶĚKǀĞƌƚŽƉƉŝŶŐ͙ƉĂƌĂŐƌĂƉŚƌĞĨĞƌĞŶĐĞƐƉƉĞŶĚŝdž:ĂƐƚŚĞŚLJĚƌŽůŽŐLJĂƉƉĞŶĚŝdž͘dŚĞĐŽƌƌĞĐƚƌĞĨĞƌĞŶĐĞŝƐƉƉĞŶĚŝdž,͘dŚŝƐƌĞĨĞƌĞŶĐĞŽĐĐƵƌƐŝŶŵƵůƚŝƉůĞůŽĐĂƚŝŽŶƐƚŚƌŽƵŐŚŽƵƚ^ĞĐƚŝŽŶϯ͘ϴϮ WŐ͘ϯ͘ϴͲϭϵ͞^ƉĞĐŝĂů&ůŽŽĚƉůĂŝŶDĂŶĂŐĞŵĞŶƚŽŶĞZĞŐƵůĂƚŝŽŶƐ͟;^&DͿ͘dŚŝƐƐĞĐƚŝŽŶŝŵƉůŝĞƐƚŚĂƚƚŚĞƉƌŽũĞĐƚŝƐŝŶĂƐƉĞĐŝĂůĨůŽŽĚƉůĂŝŶŵĂŶĂŐĞŵĞŶƚnjŽŶĞĂƐŝĚĞŶƚŝĨŝĞĚŝŶƚŚĞŝƚLJŽĨ^>KƌĂŝŶĂŐĞĞƐŝŐŶDĂŶƵĂů;DͿ͘dŚĞƉƌŽũĞĐƚŝƐEKdůŽĐĂƚĞĚŝŶĂ^&D͘&ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϵ>Eh^ EW>EE/E'ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϵ>ĂŶĚhƐĞĂŶĚWůĂŶŶŝŶŐϭ dĂďůĞϯ͘ϵͲϰ͕ƉĂŐĞϯ͘ϵͲϭϴ͕ϭ͘ϴ͘ϱƵŝůĚŝŶŐĞƐŝŐŶĂŶĚ^ŝƚŝŶŐĚŝƐĐƵƐƐŝŽŶdŚĞĚŝƐĐƵƐƐŝŽŶƐƚĂƚĞƐƚŚĞĚĞǀĞůŽƉŵĞŶƚŽŶƚŚĞƵƉƉĞƌƚĞƌƌĂĐĞĂƌĞĂǁŽƵůĚďĞ͞ŚŝŐŚůLJǀŝƐŝďůĞĨƌŽŵƉƵďůŝĐƌŽĂĚƐ͘͟dŚŝƐĐŽŶĐůƵƐŝŽŶŝƐŶŽƚĐŽƌƌĞĐƚĂŶĚŝƐŶŽƚƐƵƉƉŽƌƚĞĚďLJƚŚĞĂĞƐƚŚĞƚŝĐƐĂŶĚǀŝƐƵĂůĂŶĂůLJƐŝƐƐĞĐƚŝŽŶŽĨƚŚĞ /Z͘Ϯ dĂďůĞϯ͘ϵͲϰ͕ƉĂŐĞϯ͘ϵͲϮϯ͕ϲ͘ϰ͘ϭ,ŝůůƐŝĚĞWŽůŝĐŝĞƐŝƐĐƵƐƐŝŽŶ^ĞĞĐŽŵŵĞŶƚηϭĂďŽǀĞ͘dŚŝƐĚŝƐĐƵƐƐŝŽŶŽĨǀŝĞǁƐĨƌŽŵƉƵďůŝĐƌŽĂĚƐŝƐŶŽƚƐƵƉƉŽƌƚĞĚďLJƚŚĞǀŝƐƵĂůĂŶĂůLJƐŝƐƐĞĐƚŝŽŶŽĨƚŚĞ /Z͘ϯ dĂďůĞϯ͘ϵͲϰ͕ƉĂŐĞϯ͘ϵͲϮϰϰ͕ϵ͘Ϯ͘ϭ ^ĞĞĐŽŵŵĞŶƚƐηϭĂŶĚηϮĂďŽǀĞ͘ϰ /ŵƉĂĐƚ>hͲϭ͕ƉĂŐĞϯ͘ϵͲϲϬ͕ϭƐƚƉĂƌĂŐƌĂƉŚ͕sŝĞǁƐŽĨhƉƉĞƌdĞƌƌĂĐĞ^ĞĞĐŽŵŵĞŶƚƐηϭ͕ϮĂďŽǀĞ͘ϱ WĂŐĞϯ͘ϵͲϲϬ͕ĞƐƚŚĞƚŝĐƐdŚĞĐŽŶĐůƵƐŝŽŶƐƌĞŐĂƌĚŝŶŐƐŝŐŶŝĨŝĐĂŶƚƉŚLJƐŝĐĂůĞŶǀŝƌŽŶŵĞŶƚĂůŝŵƉĂĐƚƐƚŽĂĞƐƚŚĞƚŝĐƌĞƐŽƵƌĐĞƐƚŽƌĞĐƌĞĂƚŝŽŶĂůŝƐƚĂƌĞŶŽƚƐƵƉƉŽƌƚĞĚďLJĂŶLJƋƵĂŶƚŝĨŝĂďůĞŵĞĂƐƵƌĞŽƌĞdžƉůŝĐŝƚůLJƐƚĂƚĞĚƉŽůŝĐLJ͘dŚĞLJĂƉƉĞĂƌƚŽďĞŽƉŝŶŝŽŶŽĨƚŚĞ /ZƉƌĞƉĂƌĞƌŶŽƚĂĨĂĐƚďĂƐĞĚĂŶĚƐƵƉƉŽƌƚĞĚĐŽŶĐůƵƐŝŽŶ͘ϲ WĂŐĞϯ͘ϵͲϲϭ͕,ŝƐƚŽƌŝĐZĞƐŽƵƌĐĞƐ dŚĞĂƉƉůŝĐĂŶƚƐƌĞƚĂŝŶĞĚĞdžƉĞƌƚ,ŝƐƚŽƌŝĐƌĐŚŝƚĞĐƚ;ZŽďĞƌƚŚĂƚƚĞůͿĚŝƐĂŐƌĞĞƐǁŝƚŚƚŚĞĐŽŶĐůƵƐŝŽŶƚŚĂƚŝŵƉĂĐƚƐĂƌĞƐŝŐŶŝĨŝĐĂŶƚĂŶĚƵŶĂǀŽŝĚĂďůĞ͘ϳ WĂŐĞϯ͘ϵͲϲϮ͕ ŵĞƌŐĞŶĐLJĐĐĞƐƐĂŶĚtŝůĚĨŝƌĞ^ĞĞĂƉƉůŝĐĂŶƚƐ͛ƉƌŝŽƌĐŽŵŵĞŶƚƐŽŶƚŚĞ,ĂnjĂƌĚƐŚĂƉƚĞƌ͘A.1-93A.1-94A.1-95A.1-96A.1-97A.1-98A.1-99A.1-100A.1-1018-216
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 28 ϴ WĂŐĞϯ͘ϵͲϲϯ͕ZĞƐŝĚƵĂů/ŵƉĂĐƚƐƉƉůŝĐĂŶƚĚŝƐĂŐƌĞĞƐƚŚĂƚ/ŵƉĂĐƚƐĂƌĞ^ŝŐŶŝĨŝĐĂŶƚĂŶĚhŶĂǀŽŝĚĂďůĞ͘^ĞĞĐŽŵŵĞŶƚƐŽŶ,ĂnjĂƌĚƐĂŶĚĞƐƚŚĞƚŝĐƐ͘&ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϬEK/^ ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϬEŽŝƐĞϭ DDͲEKͲϰ͕ƉĂŐĞϯ͘ϭϬͲϯϰ͕ϯϱ͕ϯϲ͕EŽŝƐĞĨƌŽŵĞdžŝƐƚŝŶŐĐŽŵŵĞƌĐŝĂůƵƐĞƐdŚĞ /ZĂƉƉĞĂƌƐƚŽƉƌĞƐĞŶƚƚŚŝƐƚŽƉŝĐĂƐĂŶĞŶǀŝƌŽŶŵĞŶƚĂůŝŵƉĂĐƚŽĨƚŚĞƉƌŽũĞĐƚ͘,ŽǁĞǀĞƌ͕ŝƚĂƉƉĞĂƌƐƚŽďĞĂŶŝŵƉĂĐƚŽĨƚŚĞĞdžŝƐƚŝŶŐĞŶǀŝƌŽŶŵĞŶƚŽŶƚŚĞƉƌŽũĞĐƚ͘&ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϭWKWh>d/KEE,Kh^/E'ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϭWŽƉƵůĂƚŝŽŶĂŶĚ,ŽƵƐŝŶŐϭ /ŵƉĂĐƚW,Ͳϭ͕ƉĂŐĞϯ͘ϭϭͲϮϬ͕ϯƌĚƉĂƌĂŐƌĂƉŚϯ͕ďŽƚƚŽŵŽĨƚŚĞƉĂŐĞdŚĞ /ZŽǀĞƌƐƚĂƚĞƐƚŚĞůŝŬĞůLJƉŽƉƵůĂƚŝŽŶŽĨƚŚĞsŝůůĂŐŐŝŽƉŽƌƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚďLJƵƐŝŶŐĂŶŽĐĐƵƉĂŶĐLJĨĂĐƚŽƌŽĨϮƉĞƌƐŽŶƐƉĞƌƵŶŝƚ͘dŚĞĂƉƉůŝĐĂŶƚƉƌŽǀŝĚĞĚƚŚĞŝƚLJĚĂƚĂƌĞŐĂƌĚŝŶŐĞdžƉĞĐƚĞĚŽĐĐƵƉĂŶĐLJŝŶDĂƌĐŚϮϬϭϴŝŶĚŝĐĂƚŝŶŐŝƚǁŽƵůĚďĞϭ͘ϰƉĞƌƐŽŶƐƉĞƌƵŶŝƚŽĐĐƵƉĂŶĐLJĐŽŶƐŝƐƚĞŶƚǁŝƚŚŝŶĚƵƐƚƌLJĞdžƉĞƌŝĞŶĐĞĂŶĚĚĂƚĂ͘&ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϮWh>/^ Zs/ ^EZ Z d/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϮWƵďůŝĐ^ĞƌǀŝĐĞƐĂŶĚZĞĐƌĞĂƚŝŽŶϭ WĂŐĞƐϯ͘ϭϮͲϭϱƚŽϮϵ͕/ŵƉĂĐƚW^Ͳϭ͕ƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶdŚĞƉŽƉƵůĂƚŝŽŶƉƌŽũĞĐƚŝŽŶƐŝŐŶŝĨŝĐĂŶƚůLJŽǀĞƌƐƚĂƚĞƐƚŚĞƉƌŽďĂďůĞƉŽƉƵůĂƚŝŽŶŽĨƚŚĞsŝůůĂŐŐŝŽĐŽŵƉŽŶĞŶƚŽĨƚŚĞƉƌŽũĞĐƚ͘sŝůůĂŐŐŝŽĂĐƚƵĂůƉŽƉƵůĂƚŝŽŶŶƵŵďĞƌƐĨŽƌŝŶĚĞƉĞŶĚĞŶƚůŝǀŝŶŐƵŶŝƚƐĂƌĞĞdžƉĞĐƚĞĚƚŽƌĂŶŐĞĨƌŽŵϭ͘ϲĨŽƌƚŚĞŝŶŝƚŝĂůŽĐĐƵƉĂŶĐLJƉĞƌŝŽĚŽĨϭͲϳLJĞĂƌƐĂŶĚƚŚĞŶĚĞĐƌĞĂƐĞƚŽϭ͘ϰƉĞƌƐŽŶƐƉĞƌƵŶŝƚĨŽƌƚŚĞůŽŶŐͲƚĞƌŵŽƉĞƌĂƚŝŽŶŽĨƚŚĞŝŶĚĞƉĞŶĚĞŶƚůŝǀŝŶŐƵŶŝƚƐ͘A.1-102A.1-103A.1-104A.1-1058-217
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 29 Ϯ WĂŐĞϯ͘ϭϮͲϭϮ͕ϮϭĂŶĚϮϮ͕sŝůůĂŐŐŝŽĚĞƐĐƌŝƉƚŝŽŶ͕ϮŶĚƉĂƌĂŐƌĂƉŚĐĂůĐƵůĂƚŝŽŶŽĨWĂƌŬ>ĂŶĚZĞƋƵŝƌĞŵĞŶƚƐsŝůůĂŐŐŝŽĂĐƚƵĂůƉŽƉƵůĂƚŝŽŶŶƵŵďĞƌƐĨŽƌŝŶĚĞƉĞŶĚĞŶƚůŝǀŝŶŐƵŶŝƚƐĂƌĞĞdžƉĞĐƚĞĚƚŽƌĂŶŐĞĨƌŽŵϭ͘ϰƚŽϭ͘ϲƉĞƌƐŽŶƐƉĞƌƵŶŝƚĨŽƌƚŚĞŝŶĚĞƉĞŶĚĞŶƚůŝǀŝŶŐƵŶŝƚƐ͘ĂƐĞĚƵƉŽŶƚŚŝƐĚĂƚĂƚŚĞWĂƌŬůĂŶĚĐĂůĐƵůĂƚŝŽŶƐĂŶĚƌĞƋƵŝƌĞŵĞŶƚƐĂƌĞƐŝŐŶŝĨŝĐĂŶƚůLJŽǀĞƌƐƚĂƚĞĚ͘tĞĐŽŶĐƵƌƚŚĂƚƐƐŝƐƚĞĚ>ŝǀŝŶŐ͕ŵĞŵŽƌLJĐĂƌĞĂŶĚŽƚŚĞƌďĞĚƐǁŝůůŶŽƚŵĞĞƚƚŚĞƚŚƌĞƐŚŽůĚĨŽƌĂƐƐĞƐƐŵĞŶƚŽĨƉĂƌŬůĂŶĚĚĞĚŝĐĂƚŝŽŶŽĨŝŶůŝĞƵĨĞĞƐĨŽƌĂƚůĞĂƐƚϮƌĞĂƐŽŶƐϭ͘dŚĞƵƐĞŽĨƉƵďůŝĐƌĞĐƌĞĂƚŝŽŶĨĂĐŝůŝƚŝĞƐďLJƚŚĞƐĞƌĞƐŝĚĞŶƚƐǁŝůůŶŽƚŵĞĞƚƚŚĞƚŚƌĞƐŚŽůĚŽĨ͞/ŶĐƌĞĂƐĞƚŚĞƵƐĞŽĨĞdžŝƐƚŝŶŐŶĞŝŐŚďŽƌŚŽŽĚĂŶĚƌĞŐŝŽŶĂůƉĂƌŬƐŽƌŽƚŚĞƌƌĞĐƌĞĂƚŝŽŶĂůĨĂĐŝůŝƚŝĞƐƐƵĐŚƚŚĂƚƐƵďƐƚĂŶƚŝĂůƉŚLJƐŝĐĂůĚĞƚĞƌŝŽƌĂƚŝŽŶŽĨƚŚĞĨĂĐŝůŝƚLJǁŽƵůĚŽĐĐƵƌŽĨďĞĂĐĐĞůĞƌĂƚĞĚ͟ĂŶĚϮ͘sŝůůĂŐŐŝŽƉƌŽǀŝĚĞƐĂŐĞŶĞƌŽƵƐƐƵŝƚĞŽĨƌĞĐƌĞĂƚŝŽŶĨĂĐŝůŝƚŝĞƐŽŶƐŝƚĞƐƉĞĐŝĨŝĐĂůůLJƚĂƌŐĞƚĞĚĨŽƌƵƐĞďLJƚŚĞƐĞƌĞƐŝĚĞŶƚƐƚŚĂƚŚĂǀĞƉŚLJƐŝĐĂůůŝŵŝƚĂƚŝŽŶƐ͘A.1-1068-218
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 30 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϯdƌĂŶƐƉŽƌƚĂƚŝŽŶϭ 'ĞŶĞƌĂůŽŵŵĞŶƚʹdŝŵŝŶŐŽĨdƌĂŶƐƉŽƌƚĂƚŝŽŶDŝƚŝŐĂƚŝŽŶƐdŚĞƚƌĂŶƐƉŽƌƚĂƚŝŽŶƐĞĐƚŝŽŶŽĨƚŚĞ /ZŝŶĚŝĐĂƚĞƐƚŚĂƚŵĂŶLJŽĨƚŚĞŵŝƚŝŐĂƚŝŽŶƐŽĐĐƵƌƉƌŝŽƌƚŽƌĞĐŽƌĚĂƚŝŽŶŽĨƚŚĞĨŝŶĂůǀĞƐƚŝŶŐŵĂƉ͘dŚŝƐŝƐůŽŐŝƐƚŝĐĂůůLJŝŶĨĞĂƐŝďůĞƐŝŶĐĞƚŚĞĨŝŶĂůůĂƌŐĞůŽƚƉĂƌĐĞůŵĂƉŵƵƐƚƌĞĐŽƌĚĨŽƌƚŚĞƉƌŽũĞĐƚƚŽŵŽǀĞĨŽƌǁĂƌĚĂŶĚĐƌĞĂƚĞƚŚĞůĞŐĂůůŽƚƐĂƐƐŽĐŝĂƚĞĚǁŝƚŚƚŚĞĚĞǀĞůŽƉŵĞŶƚĂƌĞĂƐ͘dŚĞƚƌĂŶƐƉŽƌƚĂƚŝŽŶƐĞĐƚŝŽŶŝŶĚŝĐĂƚĞƐƚŚĂƚŵĂŶLJŽĨƚŚĞŵŝƚŝŐĂƚŝŽŶƐŽĐĐƵƌƉƌŝŽƌƚŽƌĞĐŽƌĚĂƚŝŽŶŽĨƚŚĞĨŝŶĂůǀĞƐƚŝŶŐŵĂƉ͘dŚĞƐĞŵŝƚŝŐĂƚŝŽŶƐƐŚŽƵůĚďĞƌĞʹǁƌŝƚƚĞŶƚŽŝŶĚŝĐĂƚĞƌĞƋƵŝƌĞŵĞŶƚƐƉƌŝŽƌƚŽƌĞͲƐƵďĚŝǀŝƐŝŽŶŽĨƚŚĞDĂĚŽŶŶĂ&ƌŽŽŵZĂŶĐŚƌĞƐŝĚĞŶƚŝĂůƉĂƌĐĞů͘ůůƚƌĂŶƐƉŽƌƚĂƚŝŽŶŵŝƚŝŐĂƚŝŽŶƐƐŚŽƵůĚďĞƚŝĞĚƚŽŽĐĐƵƉĂŶĐLJŽƌďƵŝůĚŝŶŐƉĞƌŵŝƚŝƐƐƵĂŶĐĞ͘DŝƚŝŐĂƚŝŽŶƐƐŚŽƵůĚďĞŝĚĞŶƚŝĨŝĞĚĐůĞĂƌůLJĨŽƌ͞ĨĂŝƌƐŚĂƌĞ͕͟d/&ŽƌŝŵƉůĞŵĞŶƚĂƚŝŽŶƐŽƚŚĂƚƚŚĞĂƉƉůŝĐĂŶƚĐĂŶĐůĞĂƌůLJŝĚĞŶƚŝĨLJǁŚĂƚŝƐďĞŝŶŐĐŽŶƐƚƌƵĐƚĞĚďLJƚŚĞƉƌŽũĞĐƚ͘Ϯ WĂŐĞϯ͘ϭϯͲϳϰDDdZE^ͲϭKŶŐŽŝŶŐZĞƋƵŝƌĞŵĞŶƚƐƚŚƌŽƵŐŚŽƵƚƚŚĞƵƌĂƚŝŽŶŽĨŽŶƐƚƌƵĐƚŝŽŶZĞǀŝƐĞdDWƌĞƋƵŝƌĞŵĞŶƚƐ͕ƐĞĐŽŶĚďƵůůĞƚ͖Η,ĞĂǀLJŚĂƵůĐŽŶƐƚƌƵĐƚŝŽŶǀĞŚŝĐůĞƐ͙ƐŚĂůůŶŽƚƉĂƐƐ͙͟ZĞǀŝƐĞƚĞdžƚƚŽ͖,ĞĂǀLJŚĂƵůĐŽŶƐƚƌƵĐƚŝŽŶǀĞŚŝĐůĞƌŽƵƚŝŶŐƐŚĂůů͕ǁŚĞŶĞǀĞƌƉŽƐƐŝďůĞ͕ďĞŵŝŶŝŵŝnjĞĚĂŶĚƌŽƵƚĞĚĂǁĂLJĨƌŽŵŽĐĐƵƉŝĞĚďƵŝůĚŝŶŐƐ͘ϯ WĂŐĞϯ͘ϭϯͲϴϮDDdZE^ͲϮĞƐŝŐŶĂŶĚĐŽŶƐƚƌƵĐƚƚŚĞĞdžƚĞŶƐŝŽŶŽĨƚŚĞǁĞƐƚďŽƵŶĚůĞĨƚͲƚƵƌŶƉŽĐŬĞƚĂƚƚŚĞ>KsZͬh͘^͘ϭϬϭƐŽƵƚŚďŽƵŶĚƌĂŵƉƐŝŶƚĞƌƐĞĐƚŝŽŶƚŽƉƌŽǀŝĚĞĂƐƚŽƌĂŐĞůĞŶŐƚŚŽĨϯϮϬĨĞĞƚ͕ĂŶĚĚĞƐŝŐŶĂŶĚĐŽŶƐƚƌƵĐƚƚŚĞĞdžƚĞŶƐŝŽŶŽĨƚŚĞƐŽƵƚŚďŽƵŶĚƌŝŐŚƚͲƚƵƌŶƉŽĐŬĞƚĂƚƚŚĞ>KsZͬh͘^͘ϭϬϭ^ĂŶ>ƵŝƐZĂŶĐŚ;^>ZͿŵŝƚŝŐĂƚŝŽŶ;ϭϬϬйͿ ůŝŵŝŶĂƚĞĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘A.1-107A.1-108A.1-1098-219
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 31 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEƐŽƵƚŚďŽƵŶĚƌĂŵƉƐŝŶƚĞƌƐĞĐƚŝŽŶƚŽƉƌŽǀŝĚĞĂƐƚŽƌĂŐĞůĞŶŐƚŚŽĨϭϰϬĨĞĞƚ͘ϰ WĂŐĞϯ͘ϭϯͲϴϮDDdZE^ͲϯĞƐŝŐŶĂŶĚŝŶƐƚĂůůŵĞĂƐƵƌĞƐƚŽƌĞƐƚƌŝĐƚůĞĨƚƚƵƌŶƐĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬsĂĐŚĞůů>ĂŶĞŝŶƚĞƌƐĞĐƚŝŽŶ͕ĞdžƚĞŶĚƵĐŬůĞLJZŽĂĚĨƌŽŵsĂĐŚĞůů>ĂŶĞƚŽ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚ͕ĂŶĚŝŶƐƚĂůůĂƚƌĂĨĨŝĐƐŝŐŶĂůĂƚƵĐŬůĞLJZŽĂĚͬ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚŝŶƚĞƌƐĞĐƚŝŽŶ͘dŚŝƐŝƐĂŶǀŝůĂZĂŶĐŚ;ZͿŵŝƚŝŐĂƚŝŽŶ͘&Z^WƐŚŽƵůĚďĞĨĂŝƌƐŚĂƌĞŽŶůLJ͘ϱ WĂŐĞϯ͘ϭϯͲϴϯDDdZE^ͲϰĞƐŝŐŶĂŶĚŝŶƐƚĂůůƚŚĞƌĞƐƚƌŝƉŝŶŐŽĨƚŚĞǁĞƐƚďŽƵŶĚĂƉƉƌŽĂĐŚŽĨƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬ^ƵďƵƌďĂŶZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽĞdžƚĞŶĚƚŚĞůĞĨƚͲĂŶĚƌŝŐŚƚͲƚƵƌŶƉŽĐŬĞƚƐƚŽƌĂŐĞƚŽϮϱϬĨĞĞƚ͘dŚŝƐŝƐĂŶǀŝůĂZĂŶĐŚ;ZͿŵŝƚŝŐĂƚŝŽŶ͘dŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϲ WĂŐĞϯ͘ϭϯͲϴϰDDdZE^Ͳϱ džƚĞŶĚƚŚĞǁĞƐƚďŽƵŶĚďŝŬĞůĂŶĞŽŶdĂŶŬ&ĂƌŵZŽĂĚĂƉƉƌŽĂĐŚŝŶŐƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬdĂŶŬ&ĂƌŵZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽƚŚĞŝŶƚĞƌƐĞĐƚŝŽŶĂŶĚŝŶƐƚĂůůĂďŝŬĞďŽdžƚŽĨĂĐŝůŝƚĂƚĞďŝĐLJĐůĞůĞĨƚͲƚƵƌŶŵŽǀĞŵĞŶƚƐ͘dŚŝƐŝƐĂŶǀŝůĂZĂŶĐŚ;ZͿŵŝƚŝŐĂƚŝŽŶ͘dŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϳ WĂŐĞϯ͘ϭϯͲϴϰDDdZE^ͲϲĞƐŝŐŶĂŶĚŝŶƐƚĂůůĂƐĞĐŽŶĚƐŽƵƚŚďŽƵŶĚůĞĨƚƚƵƌŶůĂŶĞĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬdĂŶŬ&ĂƌŵZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶ͘dŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůĂůƐŽƉĂLJĨĂŝƌƐŚĂƌĞĐŽƐƚƐĨŽƌĐŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞWƌĂĚŽZŽĂĚKǀĞƌƉĂƐƐͬ/ŶƚĞƌĐŚĂŶŐĞƉƌŽũĞĐƚ͘^,ŝŐƵĞƌĂDDŝƐǀŝůĂZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ͘&Z^WĨĂŝƌƐŚĂƌĞŽŶŽǀĞƌƉĂƐƐ͘A.1-110A.1-111A.1-112A.1-1138-220
02069
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 32 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEϴ WĂŐĞϯ͘ϭϯͲϴϱDDdZE^ͲϳĞƐŝŐŶĂŶĚŝŶƐƚĂůůĂƐĞĐŽŶĚŶŽƌƚŚďŽƵŶĚůĞĨƚƚƵƌŶůĂŶĞĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬWƌĂĚŽZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶ͕ǁŚŝĐŚƌĞƋƵŝƌĞƐƚŚĞƌĞƉůĂĐĞŵĞŶƚŽĨƚŚĞWƌĂĚŽZŽĂĚƌŝĚŐĞũƵƐƚǁĞƐƚŽĨ^ŽƵƚŚ,ŝŐƵĞƌĂ͘dŚŝƐŝƐ^ĂŶ>ƵŝƐZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ;ϭϬϬйͿ͘dŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϵ WĂŐĞϯ͘ϭϯͲϴϱDDdZE^Ͳϴ/ŶƐƚĂůůůĂƐƐ/sďŝŬĞǁĂLJƐ;ƉƌŽƚĞĐƚĞĚďŝŬĞůĂŶĞƐͿĂůŽŶŐ>KsZƚŽƉƌŽǀŝĚĞĂƉŚLJƐŝĐĂůďƵĨĨĞƌďĞƚǁĞĞŶƚŚĞƐŝĚĞǁĂůŬĂŶĚǀĞŚŝĐƵůĂƌƚƌĂĨĨŝĐůĂŶĞƐ͘/ŵƉƌŽǀĞŵĞŶƚĞdžƚĞŶƚƐƐŚĂůůŽĐĐƵƌŝŶƚŚĞŶŽƌƚŚďŽƵŶĚĚŝƌĞĐƚŝŽŶďĞƚǁĞĞŶ>ĂŐƵŶĂ>ĂŶĞĂŶĚŝĂďůŽƌŝǀĞ͕ĂŶĚŝŶƚŚĞƐŽƵƚŚďŽƵŶĚĚŝƌĞĐƚŝŽŶďĞƚǁĞĞŶŝĂďůŽƌŝǀĞĂŶĚDĂĚŽŶŶĂZŽĂĚ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƚŚĞƉƌŽũĞĐƚ͖ƉƌŽũĞĐƚĂĚĚƐϬ͘ϲďŝŬĞ͕ϭ͘ϱƉĞĚƚƌŝƉ͘&ĂŝƌƐŚĂƌĞŽŬĂLJ͘ϭϬ WĂŐĞϯ͘ϭϯͲϴϲDDdZE^ͲϵĞƐŝŐŶĂŶĚŝŶƐƚĂůůͲĐŽŵƉůŝĂŶƚĐƵƌď͕ŐƵƚƚĞƌĂŶĚƐŝĚĞǁĂůŬĂůŽŶŐƚŚĞǁĞƐƚƐŝĚĞŽĨ>KsZƚŽĐŽŵƉůĞƚĞƚŚĞƐŝĚĞǁĂůŬĐŽŶŶĞĐƚŝŽŶďĞƚǁĞĞŶƚŚĞ/ƌŝƐŚ,ŝůůƐWůĂnjĂĂŶĚĂůůĞ:ŽĂƋƵŝŶ͘dŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůĂůƐŽĚĞƐŝŐŶĂŶĚŝŶƐƚĂůůůĂƐƐ/sďŝŬĞǁĂLJƐ;ƉƌŽƚĞĐƚĞĚďŝŬĞůĂŶĞƐͿĂůŽŶŐ>KsZƚŽƉƌŽǀŝĚĞĂƉŚLJƐŝĐĂůďƵĨĨĞƌďĞƚǁĞĞŶƚŚĞƐŝĚĞǁĂůŬĂŶĚǀĞŚŝĐƵůĂƌƚƌĂĨĨŝĐůĂŶĞƐŝŶƚŚĞŶŽƌƚŚďŽƵŶĚĂŶĚƐŽƵƚŚďŽƵŶĚĚŝƌĞĐƚŝŽŶƐďĞƚǁĞĞŶDĂĚŽŶŶĂZŽĂĚĂŶĚ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚĂůƚƌĂŶƐĐŽŽƌĚŝŶĂƚŝŽŶŝƐƵŶĐůĞĂƌ͕ŝŵƉƌŽǀĞŵĞŶƚƐĂƌĞŽƵƚƐŝĚĞĂůƚƌĂŶƐƌŝŐŚƚŽĨǁĂLJ͘ϭϭ WĂŐĞϯ͘ϭϯͲϴϳdŚŝƐŝƐ^ĂŶ>ƵŝƐZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ͖ƵŶĚĞƌĐŽŶƐƚƌƵĐƚŝŽŶ͘A.1-114A.1-115A.1-116A.1-1178-221
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 33 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEDDdZE^ͲϭϬĞƐŝŐŶĂŶĚŝŶƐƚĂůůĂůĂƐƐ/DƵůƚŝͲhƐĞWĂƚŚƉĂƌĂůůĞůƚŽDĂĚŽŶŶĂZŽĂĚďĞƚǁĞĞŶKĐĞĂŶĂŝƌĞƌŝǀĞĂŶĚƚŚĞh͘^͘ϭϬϭƐŽƵƚŚďŽƵŶĚƌĂŵƉƐŝŶƚĞƌƐĞĐƚŝŽŶ͘DD͕ĚĞůĞƚĞůĂŶŐƵĂŐĞΗĚĞƐŝŐŶĂŶĚŝŶƐƚĂůůΗ͘ϭϮ WĂŐĞϯ͘ϭϯͲϴϳDDdZE^ͲϭϭdŚĞWƌŽũĞĐƚŝƐƌĞƐƉŽŶƐŝďůĞĨŽƌŝŶĐŽƌƉŽƌĂƚŝŶŐƚƌĂĨĨŝĐĐĂůŵŝŶŐŵĞĂƐƵƌĞƐ;Ğ͘Ő͕͘ƐƉĞĞĚŚƵŵƉƐ͕ďƵůďͲŽƵƚƐ͕ĐŚŝĐĂŶĞƐ͕ĞƚĐ͘ͿŝŶƚŽƚŚĞĚĞƐŝŐŶŽĨ>ŽĐĂůZŽĂĚ͟͞ƉƌŝŽƌƚŽĚĞǀĞůŽƉŵĞŶƚŽĨsŝůůĂŐŐŝŽ͛Ɛ>ŽǁĞƌƌĞĂ͘/ŵƉůĞŵĞŶƚĂƚŝŽŶƐŚŽƵůĚƌƵŶƉĂƌĂůůĞůǁŝƚŚŽĐĐƵƉĂŶĐLJ͘ϭϯ WĂŐĞϯ͘ϭϯͲϵϱDDdZE^ͲϭϮdŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůĐŽŽƌĚŝŶĂƚĞĂŶĚĨƵŶĚĂŶLJĐŽƐƚƐƌĞƋƵŝƌĞĚƚŽŽƉƚŝŵŝnjĞƚŚĞƚƌĂĨĨŝĐƐŝŐŶĂůƚŝŵŝŶŐĂƚƚŚĞŽƵŶƚLJŝŶƚĞƌƐĞĐƚŝŽŶŽĨ>KsZͬ&ŽŽƚŚŝůůŽƵůĞǀĂƌĚƚŽƌĞĚƵĐĞƋƵĞƵĞƐĨŽƌƚŚĞƐŽƵƚŚďŽƵŶĚůĞĨƚͲƚƵƌŶŵŽǀĞŵĞŶƚ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐ͕ƉƌŽũĞĐƚĂĚĚƐϲƚƌŝƉƐ͘ϭϰ WĂŐĞϯ͘ϭϯͲϵϱDDdZE^ͲϭϯWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůĨƵŶĚĂŶLJĐŽƐƚƐƌĞƋƵŝƌĞĚƚŽŝŵƉůĞŵĞŶƚ>ĞĂĚWĞĚĞƐƚƌŝĂŶ/ŶƚĞƌǀĂůƐĨŽƌĞĂĐŚƉĞĚĞƐƚƌŝĂŶĐƌŽƐƐŝŶŐƉŚĂƐĞĂƚƚŚĞ>KsZͬDĂĚŽŶŶĂZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶ͘WƌŽũĞĐƚĂĚĚƐĂƉƉƌŽdž͘ϭƉĞĚĞƐƚƌŝĂŶƚƌŝƉ͘ϭϱ WĂŐĞϯ͘ϭϯͲϵϱDDdZE^ͲϭϰWĂLJĨĂŝƌƐŚĂƌĞĐŽƐƚƐĨŽƌĐŽŶƐƚƌƵĐƚŝŽŶŽĨƚŚĞWƌĂĚŽZŽĂĚKǀĞƌƉĂƐƐͬ/ŶƚĞƌĐŚĂŶŐĞƉƌŽũĞĐƚĂŶĚŶŽƌƚŚďŽƵŶĚh͘^͘ϭϬϭƌĂŵƉƐƚŚƌŽƵŐŚƉĂƌƚŝĐŝƉĂƚŝŽŶŝŶƚŚĞŝƚLJǁŝĚĞdƌĂŶƐƉŽƌƚĂƚŝŽŶ/ŵƉĂĐƚ&ĞĞƉƌŽŐƌĂŵ͘&ĂŝƌƐŚĂƌĞƚŚƌƵd/&ƉƌŽŐƌĂŵŽŬĂLJ͘A.1-117cont.A.1-118A.1-119A.1-120A.1-1218-222
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 34 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEϭϲ WĂŐĞϯ͘ϭϯͲϵϲDDdZE^Ͳϭϱ&ƵŶĚĂŶLJĐŽƐƚƐƌĞƋƵŝƌĞĚƚŽŝŵƉůĞŵĞŶƚ>ĞĂĚWĞĚĞƐƚƌŝĂŶ/ŶƚĞƌǀĂůƐĨŽƌĞĂĐŚƉĞĚĞƐƚƌŝĂŶĐƌŽƐƐŝŶŐƉŚĂƐĞĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬdĂŶŬ&ĂƌŵZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶ͘EŽŶĞdžƵƐĨŽƌƉƌŽũĞĐƚ͘&Z^WƐŚŽƵůĚŽŶůLJďĞƌĞƋƵŝƌĞĚƚŽƉƌŽǀŝĚĞƉƌŽͲƌĂƚĞĚĨĂŝƌƐŚĂƌĞƉĞƌƉƌŽũĞĐƚŽĐĐƵƉĂŶĐLJ͘ϭϳ WĂŐĞϯ͘ϭϯͲϵϲDDdZE^ͲϭϲĞƐŝŐŶĂŶĚŝŶƐƚĂůůŝŵƉƌŽǀĞŵĞŶƚƐƚŽĞdžƚĞŶĚƚŚĞŶŽƌƚŚďŽƵŶĚƌŝŐŚƚͲƚƵƌŶƉŽĐŬĞƚƐƚŽƌĂŐĞĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬdĂŶŬ&ĂƌŵZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽϮϯϬĨĞĞƚ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƉƌŽũĞĐƚ͖ƚŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϭϴ WĂŐĞϯ͘ϭϯͲϵϳDDdZE^ͲϭϳĞƐŝŐŶĂŶĚŝŶƐƚĂůůƌĞƐƚƌŝƉŝŶŐŵŽĚŝĨŝĐĂƚŝŽŶƐĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬWƌĂĚŽZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽĂĐĐŽŵŵŽĚĂƚĞĂƐĞĐŽŶĚƐŽƵƚŚďŽƵŶĚůĞĨƚͲƚƵƌŶůĂŶĞĂŶĚƐĞĐŽŶĚĞĂƐƚďŽƵŶĚƚŚƌŽƵŐŚůĂŶĞdŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƚŚĞƉƌŽũĞĐƚ;ϬƚƌŝƉƐͿ͖ƚŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϭϵ WĂŐĞϯ͘ϭϯͲϵϴDDdZE^Ͳϭϴ&ƵŶĚĂŶLJĐŽƐƚƐƌĞƋƵŝƌĞĚƚŽŽƉƚŝŵŝnjĞƚƌĂĨĨŝĐƐŝŐŶĂůƚŝŵŝŶŐƐĂƚƚŚƌĞĞŝŶƚĞƌƐĞĐƚŝŽŶƐĂůŽŶŐ>KsZďĞƚǁĞĞŶĂůůĞ:ŽĂƋƵŝŶĂŶĚƚŚĞh͘^͘ϭϬϭŶŽƌƚŚďŽƵŶĚƌĂŵƉƐƚŽŝŵƉƌŽǀĞƚƌĂĨĨŝĐĐŽŽƌĚŝŶĂƚŝŽŶĂŶĚŽƉĞƌĂƚŝŽŶƐĂůŽŶŐƚŚŝƐƌŽĂĚǁĂLJƐĞŐŵĞŶƚ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƚŚĞƉƌŽũĞĐƚͲĂƉƉƌŽdžŝŵĂƚĞůLJϮϳŽĨϯϭ͕ϬϬϬƚƌŝƉƐ͖ĞůŝŵŝŶĂƚĞĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϮϬ WĂŐĞϯ͘ϭϯͲϵϴDDdZE^ͲϭϵĞƐŝŐŶĂŶĚŝŶƐƚĂůůƌĞƐƚƌŝƉŝŶŐŵŽĚŝĨŝĐĂƚŝŽŶƐĂƚƚŚĞ>KsZͬDĂĚŽŶŶĂZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽŝŶĐƌĞĂƐĞƚƵƌŶƉŽĐŬĞƚƐƚŽƌĂŐĞƚŽϯϲϱĨĞĞƚĂŶĚdŚŝƐŝƐ^ĂŶ>ƵŝƐZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ;ϭϬϬйͿ͖ƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘A.1-122A.1-123A.1-124A.1-125A.1-1268-223
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 35 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEŽƉƚŝŵŝnjĞƐŝŐŶĂůƚŝŵŝŶŐƐƚŽŝŵƉƌŽǀĞŽƉĞƌĂƚŝŽŶƐĂŶĚƌĞĚƵĐĞƋƵĞƵŝŶŐĂƚƚŚĞ^ůĞĨƚͲƚƵƌŶůĂŶĞ͘Ϯϭ WĂŐĞϯ͘ϭϯͲϵϵDDdZE^ͲϮϬDŽĚŝĨLJƚŚĞƚƌĂĨĨŝĐƐŝŐŶĂůĂƚƚŚĞDĂĚŽŶŶĂZŽĂĚͬĂůŝĚŝŽƌŝǀĞŝŶƚĞƌƐĞĐƚŝŽŶƚŽƉƌŽǀŝĚĞ ƌŝŐŚƚͲƚƵƌŶŽǀĞƌůĂƉƉŚĂƐĞĐŽŶĐƵƌƌĞŶƚǁŝƚŚEůĞĨƚͲƚƵƌŶƉŚĂƐĞ͘dŚŝƐŝƐ^ĂŶ>ƵŝƐZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ;ϭϬϬйͿ͖ƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϮϮ WĂŐĞϯ͘ϭϯͲϭϬϰDDdZE^ͲϮϭ/ŶĐůƵĚĞĂůĂŶĚƐĐĂƉĞĚŵĞĚŝĂŶĂůŽŶŐ>KsZĨƌŽŵƚŚĞƚĞƌŵŝŶƵƐŽĨƚŚĞĞdžŝƐƚŝŶŐŵĞĚŝĂŶĂƚŶŽƌƚŚĞƌŶWƌŽũĞĐƚĨƌŽŶƚĂŐĞƚŽĂůůĞ:ŽĂƋƵŝŶ͘WƌŽũĞĐƚĨƌŽŶƚĂŐĞŝŵƉƌŽǀĞŵĞŶƚƚŽďĞƐŚŽǁŶŝŶĨŝŶĂů&Z^W͘Ϯϯ WĂŐĞϯ͘ϭϯͲϭϬϱDDdZE^ͲϮϮdŚĞWƌŽũĞĐƚƐŚĂůůŝŶĐůƵĚĞĂŶĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐƉŽŝŶƚĨƌŽŵsŝůůĂŐŐŝŽ͛Ɛ>ŽǁĞƌƌĞĂƚŽƚŚĞ/ƌŝƐŚ,ŝůůƐEĂƚƵƌĂůZĞƐĞƌǀĞƚŽƉƌŽǀŝĚĞĂĐĐĞƐƐƚŽƚŚĞĞdžŝƐƚŝŶŐĚŝƌƚƌŽĂĚŶĞƚǁŽƌŬƚŽĨŝŐŚƚĨŝƌĞƐŝŶ/ƌŝƐŚ,ŝůůƐ͕ƐƉĞĐŝĨŝĐĂůůLJƚŽEĞŝů,ĂǀůŝŬtĂLJǁŚŝĐŚĐŽŶŶĞĐƚƐƚŽƚŚĞĨŽƵƌƵƚŝůŝƚLJƉŽǁĞƌůŝŶĞƐƚƌƵĐƚƵƌĞƐĂƚƚŚĞƚŽƉŽĨƚŚĞƌŝĚŐĞůŝŶĞ͘dŚŝƐĂĐĐĞƐƐƉŽŝŶƚŵĂLJďĞŐĂƚĞĚƚŽĞŶƐƵƌĞƐŝƚĞƐĞĐƵƌŝƚLJŝŶĐŽŶƐƵůƚĂƚŝŽŶǁŝƚŚ^>K&͘ /ZƐŚŽƵůĚŝŶĚŝĐĂƚĞ s͛ƐĂƚd:DyyůŽĐĂƚŝŽŶ͕ƵƚŽWĂƌŬtĂLJ͕ĂŶĚĂƚŚŝƌĚĂĐĐĞƐƐƉŽŝŶƚĨƌŽŵsŝůůĂŐŐŝŽƚŽ>KsZ͕ƉĞƌŵĞĞƚŝŶŐǁŝƚŚŝƚLJƐƚĂĨĨĂŶĚ&ŝƌĞDĂƌƐŚĂůʹZŽĚŐĞƌDĂŐŐŝŽ͕ĞĐĞŵďĞƌϭϳƚŚ͕ϮϬϭϵ͘A.1-126cont.A.1-127A.1-128A.1-1298-224
02073
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 36 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEϮϲ WĂŐĞϯ͘ϭϯͲϭϬϱDDdZE^ͲϮϯdŚĞWƌŽũĞĐƚƐŚĂůůŝŶƚĞŐƌĂƚĞĂĐĐĞƐƐƚŽƚŚĞWƌŽũĞĐƚƐŝƚĞƉĞƌŝŵĞƚĞƌƐĨŽƌĚĞĨĞŶĚŝŶŐƚŚĞWƌŽũĞĐƚƐŝƚĞĚĞǀĞůŽƉŵĞŶƚ͘^ƉĞĐŝĨŝĐĂůůLJ͕ƚŚĞƐĞŵĞĂƐƵƌĞƐƐŚŽƵůĚĂĚĚƌĞƐƐĂĐĐĞƐƐƚŽƚŚĞǁŝůĚůĂŶĚĂƌĞĂŝŵŵĞĚŝĂƚĞůLJĂďƵƚƚŝŶŐƚŚĞǁĞƐƚĞƌŶďŽƵŶĚĂƌLJŽĨsŝůůĂŐŐŝŽ͛Ɛ>ŽǁĞƌƌĞĂ͘dŚŝƐŵĞĂƐƵƌĞƐŚĂůůŝŶĐůƵĚĞĂĐĐĞƐƐĨƌŽŵƚŚĞƉƌŽƉŽƐĞĚ>ŽĐĂůZŽĂĚ͟͞ƚŽƚŚĞ/ƌŝƐŚ,ŝůůƐ͕ǁŚŝĐŚŵĂLJŝŶĐůƵĚĞƵƐĞŽĨƐƉĂĐĞďĞƚǁĞĞŶƉƌŽƉŽƐĞĚďƵŝůĚŝŶŐƐĨŽƌĨŝƌĞĨŝŐŚƚŝŶŐǀĞŚŝĐůĞĂĐĐĞƐƐ͕ƌĂŵƉƐƵƉƉƌŽƉŽƐĞĚƌĞƚĂŝŶŝŶŐǁĂůůƐ͕ĂŶĚƐŝŵŝůĂƌǀĞŚŝĐůĞŝŶĨƌĂƐƚƌƵĐƚƵƌĞƚŽŵĂŝŶƚĂŝŶĂĐĐĞƐƐƚŽƚŚĞďĂƐĞŽĨƚŚĞ/ƌŝƐŚ,ŝůůƐ͘ /ZƐŚŽƵůĚŝŶĚŝĐĂƚĞ&ŝƌĞĞƉĂƌƚŵĞŶƚĂĐĐĞƐƐĨƌŽŵsŝůůĂŐŐŝŽůŽǁĞƌĂƌĞĂŝƐƚŽŽĐĐƵƌĂƚƚŚĞŝŶƚĞƌƐĞĐƚŝŽŶŽĨ͚͛^ƚƌĞĞƚĂĐĐĞƐƐƚŽƚŚĞsŝůůĂŐŐŝŽǀŝůůĂƐ͘ĐĐĞƐƐĨƌŽŵ&ƌŽŽŵZĂŶĐŚĚĞǀĞůŽƉŵĞŶƚĂƌĞĂǁŝůůŽĐĐƵƌĂƚĂůŽĐĂƚŝŽŶŶĞĂƌƚŚĞŶŽƌƚŚǁĞƐƚĐŽƌŶĞƌ͕ƉĞƌŵĞĞƚŝŶŐǁŝƚŚŝƚLJƐƚĂĨĨĂŶĚ&ŝƌĞDĂƌƐŚĂůʹZŽĚŐĞƌDĂŐŐŝŽ͕ĞĐĞŵďĞƌϭϳƚŚ͕ϮϬϭϵ͘Ϯϳ WĂŐĞϯ͘ϭϯͲϭϬϳDDdZE^ͲϮϰDŽĚŝĨŝĐĂƚŝŽŶƐƚŽƉƌĞůŝŵŝŶĂƌLJĐŽŶĐĞƉƚĚĞƐŝŐŶƐƚŽĂĚĚƌĞƐƐƉĞĚĂŶĚďŝŬĞĐŝƌĐƵůĂƚŝŽŶƐĂĨĞƚLJŝƐƐƵĞƐ͘/ŵƉƌŽǀĞŵĞŶƚƐĂƉƉĞĂƌƚŽďĞĐŽŶƐƚƌƵĐƚŝŽŶĚŽĐƵŵĞŶƚůĞǀĞů͘&Z^WƵƉĚĂƚĞƐŵĂLJďĞŝŵƉƌĂĐƚŝĐĂů͘Ϯϴ WĂŐĞϯ͘ϭϯͲϭϭϯDDdZE^ͲϮϱƚŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůƉĂLJŝƚƐĨĂŝƌƐŚĂƌĞĨĞĞƐƚŽĨƵŶĚŵŽĚŝĨŝĐĂƚŝŽŶƐƚŽƚŚĞŶŽƌƚŚďŽƵŶĚĂƉƉƌŽĂĐŚĂƚƚŚĞ>KsZͬ&ŽŽƚŚŝůůŽƵůĞǀĂƌĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽƉƌŽǀŝĚĞŽŶĞůĞĨƚͲƚƵƌŶ͕ƚǁŽƚŚƌŽƵŐŚ͕ĂŶĚŽŶĞƌŝŐŚƚͲƚƵƌŶůĂŶĞ͕ŽƌƐŝŵŝůĂƌŽƉĞƌĂƚŝŽŶĂůŝŵƉƌŽǀĞŵĞŶƚƐƚŽƚŚĞƐĂƚŝƐĨĂĐƚŝŽŶŽĨƚŚĞŽƵŶƚLJWƵďůŝĐtŽƌŬƐŝƌĞĐƚŽƌ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƚŚŝƐŵŝƚŝŐĂƚŝŽŶ͖ƌĞƋƵŝƌĞƐƉůĂŶƐĂŶĚĞƐƚŝŵĂƚĞĨŽƌŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘dŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘Ϯϵ WĂŐĞϯ͘ϭϯͲϭϭϰDDdZE^ͲϮϲƉĂLJŝƚƐĨĂŝƌƐŚĂƌĞĨĞĞƐƚŽĨƵŶĚƐƚƌŝƉŝŶŐdŚĞƌĞŝƐŶŽŶĞdžƵƐĨŽƌƚŚŝƐŵŝƚŝŐĂƚŝŽŶ͖ƌĞƋƵŝƌĞƐƉůĂŶƐĂŶĚĞƐƚŝŵĂƚĞĨŽƌŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘dŚŝƐƐŚŽƵůĚďĞĞůŝŵŝŶĂƚĞĚĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘A.1-130A.1-131A.1-132A.1-1338-225
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 37 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEŵŽĚŝĨŝĐĂƚŝŽŶƐƚŽĞdžƚĞŶĚƚŚĞŶŽƌƚŚďŽƵŶĚůĞĨƚͲƚƵƌŶƉŽĐŬĞƚĂƚƚŚĞ>KsZͬZŽLJĂůtĂLJŝŶƚĞƌƐĞĐƚŝŽŶƚŽϭϱϬĨĞĞƚ͕ĂŶĚƚŽŽƉƚŝŵŝnjĞƚŚĞƚƌĂĨĨŝĐƐŝŐŶĂůƚŝŵŝŶŐƐĂůŽŶŐƚŚĞ>KsZĐŽƌƌŝĚŽƌďĞƚǁĞĞŶĞƐĐĂŶƐŽ^ƚƌĞĞƚĂŶĚ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚ͘ϯϬ WĂŐĞϯ͘ϭϯͲϭϭϰDDdZE^ͲϮϳdŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůƉĂLJŝƚƐĨĂŝƌƐŚĂƌĞĨĞĞƐƚŽĨƵŶĚƚŚĞŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨ>ĞĂĚWĞĚĞƐƚƌŝĂŶ/ŶƚĞƌǀĂůƐĨŽƌĞĂĐŚƉĞĚĞƐƚƌŝĂŶĐƌŽƐƐŝŶŐƉŚĂƐĞĂƚƚŚĞ>KsZͬĂůůĞ:ŽĂƋƵŝŶŝŶƚĞƌƐĞĐƚŝŽŶ͘&ĂŝƌƐŚĂƌĞĂƚŽĐĐƵƉĂŶĐLJ͘ϯϭ WĂŐĞϯ͘ϭϯͲϭϭϰDDdZE^ͲϮϴdŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůƉĂLJŝƚƐĨĂŝƌƐŚĂƌĞĨĞĞƐƚŽĨƵŶĚƚŚĞĞdžƚĞŶƐŝŽŶŽĨƚŚĞƐŽƵƚŚďŽƵŶĚůĞĨƚͲƚƵƌŶƉŽĐŬĞƚƐƚŽƌĂŐĞĂƚƚŚĞ^ŽƵƚŚ,ŝŐƵĞƌĂ^ƚƌĞĞƚͬdĂŶŬ&ĂƌŵZŽĂĚŝŶƚĞƌƐĞĐƚŝŽŶƚŽϯϬϬĨĞĞƚ͘dŚĞƌĞŶŽŶĞdžƵƐ͖ĞůŝŵŝŶĂƚĞĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘ϯϮ WĂŐĞϯ͘ϭϯͲϭϭϱDDdZE^ͲϮϵdŚĞWƌŽũĞĐƚƉƉůŝĐĂŶƚƐŚĂůůƉĂLJŝƚƐĨĂŝƌƐŚĂƌĞĨĞĞƚŽƚŚĞŝƚLJƚŽĨƵŶĚƚŚĞĞdžƚĞŶƐŝŽŶŽĨƚŚĞǁĞƐƚďŽƵŶĚƌŝŐŚƚͲƚƵƌŶƉŽĐŬĞƚƐƚŽƌĂŐĞĂƚƚŚĞDĂĚŽŶŶĂZŽĂĚͬKĐĞĂŶĂŝƌĞƌŝǀĞŝŶƚĞƌƐĞĐƚŝŽŶƚŽϮϬϬĨĞĞƚ͘dŚĞƌĞŝƐŶŽŶĞdžƵƐ͖ĞůŝŵŝŶĂƚĞĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐŵƚƐ͘;ϬƚƌŝƉƐͿϯϮ WĂŐĞϯ͘ϭϯͲϭϭϱDDdZE^ͲϯϬŽŽƌĚŝŶĂƚĞĂŶĚĨƵŶĚƚŚĞŝƚLJƚŽŵŽĚŝĨLJƚŚĞƚƌĂĨĨŝĐƐŝŐŶĂůƉŚĂƐŝŶŐĂŶĚƚŝŵŝŶŐƉůĂŶƐĂƚƚŚĞDĂĚŽŶŶĂZŽĂĚͬĂůŝĚŝŽƌŝǀĞŝŶƚĞƌƐĞĐƚŝŽŶƚŽdŚŝƐƐŚŽƵůĚďĞĂ^ĂŶ>ƵŝƐZĂŶĐŚŵŝƚŝŐĂƚŝŽŶ;ϭϬϬйͿ͖ĞůŝŵŝŶĂƚĞĨƌŽŵ&Z^WƌĞƋƵŝƌĞŵĞŶƚƐ͘A.1-133cont.A.1-134A.1-135A.1-136A.1-1378-226
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 38 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEƉƌŽǀŝĚĞĂŶĞĂƐƚďŽƵŶĚƌŝŐŚƚͲƚƵƌŶŽǀĞƌůĂƉƉŚĂƐĞĐŽŶĐƵƌƌĞŶƚǁŝƚŚƚŚĞŶŽƌƚŚďŽƵŶĚůĞĨƚͲƚƵƌŶƉŚĂƐĞ͘A.1-137cont.8-227
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 39 &ZKKDZE, /Z EdZ>K^ddZE^WKZdd/KEKE^h>d/E'Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϯdƌĂŶƐƉŽƌƚĂƚŝŽŶϭ WĂŐĞϯ͘ϭϯͲϲϴͬsĞŚŝĐůĞDŝůĞƐdƌĂǀĞůĞĚͬdĂďůĞϯ͘ϭϯͲϯϭdŚĞdƌĂŶƐƉŽƌƚĂƚŝŽŶ͕ ŶĞƌŐLJ͕ĂŶĚŝƌYƵĂůŝƚLJƐĞĐƚŝŽŶƐŽĨƚŚĞ /ZĐŽŶƚĂŝŶŝŶĐŽŶƐŝƐƚĞŶƚsDdĞƐƚŝŵĂƚĞƐĚĞƌŝǀĞĚĨƌŽŵĚŝĨĨĞƌĞŶƚƐŽƵƌĐĞƐ͘dŚĞdƌĂŶƐƉŽƌƚĂƚŝŽŶƐĞĐƚŝŽŶƌĞůŝĞƐŽŶƚŚĞŝƚLJ͛ƐdƌĂǀĞůĞŵĂŶĚDŽĚĞů;dDͿƚŽĞƐƚŝŵĂƚĞƚŚĞƉƌŽũĞĐƚ͛ƐsDdďƵƚĂƉƉĞĂƌƐƚŽŝŶĐůƵĚĞďŽƚŚƌĞƐŝĚĞŶƚŝĂůĂŶĚŶŽŶͲƌĞƐŝĚĞŶƚŝĂůƵƐĞƐ͘dŚŝƐŝƐŝŶĐŽŶƐŝƐƚĞŶƚǁŝƚŚKWZŐƵŝĚĂŶĐĞĂŶĚŽǀĞƌƐƚĂƚĞƐƚŚĞsDdƉĞƌŚŽƵƐĞŚŽůĚĐĂůĐƵůĂƚŝŽŶ͕ǁŚŝĐŚƐŚŽƵůĚŽŶůLJŝŶĐůƵĚĞƚŚĞsDdŐĞŶĞƌĂƚĞĚďLJƌĞƐŝĚĞŶƚŝĂůƵƐĞƐ͘/ŶĂĚĚŝƚŝŽŶ͕ƚŚĞ^K/ĂŶĚZĞŐŝŽŶĂůsDdĞƐƚŝŵĂƚĞƐŝŶdĂďůĞϯ͘ϭͲϭϬϮŽĨƚŚĞƉƉĞŶĚŝdž:d/^ƌĞĨĞƌĞŶĐĞĂϮϬϭϲĞŶƚƌĂůŽĂƐƚdƌĂŶƐƉŽƌƚĂƚŝŽŶŽŶƐƵůƚŝŶŐƌĞƉŽƌƚ͕ĂƉƉĂƌĞŶƚůLJƚŚĞǀŝůĂZĂŶĐŚd/^͘dŚŝƐƐƚƵĚLJƵƐĞĚĂƐŬĞƚĐŚƉůĂŶŶŝŶŐƚŽŽůƚŽĞƐƚŝŵĂƚĞsDd͕ŶŽƚƚŚĞŝƚLJdƌĂǀĞůĞŵĂŶĚDŽĚĞů͘KWZŐƵŝĚĂŶĐĞĂŶĚŝŶĚƵƐƚƌLJƐƚĂŶĚĂƌĚƉƌĂĐƚŝĐĞƌĞƋƵŝƌĞƵƐĞŽĨƚŚĞƐĂŵĞƚŽŽůƚŽĞƐƚŝŵĂƚĞƉƌŽũĞĐƚsDdĂƐǁĞůůĂƐŝƚLJǁŝĚĞĂŶĚZĞŐŝŽŶĂůsDdƚŽĞŶĂďůĞĂŶ͚ĂƉƉůĞƐƚŽĂƉƉůĞƐ͛ĐŽŵƉĂƌŝƐŽŶ͘&ŝŶĂůůLJ͕ĐĂůĐƵůĂƚŝŽŶƐĚĞǀĞůŽƉĞĚƵƐŝŶŐƚŚĞŝƚLJdDƐŚŽƵůĚĚĞƐĐƌŝďĞǁŚĂƚĂĚũƵƐƚŵĞŶƚƐǁĞƌĞŵĂĚĞƚŽƌĞĨůĞĐƚƚŚĞůŝŬĞůLJĚĞŵŽŐƌĂƉŚŝĐƐĂŶĚƚƌĂǀĞůƉĂƚƚĞƌŶƐŽĨƉƌŽũĞĐƚƌĞƐŝĚĞŶƚƐ͘dŚĞdDĚŽĞƐŶŽƚŝŶĐůƵĚĞĂŶLJůĂŶĚƵƐĞƐĚŝƌĞĐƚůLJĂŶĂůŽŐŽƵƐƚŽƐĞŶŝŽƌŚŽƵƐŝŶŐĂŶĚƚLJƉŝĐĂůŵƵůƚŝͲĨĂŵŝůLJŚŽƵƐŝŶŐ;ƚŚĞĐůŽƐĞƐƚůĂŶĚƵƐĞŝŶƚŚĞdDͿŐĞŶĞƌĂƚĞƐŵŽƌĞƚƌŝƉƐƚŚĂŶƐĞŶŝŽƌŚŽƵƐŝŶŐ͘dŚĞsDdĞƐƚŝŵĂƚĞŝƐƵƐĞĚĚŝƌĞĐƚůLJŝŶƚŚĞŝƌYƵĂůŝƚLJĂŶĚhƚŝůŝƚŝĞƐĂŶĚ ŶĞƌŐLJŽŶƐĞƌǀĂƚŝŽŶƐĞĐƚŝŽŶƐŽĨƚŚĞ /ZĂŶĚƐŚŽƵůĚďĞĐŽƌƌĞĐƚĞĚƚŽŵŽƌĞĂĐĐƵƌĂƚĞůLJƌĞĨůĞĐƚƚŚĞƉƌŽũĞĐƚ͕ŝŶĐůƵĚŝŶŐĨĞĂƚƵƌĞƐůŝŬĞƉƌŽdžŝŵŝƚLJƚŽƚƌĂǀĞů͕ŵŝdžŽĨƵƐĞƐ͕ƉƌŽǀŝƐŝŽŶŽĨƐŚƵƚƚůĞƐ͕ĂŶĚďŝĐLJĐůĞͬƉĞĚĞƐƚƌŝĂŶŝŶĨƌĂƐƚƌƵĐƚƵƌĞƚŚĂƚǁŝůůĂůůƌĞĚƵĐĞsDd͘Ϯ WĂŐĞϯ͘ϯͲϱϳͬ/ŵƉĂĐƚYͲϱdŚĞƉĞƌĐĞŶƚĂŐĞŝŶĐƌĞĂƐĞŝŶsDdĐŝƚĞĚƵŶĚĞƌŚĞĂĚŝŶŐϮͿƌĞůŝĞƐŽŶƚŚĞŝƚLJdDĂŶĚƐŚŽƵůĚďĞĐŽƌƌĞĐƚĞĚĐŽŶƐŝƐƚĞŶƚǁŝƚŚŽŵŵĞŶƚηϭ͘dŚĞŽƉĞƌĂƚŝŽŶĂůŝŵƉĂĐƚƐǁŝůůůŝŬĞůLJďĞƌĞĚƵĐĞĚƵƉŽŶƌĞĐĂůĐƵůĂƚŝŽŶ͘ϯ WĂŐĞϯ͘ϭϰͲϰϭͬKƉĞƌĂƚŝŽŶĂůsĞŚŝĐůĞ&ƵĞůŽŶƐƵŵƉƚŝŽŶͬdĂďůĞϯ͘ϭϰͲϭϯ^ŝŵŝůĂƌƚŽŽŵŵĞŶƚηϭ͕ƚŚĞhƚŝůŝƚŝĞƐĂŶĚ ŶĞƌŐLJŽŶƐĞƌǀĂƚŝŽŶƐĞĐƚŝŽŶŵŝdžĞƐsDdĐĂůĐƵůĂƚŝŽŶŵĞƚŚŽĚŽůŽŐŝĞƐƌĞƐƵůƚŝŶŐŝŶƵŶƌĞĂƐŽŶĂďůĞƌĞƐƵůƚƐ͘dŚĞƐĞĐƚŝŽŶŶŽƚĞƐƚŚĂƚ͞ŽƉĞƌĂƚŝŽŶŽĨƚŚĞWƌŽũĞĐƚŝƐĂŶƚŝĐŝƉĂƚĞĚƚŽƌĞƐƵůƚŝŶƚŚĞŐĞŶĞƌĂƚŝŽŶŽĨĂŶĂĚĚŝƚŝŽŶĂůϰϲ͕ϴϵϰĚĂŝůLJsDd͕ŽƌĂƉƉƌŽdžŝŵĂƚĞůLJϱ͘ϱƉĞƌĐĞŶƚŽĨƚŚĞŝƚLJ͛ƐĞƐƚŝŵĂƚĞĚϴϱϭ͕ϵϯϵA.1-138A.1-139A.1-1408-228
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 40 &ZKKDZE, /Z EdZ>K^ddZE^WKZdd/KEKE^h>d/E'Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEĚĂŝůLJsDdŝŶϮϬϭϰĂŶĚϬ͘ϱƉĞƌĐĞŶƚŽĨƚŚĞŝƚLJ͛ƐĞƐƚŝŵĂƚĞĚϴ͕Ϭϭϲ͕ϱϬϭĚĂŝůLJsDdĨŽƌƚŚĞLJĞĂƌϮϬϯϱ͘͟dŚĞƉƌŽũĞĐƚĞƐƚŝŵĂƚĞŝƐŽďƚĂŝŶĞĚĨƌŽŵƚŚĞŝƚLJdƌĂǀĞůĞŵĂŶĚDŽĚĞů͖ƚŚĞϮϬϭϰŝƚLJĞƐƚŝŵĂƚĞŝƐŽďƚĂŝŶĞĚĨƌŽŵƚŚĞĂůƚƌĂŶƐ,ŝŐŚǁĂLJWĞƌĨŽƌŵĂŶĐĞDŽŶŝƚŽƌŝŶŐ^LJƐƚĞŵĂƐƌĞƉŽƌƚĞĚŝŶƚŚĞŝƚLJŝƌĐƵůĂƚŝŽŶ ůĞŵĞŶƚĂĐŬŐƌŽƵŶĚZĞƉŽƌƚ͖ĂŶĚƚŚĞLJĞĂƌϮϬϯϱĞƐƚŝŵĂƚĞŝƐĐĂůĐƵůĂƚĞĚƵƐŝŶŐƚŚĞ^>KK'dƌĂǀĞůĞŵĂŶĚDŽĚĞů͘dŚĞŶĞĂƌůLJƚĞŶĨŽůĚŐƌŽǁƚŚƐŚŽǁŶĨƌŽŵϮϬϭϰƚŽϮϬϯϱͲĐůĞĂƌůLJŝŶĐŽƌƌĞĐƚĂŶĚĨĂƌŝŶĞdžĐĞƐƐŽĨĂŶƚŝĐŝƉĂƚĞĚůĂŶĚƵƐĞŐƌŽǁƚŚͲŝůůƵƐƚƌĂƚĞƐƚŚĞƉƌŽďůĞŵǁŝƚŚƵƐŝŶŐĚŝĨĨĞƌĞŶƚŵĞƚŚŽĚƐĨŽƌƚŚĞƐĂŵĞŵĞƚƌŝĐ͘dŚĞĐĂůĐƵůĂƚŝŽŶƐƐŚŽƵůĚďĞƌĞǀŝƐĞĚƚŽƵƐĞĂĐŽŶƐŝƐƚĞŶƚsDdĐĂůĐƵůĂƚŝŽŶĂƉƉƌŽĂĐŚŽǀĞƌĂůůLJĞĂƌƐĂŶĚƐĐĞŶĂƌŝŽƐ͘ϰ WĂŐĞϯ͘ϭϯͲϳϭͬ^ƵŵŵĂƌLJŽĨWƌŽũĞĐƚ/ŵƉĂĐƚƐͬdĂďůĞϯ͘ϭϯͲϯϮ/ŵƉĂĐƚdZE^ͲϯƌĞĨĞƌƐƚŽƚŚĞEĞĂƌͲdĞƌŵƐĐĞŶĂƌŝŽ͘dŚŝƐƐĐĞŶĂƌŝŽŝŶĐůƵĚĞƐƚŚŽƵƐĂŶĚƐŽĨŶĞǁƌĞƐŝĚĞŶƚŝĂůƵŶŝƚƐĂŶĚŚƵŶĚƌĞĚƐŽĨƚŚŽƵƐĂŶĚƐŽĨƐƋƵĂƌĞĨĞĞƚŽĨĐŽŵŵĞƌĐŝĂůĚĞǀĞůŽƉŵĞŶƚƐƉƌĞĂĚĂŵŽŶŐϯϴƉƌŽũĞĐƚƐŝŶƚŚĞŝƚLJ͘dŚŝƐŝŵƉĂĐƚƐŚŽƵůĚďĞĐŽŶƐŝĚĞƌĞĚĂĐƵŵƵůĂƚŝǀĞŝŵƉĂĐƚ͕ŶŽƚĂƉƌŽũĞĐƚůĞǀĞůŝŵƉĂĐƚ͕ĂŶĚƚŚĞƚŝŵŝŶŐĂŶĚƌĞƐƉŽŶƐŝďŝůŝƚLJĨŽƌŝŵƉůĞŵĞŶƚĂƚŝŽŶŽĨŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐƐŚŽƵůĚďĞƌĞǀŝƐĞĚĂĐĐŽƌĚŝŶŐůLJ͘>ŝŬĞƚŚĞĐƵŵƵůĂƚŝǀĞŝŵƉĂĐƚƐ͕ƚŚĞƉƌŽũĞĐƚƐŚŽƵůĚďĞĂďůĞƚŽŵĂŬĞĂĨĂŝƌƐŚĂƌĞĐŽŶƚƌŝďƵƚŝŽŶƚŽĂůůƚŚĞŵĞĂƐƵƌĞƐůŝƐƚĞĚŝŶƚŚŝƐƚĂďůĞĂŶĚƐŚŽƵůĚŶŽƚďĞƐŽůĞůLJƌĞƐƉŽŶƐŝďůĞĨŽƌŝŵƉůĞŵĞŶƚĂƚŝŽŶ͘ϱ WĂŐĞϯ͘ϭϯͲϴϮͬDDdZE^ͲϮdŚŝƐŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞĂƉƉůŝĞƐƚŚĞŝƚLJ͛ƐƋƵĞƵŝŶŐƚŚƌĞƐŚŽůĚƚŽĂĂůƚƌĂŶƐĨĂĐŝůŝƚLJ͘ĂůƚƌĂŶƐĚŽĞƐŶŽƚŚĂǀĞĂƋƵĞƵŝŶŐƚŚƌĞƐŚŽůĚĂŶĚƌĞůŝĞƐŽŶ>K^ƚŽŝĚĞŶƚŝĨLJŝŵƉĂĐƚƐ͘dŚĞƌĞĂƌĞŶŽ>K^ŝŵƉĂĐƚƐĂƚƚŚŝƐŝŶƚĞƌƐĞĐƚŝŽŶ͘ϲ WĂŐĞϯ͘ϭϯͲϴϮͬDDdZE^ͲϯdŚĞŝŵƉĂĐƚƚŽ^,ŝŐƵĞƌĂ^ƚƌĞĞƚͬsĂĐŚĞůů>ĂŶĞĐŽƵůĚĂůƐŽďĞŵŝƚŝŐĂƚĞĚďLJŝŶƐƚĂůůĂƚŝŽŶŽĨĂĐĞŶƚĞƌƌĞĨƵŐĞůĂŶĞƚŽĂůůŽǁƚǁŽͲƐƚĂŐĞůĞĨƚƚƵƌŶƐ͘/ŶĂĚĚŝƚŝŽŶ͕ƚŚĞůĞĨƚƚƵƌŶƉƌŽŚŝďŝƚŝŽŶĐŽƵůĚďĞŝŵƉůĞŵĞŶƚĞĚǁŝƚŚĂĐŽŶŶĞĐƚŝŽŶƚŽ^ƵďƵƌďĂŶZŽĂĚǁŚŝĐŚǁŽƵůĚŶŽƚƌĞƋƵŝƌĞƚŚĞƵĐŬůĞLJZŽĂĚĞdžƚĞŶƐŝŽŶ͘dŚĞŵĞĂƐƵƌĞƐŚŽƵůĚďĞƌĞǀŝƐĞĚƚŽƌĞĨůĞĐƚƚŚĞƐĞĂůƚĞƌŶĂƚŝǀĞŵŝƚŝŐĂƚŝŽŶŵĞĂƐƵƌĞƐĂŶĚŶŽƚƉƌĞƐĐƌŝďĞƚŚĞƵĐŬůĞLJZŽĂĚĞdžƚĞŶƐŝŽŶ͕ŽŶůLJƚŚĞĚŝƌĞĐƚŵĞĂƐƵƌĞƐĂƚsĂĐŚĞůů>ĂŶĞ͘ϳ WĂŐĞϯ͘ϭϯͲϴϰͬDDdZE^ͲϲdŚĞƉƌŽũĞĐƚĂĚĚƐůĞƐƐƚŚĂŶЪŽĨĂǀĞŚŝĐůĞůĞŶŐƚŚƚŽƚŚĞƐŽƵƚŚďŽƵŶĚůĞĨƚϵϱƚŚƉĞƌĐĞŶƚŝůĞƋƵĞƵĞĂŶĚĚŽĞƐŶŽƚĂĚĚĂŶLJƚƌĂĨĨŝĐƚŽƚŚŝƐŵŽǀĞŵĞŶƚ͘dŚŝƐŝƐĂŶŝŶƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚ͘/ŶƐƚĂůůŝŶŐĂƐĞĐŽŶĚƐŽƵƚŚďŽƵŶĚůĞĨƚƚƵƌŶůĂŶĞŝƐŝŶƚŚĞŝƚLJ͛Ɛ/ŵƉĂĐƚ&ĞĞƉƌŽŐƌĂŵĂŶĚƚŚĞƉƌŽũĞĐƚ͛ƐŝŵƉĂĐƚĨĞĞƐǁŽƵůĚĐŽŶƚƌŝďƵƚĞƚŽƚŚŝƐŝŵƉƌŽǀĞŵĞŶƚ͘A.1-140cont.A.1-141A.1-142A.1-143A.1-1448-229
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 41 &ZKKDZE, /Z EdZ>K^ddZE^WKZdd/KEKE^h>d/E'Z ^WKE^ ^ͬKDD Ed^ʹϯ͘ϭϯdZE^WKZdd/KEϴ WĂŐĞϯ͘ϭϯͲϴϱͬDDdZE^ͲϳdŚĞƉƌŽũĞĐƚĂĚĚƐůĞƐƐƚŚĂŶŽŶĞǀĞŚŝĐůĞůĞŶŐƚŚƚŽƚŚĞŶŽƌƚŚďŽƵŶĚůĞĨƚϵϱƚŚƉĞƌĐĞŶƚŝůĞƋƵĞƵĞĂŶĚĚŽĞƐŶŽƚĂĚĚĂŶLJƚƌĂĨĨŝĐƚŽƚŚŝƐŵŽǀĞŵĞŶƚ͘dŚŝƐŝƐĂŶŝŶƐŝŐŶŝĨŝĐĂŶƚŝŵƉĂĐƚ͘/ŶƐƚĂůůŝŶŐĂƐĞĐŽŶĚŶŽƌƚŚďŽƵŶĚůĞĨƚƚƵƌŶůĂŶĞŝƐŝŶƚŚĞŝƚLJ͛Ɛ/ŵƉĂĐƚ&ĞĞƉƌŽŐƌĂŵĂŶĚƚŚĞƉƌŽũĞĐƚ͛ƐŝŵƉĂĐƚĨĞĞƐǁŽƵůĚĐŽŶƚƌŝďƵƚĞƚŽƚŚŝƐŝŵƉƌŽǀĞŵĞŶƚ͘dŚŝƐŝŵƉƌŽǀĞŵĞŶƚŝƐĂůƐŽĐŽŶƚŝŶŐĞŶƚŽŶƚŚĞǁŝĚĞŶŝŶŐŽĨƚŚĞďƌŝĚŐĞǁĞƐƚŽĨƚŚĞŝŶƚĞƌƐĞĐƚŝŽŶƚŽƉƌŽǀŝĚĞƚǁŽƌĞĐĞŝǀŝŶŐůĂŶĞƐ͘ϵ ϯ͘ϭϯͲϴϱͬDDdZE^ͲϴdŚĞƉƌŽũĞĐƚŝŶĐƌĞĂƐĞƐƚŚĞƉĞĚĞƐƚƌŝĂŶ>K^ƐĐŽƌĞďLJůĞƐƐƚŚĂŶϬ͘ϬϮďLJŝŶĐƌĞĂƐŝŶŐǀĞŚŝĐůĞǀŽůƵŵĞƐďLJůĞƐƐƚŚĂŶƚǁŽƉĞƌĐĞŶƚ͕ǁŚŝĐŚŝƐŝŶƐŝŐŶŝĨŝĐĂŶƚĂŶĚǁŽƵůĚďĞƵŶŶŽƚŝĐĞĂďůĞƚŽƉĞĚĞƐƚƌŝĂŶƐĂƐŝƚŝƐďĞůŽǁƚŚĞƚLJƉŝĐĂůĚĂLJͲƚŽͲĚĂLJǀĂƌŝĂƚŝŽŶƐŝŶƚƌĂĨĨŝĐĂůŽŶŐƚŚĞĐŽƌƌŝĚŽƌ͘ůƚĞƌŶĂƚŝǀĞƉŚLJƐŝĐĂůďƵĨĨĞƌƐƐƵĐŚĂƐƐƚƌĞĞƚƚƌĞĞƐƉůĂŶƚĞĚĂƐĂďƵĨĨĞƌŝŶƐƚĞĂĚŽĨůĂƐƐ/sďŝŬĞůĂŶĞƐƐŚŽƵůĚďĞĂĚĚĞĚĂƐƚŚĞLJǁŽƵůĚĂůƐŽŝŵƉƌŽǀĞƚŚĞŵŝŶŽƌĚĞŐƌĂĚĂƚŝŽŶŝŶƉĞĚĞƐƚƌŝĂŶ>K^ƐĐŽƌĞ͘A.1-145A.1-1468-230
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 42 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^Ͳϯ͘ϭϰhd/>/d/ ^E E Z'zKE^ Zsd/KEŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϯ͘ϭϰhƚŝůŝƚŝĞƐĂŶĚ ŶĞƌŐLJŽŶƐĞƌǀĂƚŝŽŶϭ dĂďůĞϯ͘ϭϰ͘ϭϬ͕ƉĂŐĞϯ͘ϭϰͲϯϵ͕ĨŽŽƚŶŽƚĞϭ dŚŝƐĂŶĂůLJƐŝƐŝƐŽǀĞƌůLJĐŽŶƐĞƌǀĂƚŝǀĞŝŶŝƚƐĞƐƚŝŵĂƚĞŽĨ^ŽůŝĚtĂƐƚĞƉƌŽĚƵĐƚŝŽŶĨŽƌƐƐŝƐƚĞĚ>ŝǀŝŶŐĂƚsŝůůĂŐŐŝŽ͘sŝůůĂŐŐŝŽŝƐŶŽƚĂŚŽƐƉŝƚĂůĂŶĚĂƐƐƵĐŚĂƐƐŝŐŶŝŶŐĂƉƌŽĚƵĐƚŝŽŶƌĂƚĞĨŽƌĂŚŽƐƉŝƚĂůƚŚĂƚŝƐϯdžǁŚĂƚŝƐĚŝƐĐƵƐƐĞĚĨŽƌĂŶƵƌƐŝŶŐͬƌĞƚŝƌĞŵĞŶƚŚŽŵĞŝƐŽǀĞƌůLJĐŽŶƐĞƌǀĂƚŝǀĞĂŶĚĞdžĐĞƐƐŝǀĞ͘Ϯ WĂŐĞϯ͘ϭϰͲϰϭ͕KƉĞƌĂƚŝŽŶĂůsĞŚŝĐůĞ&ƵĞůŽŶƐƵŵƉƚŝŽŶdŚĞsDdĐĂůĐƵůĂƚŝŽŶĂƉƉĞĂƌƐƚŽďĞĞdžĂŐŐĞƌĂƚĞĚŽƌƚŚĞƐƵďũĞĐƚŽĨĂŶĞƌƌŽƌŝŶĐĂůĐƵůĂƚŝŽŶ͘/ƚĂƉƉĞĂƌƐƵŶƌĞĂƐŽŶĂďůĞƚŚĂƚĂƉƌŽũĞĐƚǁŝƚŚĂƐŝŐŶŝĨŝĐĂŶƚƉŽƉƵůĂƚŝŽŶĐŽŵƉƌŝƐĞĚŽĨƐĞŶŝŽƌĐŝƚŝnjĞŶƐǁŝƚŚĂǀĂŝůĂďůĞƐŚƵƚƚůĞƐĞƌǀŝĐĞƚŽŽĨĨͲƐŝƚĞůŽĐĂƚŝŽŶƐ͕ůŝŵŝƚĞĚĐŽŵŵĞƌĐŝĂůĚĞǀĞůŽƉŵĞŶƚĂŶĚůŝŵŝƚĞĚƚLJƉŝĐĂůƌĞƐŝĚĞŶƚŝĂůƵŶŝƚƐǁŽƵůĚŐĞŶĞƌĂƚĞŚŝŐŚĞƌsDdƚŚĂŶĞdžŝƐƚŝŶŐŝƚLJƌĞƐŝĚĞŶƚƐ͕ŽƵŶƚLJƌĞƐŝĚĞŶƚƐŽƌ^ƚĂƚĞƌĞƐŝĚĞŶƚƐ͘dŚĞĂƉƉĞŶĚŝdžsDdĐĂůĐƵůĂƚŝŽŶƐŽƌƚƌĂĨĨŝĐĐĂůĐƵůĂƚŝŽŶƐĂƉƉĞĂƌƚŽŚĂǀĞĂŶĞƌƌŽƌŝŶƚŚĞƚƌŝƉŐĞŶĞƌĂƚŝŽŶƌĂƚĞƐ͕ůĂŶĚƵƐĞĂƐƐƵŵƉƚŝŽŶƐ;ƌĞŐŝŽŶĂůƐŚŽƉƉŝŶŐĐĞŶƚĞƌ͍ͿĂŶĚŽƌŝĚĞŶƚŝĨŝĐĂƚŝŽŶŽĨĚĞƐƚŝŶĂƚŝŽŶƐ͘ϯ dĂďůĞϯ͘ϭϰͲϭϯ͕WĂŐĞϯ͘ϭϰͲϰϮ͕ĂŝůLJsDdƉĞƌĂƉŝƚĂdŚĞsDdƌĂƚĞƐĚŽŶŽƚƐĞĞŵĐŽƌƌĞĐƚ͘/ƚŵĂŬĞƐŶŽƐĞŶƐĞƚŚĂƚ&Z^WsDdƌĂƚĞƐǁŝůůďĞŽǀĞƌϮdžƚŚĞĞdžŝƐƚŝŶŐŝƚLJĂŝůLJsDdƌĂƚĞǁŚĞŶƚŚĞĚĞŵŽŐƌĂƉŚŝĐĐŽŵƉŽƐŝƚŝŽŶŽĨƚŚĞƉƌŽũĞĐƚƉŽƉƵůĂƚŝŽŶ͕ĂǀĂŝůĂďŝůŝƚLJŽĨŽŶͲƐŝƚĞƐĞƌǀŝĐĞƐĨŽƌsŝůůĂŐŐŝŽƌĞƐŝĚĞŶƚƐ͕ĂǀĂŝůĂďŝůŝƚLJŽĨĂĚũĂĐĞŶƚĐŽŵŵĞƌĐŝĂůƐĞƌǀŝĐĞƐƚŽƉƌŽũĞĐƚƌĞƐŝĚĞŶƚƐĂŶĚŽƚŚĞƌĨĂĐƚŽƌƐĂƌĞĐŽŶƐŝĚĞƌĞĚ͘ϰ dĂďůĞϯ͘ϭϰͲϭϰ͕WĂŐĞϯ͘ϭϰͲϰϮ^ĞĞĐŽŵŵĞŶƚƐϮĂŶĚϯĂďŽǀĞ͘ϱ WĂŐĞϯ͘ϭϰͲϰϰ͕DDYͲϯƚŚƌƵDDYͲϲĂƐĞĚƵƉŽŶĐŽŵŵĞŶƚƐϮĂŶĚϯĂďŽǀĞDDYͲϯƚŚƌŽƵŐŚDDYͲϲƐŚŽƵůĚďĞƌĞͲĞdžĂŵŝŶĞĚ͘A.1-147A.1-148A.1-149A.1-150A.1-1518-231
02080
Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 43 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^Ͳϰ͘ϬKd, Z Y/^^h ^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϰ͘ϬKƚŚĞƌ Y/ƐƐƵĞƐϭ WĂŐĞϰͲϭ͕/ƌƌĞǀĞƌƐŝďůĞ ŶǀŝƌŽŶŵĞŶƚĂů/ŵƉĂĐƚƐdŚĞĚŝƐĐƵƐƐŝŽŶĚŝƐĐƵƐƐĞƐƚŚĞ͞ĂƵƚŽŵŽďŝůĞͲŽƌŝĞŶƚĞĚŶĂƚƵƌĞŽĨƚŚĞƉƌŽũĞĐƚ͘͟dŚŝƐĐŽŵŵĞŶƚĚŽĞƐŶŽƚƐĞĞŵĂƉƉƌŽƉƌŝĂƚĞŝŶƚŚĞĐŽŶƚĞdžƚŽĨƚŚĞŝƚLJ>h ͕>h /Z͕&Z^WƉƌŽũĞĐƚĚĞƐĐƌŝƉƚŝŽŶĂŶĚƉƌŽƉŽƐĞĚƉƌŽũĞĐƚĐŽŵƉŽŶĞŶƚƐ͘/ƚŝƐĂŵŝdžĞĚͲƵƐĞƉƌŽũĞĐƚŽŶĂĚĞƐŝŐŶĂƚĞĚŝƚLJĚĞǀĞůŽƉŵĞŶƚƐŝƚĞ͘ĞǀĞůŽƉŵĞŶƚŽĨƚŚĞ&Z^WƐŝƚĞŝƐĐŽŶƐŝƐƚĞŶƚǁŝƚŚƚŚĞϮϬϭϰ>h ƚŚĂƚŝĚĞŶƚŝĨŝĞƐŝƚĂƐĂŶĞdžƉĂŶƐŝŽŶĂƌĞĂĨŽƌƚŚĞŝƚLJ͘dŚĞhƚŝůŝƚŝĞƐĂŶĚ ŶĞƌŐLJƐĞĐƚŝŽŶŽĨƚŚĞ /ZŽŶƉĂŐĞϯ͘ϭϰͲϰϯŝŶĚŝĐĂƚĞƐ͞dŚĞƉƌŽũĞĐƚƐĞƐƚŝŵĂƚĞĚƉĞƌĐĂƉŝƚĂĞůĞĐƚƌŝĐŝƚLJĂŶĚŶĂƚƵƌĂůŐĂƐĚĞŵĂŶĚƐǁŽƵůĚďĞďĞůŽǁŝƚLJ͕ZĞŐŝŽŶĂůĂŶĚƐƚĂƚĞǁŝĚĞĚĞŵĂŶĚƐ͘͟dŚĞĂƉƉůŝĐĂŶƚŚĂƐƉŽŝŶƚĞĚŽƵƚƚŚĂƚƚŚĞƌĞŵĂLJďĞĞƌƌŽƌƐŝŶƚŚĞsDdĐĂůĐƵůĂƚŝŽŶƐĂƐƚŚĞLJƐĞĞŵƐƵƐƉĞĐƚĨŽƌƌĞĂƐŽŶƐƉŽŝŶƚĞĚŽƵƚŝŶƚŚĞĂƉƉůŝĐĂŶƚ͛ƐĐŽŵŵĞŶƚƐŽŶhƚŝůŝƚŝĞƐĂŶĚ ŶĞƌŐLJƐĞĐƚŝŽŶ͘Ϯ WĂŐĞϰͲϯ͕ƉĂƌĂŐƌĂƉŚϮdŚĞ /ZĐŽƵůĚĨƵƌƚŚĞƌĂĐŬŶŽǁůĞĚŐĞƚŚĂƚĂƐŝŐŶŝĨŝĐĂŶƚƉŽƌƚŝŽŶŽĨƚŚĞsŝůůĂŐŐŝŽƌĞƐŝĚĞŶƚƉŽƉƵůĂƚŝŽŶĂƌĞůŝŬĞůLJƚŽĐŽŵĞĨƌŽŵƚŚĞŝƚLJĂŶĚŽƵŶƚLJŽĨ^ĂŶ>ƵŝƐKďŝƐƉŽ͘ƵƌƌĞŶƚĚĞƉŽƐŝƚůŝƐƚŽĨϲϬϬƉĞŽƉůĞŝƐĂďŽƵƚϰϱͲϱϬйĐŽŵƉŽƐĞĚŽĨŝƚLJƌĞƐŝĚĞŶƚƐ͘dŚŽƐĞƌĞƐŝĚĞŶƚƐǁŚĞŶƚŚĞLJŵŽǀĞƚŽsŝůůĂŐŐŝŽǁŝůůǀĂĐĂƚĞĂŶĚŵĂŬĞĂǀĂŝůĂďůĞƚŚĞŝƌĞdžŝƐƚŝŶŐŚŽƵƐŝŶŐŝŶƚŚĞŝƚLJƚŚƵƐĂĚĚŝŶŐƚŽƚŚĞŚŽƵƐŝŶŐŝŶǀĞŶƚŽƌLJ͘A.1-152A.1-1538-232
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 44 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^Ͳϱ͘Ϭ>d ZEd/s ^ŽŵŵĞŶƚη WĂŐĞηͬ^ĞĐƚŝŽŶͬ&ŝŐƵƌĞZĞĨĞƌĞŶĐĞ ŽŵŵĞŶƚ/ƐƐƵĞƌĞĂʹϱ͘ϬůƚĞƌŶĂƚŝǀĞƐϭ &ŝŐƵƌĞϱͲϮ͕ƉĂŐĞϱͲϮϲĞůĞƚĞƚŚĞϭϱϬĨƚĞůĞǀĂƚŝŽŶůŝŶĞƐĂƐƚŚĞLJŝŵƉƌŽƉĞƌůLJŝŵƉůLJĂŚĞŝŐŚƚůŝŵŝƚƌĂƚŚĞƌƚŚĂŶĂĚĞǀĞůŽƉŵĞŶƚĂƌĞĂůŝŵŝƚĂƚŝŽŶ͘Ϯ WĂŐĞϱͲϭϴ͕ŝƚĞŵϯͿdŚĞĂƉƉůŝĐĂŶƚĚŝƐĂŐƌĞĞƐǁŝƚŚƚŚĞĂŶĂůLJƐŝƐŽĨƚŚĞϯƌĚĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐƚŽĂůůĞ:ŽĂƋƵŝŶ͘ĂůůĞ:ŽĂƋƵŝŶŝƐƵŶƐƵŝƚĂďůĞĂƐĂŶĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐĨŽƌƚŚĞĨŽůůŽǁŝŶŐƌĞĂƐŽŶƐ͗͘Ϳ/ƚŝƐƐƵďũĞĐƚƚŽŝŶƵŶĚĂƚŝŽŶĚƵƌŝŶŐŚŝŐŚĨůŽǁƐƚŽƌŵĞǀĞŶƚƐ͘͘ͿĂůůĞ:ŽĂƋƵŝŶŝƐĂĐƵůͲĚĞͲƐĂĐƐƚƌĞĞƚŚĂǀŝŶŐŽŶůLJŽŶĞǁĂLJŽƵƚ;ƚŽǁĂƌĚ>KsZͿ͘WƌŽǀŝƐŝŽŶŽĨĂƐĞĐŽŶĚĂĐĐĞƐƐĂůŽŶŐ>KsZŝƐĂďĞƚƚĞƌ͕ŵŽƌĞƵƐĞĂďůĞŽƉƚŝŽŶĨŽƌƚŚĞϯƌĚĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐ͘ͿĞƐŝŐŶŽĨƚŚĞĂĐĐĞƐƐĂƚƚŚŝƐůŽĐĂƚŝŽŶŵĂLJĨŽƌĐĞĞŶĐƌŽĂĐŚŵĞŶƚŝŶƚŽĂŶĞdžŝƐƚŝŶŐŽƵŶƚLJKƉĞŶ^ƉĂĐĞ ĂƐĞŵĞŶƚĂƌĞĂĂŶĚĐŽŶƐƚƌƵĐƚŝŽŶŽĨĂƌĞƚĂŝŶŝŶŐǁĂůůŝŶƚŚĞǀŝĐŝŶŝƚLJŽĨƚŚĞĐƌĞĞŬ͘ͿƌĞƋƵŝƌĞĐŽŶƐƚƌƵĐƚŝŽŶŽĨĂďƌŝĚŐĞĂƚƚŚĞĐŽŶĨůƵĞŶĐĞŽĨĚƌĂŝŶĂŐĞϭ͕Ϯ͕ϯĂŶĚ&ƌŽŽŵƌĞĞŬ͘^ĞĞĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϯ WĂŐĞϱͲϮϯ͕DĂĚŽŶŶĂ&ƌŽŽŵZĂŶĐŚĞǀĞůŽƉŵĞŶƚdŚĞĂƉƉůŝĐĂŶƚŚĂƐƐĞǀĞƌĂůĐŽŶĐĞƌŶƐǁŝƚŚƚŚĞƉƌŽƉŽƐĞĚůŽĐĂƚŝŽŶŽĨƚŚĞdƌĂŝůŚĞĂĚWĂƌŬƐŚŽǁŶŽŶůƚηϭ͘dŚĞĐŽŶĐĞƌŶƐĂƌĞ͗•WůĂĐĞŵĞŶƚŽĨƚŚĞWƵďůŝĐWĂƌŬĂƚYƵĂƌƌLJĂƌĞĂƐĞĞŵƐĂƚŽĚĚƐǁŝƚŚƚŚĞŐŽĂůŽĨƐƉĞŶĚŝŶŐƚŚĞŵŽŶĞLJƚŽƌĞƐƚŽƌĞĂŶĚĐĞůĞďƌĂƚŝŶŐƚŚĞ,ŝƐƚŽƌŝĐZĞƐŽƵƌĐĞƐʹŝƚŚŝĚĞƐƚŚĞďƵŝůĚŝŶŐƐĂŶĚƚŚĞWƵďůŝĐWĂƌŬǀĞƌƐƵƐƉůĂĐŝŶŐƚŚĞŵŝŶĂƉƌŽŵŝŶĞŶƚƉŽƐŝƚŝŽŶŶĞĂƌƚŚĞĞŶƚƌLJƚŽƚŚĞĚĞǀĞůŽƉŵĞŶƚ͘•ĚĂƉƚŝǀĞƌĞͲƵƐĞͲƉůĂĐŝŶŐƚŚĞďƵŝůĚŝŶŐƐĂƚƚŚĞĞŶĚŽĨƚŚĞĐƵůĚĞƐĂĐŵĂLJŵĂŬĞƚŚĞŵŵŽƌĞĚŝĨĨŝĐƵůƚĨŽƌĂĚĂƉƚŝǀĞƌĞͲƵƐĞ͘• ŵĞƌŐĞŶĐLJĐĐĞƐƐͲƉƵƚƚŝŶŐƉĂƌŬĂƚƚŚĞĞŶĚŽŶƚŚĞĐƵůĚĞƐĂĐŚĂƐƐŝŐŶŝĨŝĐĂŶƚĐŽŶƐƚƌĂŝŶƚƐĨŽƌĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐƚŽƚŚĞŵ͘•^ĂĨĞƚLJͲWůĂĐŝŶŐƚŚĞďƵŝůĚŝŶŐƐĂƚƚŚĞĞŶĚŽĨƚŚĞĐƵůĚĞƐĂĐǁŝůůŵĂŬĞƚŚĞƉĂƌŬůĞƐƐƐĂĨĞ͘A.1-154A.1-155A.1-1568-233
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 45 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^Ͳϱ͘Ϭ>d ZEd/s ^•&ŝƌĞƐĂĨĞƚLJͲZĞƐƚŽƌĞĚďƵŝůĚŝŶŐƐǁŝůůŚĂǀĞǁŽŽĚƐŚŝŶŐůĞƌŽŽĨʹĂĨŝƌĞŝƐƐƵĞĂĚũĂĐĞŶƚƚŽǁŝůĚůĂŶĚƐŝŶĐŽŵƉĂƌŝƐŽŶƚŚĞŶĞǁďƵŝůĚŝŶŐƐǁŝƚŚĨŝƌĞƌĞƐŝƐƚŝǀĞĐŽŶƐƚƌƵĐƚŝŽŶ͘•,ŽƵƐŝŶŐǀƐWĂƌŬͲWůĂĐŝŶŐŚŽƵƐŝŶŐŽĐĐƵƉŝĞĚϭϲŚƌͬĚĂLJĂĚũĂĐĞŶƚƚŽ,ŽŵĞĞƉŽƚƐĞĞŵƐůŝŬĞĂƉŽŽƌĐŚŽŝĐĞĐŽŵƉĂƌĞĚƚŽƚŚĞďĞŶĞĨŝƚƐŽĨƚŚĞƉĂƌŬĂŶĚŚŝƐƚŽƌŝĐďƵŝůĚŝŶŐƐďĞŝŶŐĨƌŽŶƚĂŶĚĐĞŶƚĞƌĂŶĚƚŚĞŚŽƵƐŝŶŐƐŚŝĞůĚĞĚĨƌŽŵƚŚĞĐŽŵŵĞƌĐŝĂůƵƐĞ͘ϰ dĂďůĞϱͲϰ͕ƉĂŐĞϱͲϮϴ͕ ŵĞƌŐĞŶĐLJĂĐĐĞƐƐĂƚĚƌĂŝŶĂŐĞďĂƐŝŶ^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϱ WĂŐĞϱͲϯϬ͕ ŵĞƌŐĞŶĐLJĂĐĐĞƐƐĂƚĚƌĂŝŶĂŐĞďĂƐŝŶ^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϲ͘ WĂŐĞϱͲϯϭ͕ŝƚĞŵϯ͕͘ĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐ ^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϳ͘ WĂŐĞϱͲϯϯ͕dĂďůĞϱͲϱ^ĞĞƉƌŝŽƌĐŽŵŵĞŶƚƐƌĞŐĂƌĚŝŶŐsŝůůĂŐŐŝŽƉŽƉƵůĂƚŝŽŶĞƐƚŝŵĂƚĞƐďĞŝŶŐƚŽŽŚŝŐŚ͘ϴ͘ WĂŐĞϱͲϯϱ͕dĂďůĞϱͲϳdŚĞƌĞĂƌĞŶŽ^ƚĂƚĞƐĐĞŶŝĐ,ŝŐŚǁĂLJƐŝŶƚŚĞǀŝĐŝŶŝƚLJŽĨƚŚĞƉƌŽũĞĐƚ͘h͘^͘ϭϬϭŵĂLJďĞĞůŝŐŝďůĞŚŽǁĞǀĞƌŝƚŝƐŶŽƚĚĞƐŝŐŶĂƚĞĚ;sŝƐͲϭĂŶĚsŝƐͲϮͿ͘ϵ WĂŐĞϱͲϯϳ͕dĂďůĞϱͲϳ͕ZͲϯEŽŝŶĚŝǀŝĚƵĂůůLJĞůŝŐŝďůĞďƵŝůĚŝŶŐƐĂƌĞƉƌŽƉŽƐĞĚĨŽƌƌĞŵŽǀĂů͘WĞƌŚĂƚƚĞůZĞƉŽƌƚƉĂŐĞƐϯϰͲϯϱ͕ĞĐĞŵďĞƌϭϰ͕ϮϬϭϳ&ŝŶĂůƌĂĨƚZĞƉŽƌƚ͘ϭϬ WĂŐĞϱͲϯϴ͕dĂďůĞϱͲϳ͕,ĂnjͲϭ ŵĞƌŐĞŶĐLJƌĞƐƉŽŶƐĞŝƐŶŽƚŝŵƉĂŝƌĞĚ͘^ĞĞĐŽŵŵĞŶƚƐŽŶ^ĞĐƚŝŽŶϯ͘ϳ͘ϭϭ WĂŐĞϱͲϱϱ͕','ŝƐĐƵƐƐŝŽŶ^ĞĞƉƌŝŽƌĐŽŵŵĞŶƚƐƌĞŐĂƌĚŝŶŐ','ĐĂůĐƵůĂƚŝŽŶƐ͘ϭϮ WĂŐĞϱͲϲϬ͕DDŝŽͲůƚϭ^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϭϯ WĂŐĞϱͲϲϳ͕/ŵƉĂĐƚZͲϯ͕>ŽƐƐŽĨĐŽŶƚƌŝďƵƚŽƌƐ^ĞĞƉƌŝŽƌĐŽŵŵĞŶƚƐŽŶ^ĞĐƚŝŽŶϯ͘ϱ͘ϭϰ WĂŐĞϱͲϳϬ͕,ĂnjĂƌĚƐ͕ŵŝĚĚůĞƉĂƌĂŐƌĂƉŚ ^ĞĞĐŽŵŵĞŶƚηϮĂďŽǀĞ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘ϭϱ WĂŐĞϱͲϳϱ͕DD/KͲϰ^ĞĞƉƌŝŽƌĐŽŵŵĞŶƚƐƌĞŐĂƌĚŝŶŐůĂĐŬŽĨƋƵĂŶƚŝĨŝĂďůĞƌĂƚŝŽŶĂůĨŽƌďƵĨĨĞƌĚŝƐƚĂŶĐĞƐ͘ϭϲ WĂŐĞϱͲϳϱ͕ŽƚƚŽŵƉĂƌĂŐƌĂƉŚ͕>ŽƐƐŽĨĐŽŶƚƌŝďƵƚŽƌƐ^ĞĞĐŽŵŵĞŶƚƐŽŶ^ĞĐƚŝŽŶϯ͘ϱ͘ϭϳ WĂŐĞϱͲϴϳ͕dĂďůĞϱͲϭϯ͕,ĞĂůƚŚĂƌĞhŶŝƚƐtĂƐƚĞ'ĞŶĞƌĂƚŝŽŶƌĂƚĞƐ,ŽƐƉŝƚĂůĐůĂƐƐŝĨŝĐĂƚŝŽŶŝƐŶŽƚĐŽƌƌĞĐƚĨŽƌƚŚĞƉƌŽƉŽƐĞĚƵƐĞ͘dŚĞĐůĂƐƐŝĨŝĐĂƚŝŽŶƐŚŽƵůĚďĞƚŚĞEƵƌƐŝŶŐͬZĞƚŝƌĞŵĞŶƚ,ŽŵĞĐůĂƐƐŝĨŝĐĂƚŝŽŶĨŽƌƚŚĞƉƌŽƉŽƐĞĚ,ĞĂůƚŚĂƌĞhŶŝƚƐ͘A.1-156cont.A.1-157A.1-158A.1-159A.1-160A.1-161A.1-162A.1-163A.1-164A.1-165A.1-166A.1-167A.1-168A.1-169A.1-1708-234
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Froom Ranch Specific Plan Draft EIR Comments December 2019 Page _ 46 &ZKKDZE, /ZZZDZ ^WKE^ ^ͬKDD Ed^Ͳϱ͘Ϭ>d ZEd/s ^dŚĞƌĞĂƌĞŶŽƐƵƌŐĞƌLJƐƵŝƚĞƐƉƌŽƉŽƐĞĚĂƐƉĂƌƚŽĨƚŚĞ,ĞĂůƚŚĂƌĞhŶŝƚƐĂŶĚŶŽŝŶǀĂƐŝǀĞƉƌŽĐĞĚƵƌĞƐĂƌĞƉĞƌĨŽƌŵĞĚŝŶƚŚĞ,ĞĂůƚŚĞŶƚĞƌ͘ϭϴ WĂŐĞϱͲϵϬ͕&ŝŐƵƌĞϱͲϰ^ĞĞŽŵŵĞŶƚηϮĂďŽǀĞƌĞŐĂƌĚŝŶŐĞŵĞƌŐĞŶĐLJĂĐĐĞƐƐĂƚďĂƐŝŶůŽĐĂƚŝŽŶ͘^ĞĞĂůƐŽĐŽŵŵĞŶƚηϮϯĂďŽǀĞŝŶ^ĞĐƚŝŽŶϯ͘ϭϯZZDĐŽŵŵĞŶƚƐ͘A.1-1718-235
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8.4.5.1 Comment Letter A.1, RRM Design Group
Comment Response A.1-1
Thank you for your comments regarding the FRSP and EIR. Comments will be included in the
public record and provided to decision makers in the planning process. Detailed responses to each
discrete comment made by the commenter are provided below.
Comment Response A.1-2
The comment states the existing red rock quarry at the Project site is not inactive. While not used
for red rock mining, it is currently used for a variety of construction activities and material storage.
The EIR’s description of the permitted red rock quarry has been clarified to indicate this current
setting throughout the EIR.
Comment Response A.1-3
The comment states no State-designated Scenic Highway views would be affected by the Project
as U.S. 101 is not designated as a State Scenic Highway in this area. The EIR correctly identifies
the U.S. 101 in the Project vicinity as an eligible State Scenic Highway (though not officially
designated). Clarifying edits been incorporated into relevant discussions in the EIR. Further, as
described in Section 3.1, Aesthetics and Visual Resources, the segment of U.S. 101 nearest the
Project site is identified as having visual or scenic value under the City’s General Plan. Therefore,
the EIR analysis evaluates impacts to views and visual resources based on eligibility of this
highway under the State Scenic Highway Program and scenic value of the highway as identified
under the City General Plan.
Comment Response A.1-4
The comment states it is unclear how Alternative 3 would increase emergency access and that
Froom Creek would remain a substantial barrier to firefighting equipment accessing the Irish Hills
in the Project area. As discussed in Section 5.0, Alternatives, an existing access point across Froom
Creek is used by ongoing operations onsite. Additionally, an existing City easement maintains an
emergency access between LOVR and the Irish Hills to support wildfire management and
firefighting. The use of the existing Froom Creek crossing at the site would not impede emergency
access. Under Alternative 3, the Applicant would be required to maintain this point of access per
the City’s existing easement. Nevertheless, the comment’s opposition to Alternative 3’s
emergency access evaluation will be included in the public record and provided to decision makers.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response A.1-5
The comment states it is unclear why the EIR identifies Alternative 3 as having “less” of an impact
on Population and Housing if no senior housing would be provided, which is an identified need in
the City Housing Element. Both the Project and Alternative 3 would have less than significant
impacts to population and housing because population growth resulting from new development
would be ultimately accommodated/offset by proposed multi-family residential and senior
residential uses. However, as analyzed in Section 5.0, Alternatives, impacts to population and
housing would be slightly less severe when compared to the Project, as the alternative would
develop 378 fewer residential units and 50,000 fewer square feet of commercial land uses
compared to the Project. Assuming Citywide household size of 2.29 persons per household, this
alternative would result in approximately 458 additional residents in the City, or 866 fewer than
under the Project. Additionally, this alternative would be expected to result in 91 fewer jobs than
under the Project. This decrease in population would have a lessened impact on direct population
growth compared to the Project. Further, given this alternative does not proposed a Life Plan
Community, the development of 200 multi-family residential units would result in a greater
increase in housing that would count towards the City’s housing supply than the Project, including
affordable housing as defined by the Housing Element. In compliance with City requirements, the
additional 26 multi-family residential units counting towards City housing supply would result in
provision of additional affordable housing units that would be constructed under inclusionary
housing requirements, which would lessen impacts compared to the Project. Section 3.11,
Population and Housing acknowledges that the City Housing Element acknowledges affordable
housing as a priority in the City, as well as senior housing as another housing need.
Comment Response A.1-6
The comment states that Section 1.0, Introduction inaccurately describes the 2014 LUCE Specific
Plan Area uses as “small scale commercial” as the LUCE allows for commercial space to be up to
300,000 sf. The comment has been incorporated and “small scale” has been removed from the
description of existing commercial uses.
Comment Response A.1-7
The comment restates comments regarding the status of the onsite quarry and that it is not inactive.
Please refer to Comment Response A.1-2.
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Comment Response A.1-8
The comment states the City’s General Plan does not prohibit development above the 150-foot
elevation line. The EIR analyzed the Project consistent with applicable policies of the City’s
General Plan, including Policies 6.4.1, 6.4.2, and 6.4.7, which, as the commenter points out, state
that open space should be secured above the 150-foot elevation in conjunction with any
subdivision or development of the lower elevation areas. It is clear from City policy that Project
development should be restricted above the 150-foot elevation line. As analyzed in Section 3.9,
Land Use and Planning, the proposed Project would be inconsistent with the policy and set an
inconsistent precedent for the City causing the potential for further development above 150-feet
elevation line in the Irish Hills area.
Comment Response A.1-9
The comment states although many of the surrounding land uses are single-story, there are several
buildings in the vicinity that approach 35 to 40 feet in height including Costco, Home Depot, and
others. Therefore, it is more accurate to describe development in the Project vicinity particularly
at Irish Hills Plaza, as consisting of a range of building types and heights ranging from 1-3 stories
and 30-35 feet in height. The EIR has been edited as needed to reflect the range of building heights
in the Project vicinity.
Comment Response A.1-10
The comment restates comments regarding the status of the onsite quarry and that it is not inactive.
Please refer to Comment Response A.1-2.
Comment Response A.1-11
The comment states Objective 10 in Section 2.3, Project Objectives requires the Applicant to
exceed the requirements of Title 24 and California Energy Code, which the Applicant feels is too
open-ended and required exceedance of Title 24 may be infeasible for the Project. For consistency
with other mitigation requirements in the EIR, this objective has been revised to state that the
Project shall “meet or exceed” Title 24 and California Energy Code requirements.
Comment Response A.1-12
The comment expresses concern that the wording of “59.0 acres of dedicated open space” is
awkward and implies a fee dedication of open space. Comment suggests use of phrase “dedicated
for use as open space” or delete the word “dedicated.” The City’s LUE requires open space be
preserved either by dedication of permanent easements or transfer of fee ownership to the City,
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
the County, or a responsible, nonprofit conservation organization. No fee dedication of the Open
Space area is proposed at this time. The EIR has been clarified by deleting the term “dedicated” in
relation to proposed Project open space and conservation district uses (C/OS). Rather, through the
proposed FRSP land use plan, open space would be designated onsite and edits to reflect this
clarification have been made throughout the EIR.
Comment Response A.1-13
The comment requests Figure 2-6 of the EIR be revised to exclude the 150-elevation line as the
line implies a height limit rather than a development area limitation. Figure 2-6 has been revised
as requested by the comment.
Comment Response A.1-14
The comment restates comments regarding the wording of “59.0 acres of dedicated open space”
as being awkward and implying a fee dedication of open space. Please refer to Comment Response
A.1-12.
Comment Response A.1-15
The comment restates concerns regarding Objective 10 in Section 2.3, Project Objectives and that
required exceedance of Title 24 may be infeasible for the Project. Please refer to Comment
Response A.1-11.
Comment Response A.1-16
The comment states the historic buildings to be relocated would be maintained by the City as the
structures would be located within the proposed public park. As noted in footnote to Table 2-5, the
City has not determined who would be responsible for maintenance of the rehabilitated historic
buildings. Responsibility for maintenance of the historic structures is subject to City Council
approval.
Comment Response A.1-17
The comment references the EIR’s description of Mountainbrook Church as a single-story building
and specifies the EIR does not state the building is 35 feet tall and does not mention the nearby
KSBY facility. To address the comment, the EIR has been clarified to describe the building as
approximately 35 feet tall in Section 3.1.1.2. While the KSBY facility is in the Project vicinity,
the facility is not relevant in the context of the Project and is not visible from the Project site, so
discussion of the KSBY facility as an aesthetic issue is not directly applicable or necessary in this
EIR.
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Comment Response A.1-18
The comment states the EIR fails to discuss that roughly parallel to the trail (KVA 4) and
approximately 400 to 600 feet away are the Costco loading docks, Costco fuel station, and Home
Depot loading docks. While activities associated with Irish Hills Plaza, including fuel stations and
loading docks are present, the existing character of the view faces urban development from a rural
setting. The Project site can be viewed as natural buffer between commercial and urban
development within the City and the natural landscapes of the Irish Hills. To address the
comment’s identification of specific activities at Irish Hills Plaza, specification of activities
associated with loading docks has been added to Section 3.1.1.4.
Comment Response A.1-19
The comment states a break of 250 feet along LOVR would afford drivers a view of the Project
lasting approximately two seconds. To address this comment, the specification of the duration of
visibility has been added to Section 3.1, Aesthetics and Visual Resources.
Comment Response A.1-20
The comment states the view from the LOVR Overpass of 300 feet would last approximately 2.2
seconds. To address this comment, the duration of visibility has been added to Section 3.1,
Aesthetics and Visual Resources.
Comment Response A.1-21
This comment references prior comments made to Section 3.1, Aesthetics and Visual Resources
regarding characterization of U.S. 101 as a designated State scenic highway. Please refer to
Comment Response A.1-3.
Comment Response A.1-22
The comment states KVA 4 is not shown on the City’s COSE Figure 11 Scenic Roadways and
Vistas Mapping. KVAs are analysis tools to isolate and analyze representative views of a project
to demonstrate the potential visual effects from different perspectives. As a representation, the
impact analyzed in a KVA may indicate a type or range of impacts not only for the specific KVA
but also for the general perspective or vantage point the KVA represents. KVA 4 was selected due
to the proximity of an existing scenic vista along a public trail area. Additionally, this KVA was
selected because it provides a view of the existing open space and adjacent land uses experienced
from a popular public trail. This KVA also represents the view from a comparable location
reflective of that identified in the General Plan COSE as a scenic vista. The City’s COSE Figure
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
11 identifies a location approximate to KVA 4 as a scenic vista with a cone of view towards the
Project site.
Comment Response A.1-23
The comment asks in the visual simulation image of KVA 2, what is the building opposite the
roundabout? The building is identified in Figure 2-5 – the conceptual site plan - as a High-Density
Multi-Family Housing building.
Comment Response A.1-24
The comment states implementing landscape planting and irrigation prior to issuance of building
permits is not practicable or desirable as damage may result from construction. Comment request
timing be prior to occupancy of each phase. As identified in MM VIS-1, the landscaping plan
would occur upon completion of Phase 1, so no damage to landscaping outside of building sites
would result from construction activities. MM VIS-1 has been modified to require completion of
landscape plantings and irrigation outside of building sites prior to issuance of building permits
for each phase. Completion of landscape plantings and irrigation within building sites is required
prior to occupancy for each phase.
Comment Response A.1-25
The comment states that the EIR discussion fails to note that none of the proposed buildings would
visually exceed the height of the existing Mountainbrook Church building on a hillside adjacent
to the Project site, as specified in the FRSP. Discussion of Impact VIS-2 in Section 3.1, Aesthetic
and Visual Resources has been revised to disclose this proposed aspect of the FRSP.
Comment Response A.1-26
The comment states the 150-foot elevation is not a building height limitation but instead a ground
elevation topographical reference to limit the extent of development area. Page 3.1-35 of the EIR,
as referenced by the commenter, does not specify the 150-foot elevation is a building height
limitation. Rather, the EIR acknowledges that the elevation line represents a development area and
land use restriction under the City’s General Plan.
Comment Response A.1-27
The comment states the EIR’s description overstates the quality of the view from KVA 4. Views
and aesthetic resources are to an extent subjective; however, existing views from trails and the
Irish Hills Natural Reserve provided a buffer of the existing undeveloped Project site, which
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warrants scenic value. The scenic value of this view from a popular public trail is also supported
by the City LUCE policies, as analyzed in Section 3.9, Land Use and Planning.
Comment Response A.1-28
Please refer to Comment A.1-17. The comment references the EIR’s description of Mountainbrook
Church as a single-story building and specifies the EIR does not state the building is 35 feet tall
and does not mention the nearby KSBY facility.
Comment Response A.1-29
The comment states the visual simulation places the proposed buildings in the center of the Upper
Terrace too high. Additionally, the comment claims the FRSP specifies that no building on the
Upper Terrace would exceed the height of Mountainbrook Church. Placement of structures models
for the purposes of the visual simulations and EIR analysis are based on the location of structures
as depicted in the FRSP conceptual site plan to demonstrate the overall scale and extent of
proposed development under the Project. As discussed in Comment Response A.1-25, discussion
of Impact VIS-2 in Section 3.1, Aesthetic and Visual Resources has been revised to disclose that
structures would not exceed the finished height of the Mountainbrook Church building.
Comment Response A.1-30
The comment asks if there is quantitative evidence supporting KVA 5 discussion and that
“recreationalists currently expect scenic views of high-quality habitats.” The comment states that
this is characterization is speculative and that the City Planning Commission has disagreement on
the issue. The City’s Irish Hills Natural Preserve encompasses approximately 1,110 acres of land
identified as a significant natural resource supporting a rich and diverse wildlife population. The
Irish Hills Natural Preserve is frequented by recreationalists. For many of these recreationalists
and visitors of the Irish Hills Natural Preserve, the belief and expectation of visitors and users of
the trails is that views of the natural areas and open spaces are high in quality. While it is
acknowledged that views and aesthetic resources are to an extent subjective, the EIR reasonably
characterizes the views afforded from trails within the Irish Hills Natural Reserve and their value
to the public as important visual resources.
Comment Response A.1-31
The comment states that the Project would not obstruct scenic views of open spaces from the City
and Irish Hills Natural Preserve. The comment additionally claims the EIR does not include
discussion of obstruction. The discussion of Impact VIS-2 in Section 3.1, Aesthetics and Visual
Resources states that development of the Project above the 150-foot elevation line would intrude
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
into or obstruct views of the Irish Hills Natural Preserve. The Project site is highly visible from
public trails along the southeastern edge of the Irish Hills Natural Preserve; therefore, the Project
would reasonably result in the obstruction of scenic views of open spaces from the City and Irish
Hills Natural Preserve. Please refer to discussion of Impact VIS-2 in Section 3.1, Aesthetics and
Visual Resources for further analysis.
Comment Response A.1-32
The comment asks if the acreages in Table 3.2-2 of Section 3.2, Agricultural Resources account
for deductions for land that is not farmable (e.g., creeks, protected plant species). Soil capabilities
and acreages provided in Table 3.2-2 are based on NRCS soil surveys for the entire Project site
and does not include a distinction for areas that may not be farmable. Table 3.2-2 is intended to
identify the total area and amount of soils that are current present at the Project site.
Comment Response A.1-33
The comment states the EIR presumes offsite mitigation would be required; however, Table 3.3-7
indicates that the Project’s mitigated construction emissions would not exceed the APCD’s Tier 2
quarterly threshold for NOx and ROG emission nor DPM emissions. The comment requests MM
AQ-3 be revised to indicate the offsite mitigation may not be required. As described in the EIR,
despite implementation of MM AQ-1 and -2, ROG and NOx emissions would exceed SLO County
APCD daily and Tier 1 quarterly thresholds as described in Table 3.3-7. Based on exceedance of
SLO County APCD thresholds, MM AQ-3 is required consistent with adopted SLO County APCD
guidance to reduce Project emissions. Per the SLO County APCD’s 2017 Clarification
Memorandum for the San Luis Obispo County Air Pollution Control District’s 2012 CEQA Air
Quality Handbook clarification regarding the ROX and NOx Quarterly Tier 1 threshold “Offsite
mitigation may be required if feasible mitigation measures are not implemented, or if no mitigation
measures are feasible for the project.” Based on the analysis of Project construction emissions
presented in Impact AQ-1, offsite mitigation is identified as necessary to mitigate Project impacts.
SLO County APCD concurs with the findings and required mitigation measures of the EIR made
with respect to Project construction emissions in their comment letter submitted to the City during
review of the Draft EIR (refer to Comment Letter L.1).
Comment Response A.1-34
The comment states the residual impact discussion is confusing regarding operational ROG and
NOx emissions, as the EIR states the impact would be considered less than significant per SLO
County APCD’s CEQA Air Quality Handbook if mitigation measures are implemented. The
comment further states that this is in contradiction to the EIR statement that operational emissions
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reductions cannot be quantified so are determined significant and unavoidable. The EIR’s
approach to residual impacts of ROG and NOx emissions is consistent with existing EIRs in the
City, including the San Luis Ranch EIR, and guidance provided by SLO County APCD in their
2012 CEQA Air Quality Handbook and 2017 Clarification Memo. As noted in MM AQ-2, many
measures listed in the mitigation do not contain quantifiable air quality emissions reductions for
land use planning programs such as the FRSP. While implementation of these measures can reduce
ROG and NOx, the Project’s estimated emissions after implementation of the measures cannot be
reasonably quantified; therefore, the EIR determined impacts to be significant and unavoidable.
Please refer to Section 3.3, Air Quality and Greenhouse Gas Emissions for further discussion of
the EIR’s approach.
Comment Response A.1-35
The comment notes a discrepancy in AQ-4 impact discussion as the impact being identified less
than significant with mitigation, while the residual discussion finds the impact being significant
and unavoidable. Impact AQ-4 would result in significant and unavoidable impacts as discussed
throughout Section 3.3, Air Quality and Green House Gas Emissions. The summary of Impact
AQ-4 incorrectly stated impacts would be less than significant with mitigation. This text has been
corrected in the EIR to accurately present the Project’s impact and findings as significant and
unavoidable.
Comment Response A.1-36
The comment states that the EIR does not attempt to quantify reductions in emissions that would
result from implementation of required mitigation measures, particularly those identified in MM
AQ-4 through MM AQ-6. However, as discussed in the residual impact discussion in Section 3.3,
Air Quality and Greenhouse Gas Emission, the FRSP is a programmatic land use plan and many
of the mitigation measures identified require implementation of strategies for reducing GHG
emissions that cannot be reliably quantified absent more specific information for the Project. For
instance, one of the standard mitigation strategies identified for the Project in MM AQ-6 is for the
FRSP to encourage and incentivize resident and employee participation in the San Luis Obispo
Regional Rideshare program, and Table 3.3-9 (Mitigation Measures from APCD CEQA Air
Quality Handbook) requires promotion of carpool and vanpool programs, and use of electric
vehicles. At this stage, the Project does not contain operation details related to these measures.
While these measures and others identified in the EIR would help to reduce individual automobile
trips, it is uncertain how effective the programs would be or how many trips could be eliminated.
These conclusions regarding inability to reliably quantify emission reduction strategies are
consistent with CEQA analyses presented throughout the State, as well as those conducted for
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
other large-scale development within the City, such as the Avila Ranch Development Plan and San
Luis Ranch Specific Plan.
Comment Response A.1-37
The comment is related to the VMT calculations used in the EIR. The analysis and VMT
calculations presented in Section 3.3, Air Quality and Greenhouse Gas Emissions utilized the
VMT calculations presented within the Applicant-prepared and City-approved Transportation
Impact Study. The Final EIR includes additional clarifications regarding VMT based on
supplemental analysis; however, the net VMT attributable to the Project is 16,362 daily VMT. It
is uncertain how effective identified programs would eliminate vehicle trips and/or associated
emissions; therefore, the conclusions in the EIR remain valid. Please refer to Section 3.13,
Transportation and Traffic and Appendix J for explanation of the Project’s VMT calculations.
Comment Response A.1-38
The comment states that the EIR should note that mobile source emissions are the largest source
of operational emissions, which are not regulated directly by the City or SLO County APCD but
are regulated at a state and federal level. The comment further states that the GHG mitigation
program should acknowledge that the Applicant should not be penalized for mobile source
emissions that are regulated at the state and federal level. MM AQ-6 has been revised to note that
mobile source emissions are regulated at the state and federal level.
Comment Response A.1-39
The comment states that it is infeasible for the Applicant to operate a hub/node of the bicycle share
program as the ultimate developer of the Project may not be the property owner or business
operator upon completion of the Project. Based on further review of the feasibility of this measure,
Measure 16 in MM AQ-4 has been revised to require identification of a hub/node location within
the FRSP such that it could be developed in the future.
Comment Response A.1-40
The comment questions if zero emission shuttle vehicles are currently feasible and available. Zero
emission shuttle vehicles are currently available in the City and are feasible for further use
including the Project site.
Comment Response A.1-41
The comment questions who will operate mitigation measure services. Upon further review of the
feasibility of a car share program, MM AQ-4 has been amended to state that “The City has
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consulted with car share programs in other areas and researched the requirements of such a
program, and have determined that a car share program is not feasible for this Project.” Other
aspects of this measure remain applicable and feasible for Project implementation by future
occupants and managers of the development.
Comment Response A.1-42
The comment restates concerns regarding who will operate mitigation measure services. Please
refer to Comment Response A.1-41.
Comment Response A.1-43
The comment states the FRSP upon implementation would not be a single ownership able to
implement measures identified in MM AQ-4, as amended. The referenced measure would require
revisions to the FRSP to include policies for implementation of this measure, making the
responsibility for implementation of this measure the ultimate operator of proposed development
under the FRSP.
Comment Response A.1-44
The comment states the FRSP upon implementation would not be a single ownership able to
implement measures identified in MM AQ-4. The referenced measure would require revisions to
the FRSP to include policies for implementation of this measure, making the responsibility for
implementation of this measure the ultimate operator of proposed development under the FRSP.
Comment Response A.1-45
The comment states the FRSP upon implementation would not be a single ownership able to
implement measures identified in MM AQ-4. The referenced measure would require revisions to
the FRSP to include policies for implementation of this measure, making the responsibility for
implementation of this measure the ultimate operator of proposed development under the FRSP.
Comment Response A.1-46
The comment states the Applicant does not feel Measure 37 of MM AQ-4 is feasible. As discussed
in MM AQ-4, the Project is required to comply with MM AQ-5 requiring FRSP amendment to
require Project include measures necessary to reduce Project operational stationary-source
emissions, including utilization of 100 percent of carbon-free energy.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response A.1-47
The comment expresses concern that there is a lack of quantifiable information regarding potential
mitigation measures puts the discussion into the realm of speculation regarding achieving actual
reductions. Please refer to Comment Response A.1-34.
Comment Response A.1-48
The comment states MM AQ-5 would not be feasible for the Applicant to achieve. As described
in Section 3.3, Air Quality and Greenhouse Gas Emission, MM AQ-5 requires the Project to
reduce operational stationary-source GHG emissions to achieve net zero emission for the Project,
consistent with the City’s 2035 net-zero GHG emissions target. It is feasible for solar photovoltaic
systems to be installed onsite and retrofitted to buildings, including large structures and hospital
facilities. The Project is also required to provide on-grid power with 100-percent renewable or
carbon free source, which is a planned product available to the City by 2020 of the Monterey Bay
Community Power. Backup power and battery technology is intended for emergency conditions
on a short-term time scale, so the Project would not be required to include emergency scenarios in
net-zero objectives. In addition, consistent with the City’s 2035 net-zero GHG emissions target
assumptions, exemptions to the electricity requirement include commercial kitchens and medical
end-uses that have no viable electric alternative (refer to clarifications to MM AQ-5).
Comment Response A.1-49
The comment asks how car sharing opportunities would be provided within Madonna Froom
portion of the Project site. Upon further review of the feasibility of a car share program, MM AQ-
4 has been amended to state that “The City has consulted with car share programs in other areas
and researched the requirements of such a program, and have determined that a car share program
is not feasible for this Project.” The comment states that residential units may be sold to the public
without a homeowner’s association. The air quality and GHG analysis presented in the EIR
acknowledges difficulty in mobile-emission sources generated by the Project, and notes that
achieving net-zero emissions may be infeasible. Therefore, impacts of the Project are identified as
being significant and unavoidable. In addition, refer to Comment Response A.1-41.
Comment Response A.1-50
The comment states MM AQ-6 is a blank check mitigation approach with no quantified mitigation
cost or feasibility determination. The commenter question who determines what is feasible. As
described in the EIR, MM AQ-6 requires the Applicant to include all feasible Best Management
Practices (BMPs), as well as coordinate with the SLO County APCD and City to calculate
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estimated mobile-source emissions to ensure emissions are reduced to the maximum extent
feasible. The mitigation measures presented in this EIR for reducing Project impacts from
generation of air pollutant and GHG emissions were developed in close coordination with the City
and/or are based on accepted and recommended mitigation measures developed by SLO County
APCD. In addition, clarifications regarding the requirement to provide EV charging stations have
been incorporated into Table 3.3-9 (refer to line 9, which requires installation of or specific fair-
share mitigation to fund an EV charging station at the Calle Joaquin Park & Ride Lot).
Comment Response A.1-51
The comment questions why mitigations described in MM AQ-6 would be included on the VTM.
The commenter states they would not be appropriate for a subdivision map and asks who
determines what is feasible for the MM AQ-6. Reference to inclusion of these measures on the
final VTM has been revised. Regarding feasibility of these measures, the mitigation measures
presented in this EIR for reducing Project impacts from generation of air pollutant and GHG
emissions were developed in close coordination with the City and/or are based on accepted and
recommended mitigation measures developed by SLO County APCD.
Comment Response A.1-52
The comment restates concerns that the EIR does not attempt to quantify reductions in emissions
that would result from implementation of required mitigation measures. Please refer to Comment
Response A.1-36.
Comment Response A.1-53
The comments states there is conflict in the EIR regarding reference to Project compliance with
the calculation projections of the Clean Air Plan. While the Project population projections are
within the County’s Clean Air Plan projections, as described in the EIR, population estimates
cannot be directly compared as the Clean Air Plan only projects population estimates until 2011.
In addition, as described in Impact AQ-2, the Project would result in significant and unavoidable
operational air quality impacts generated by area, energy, and mobile emissions; therefore, the
Project is potentially inconsistent with the Clean Air Plan.
Comment Response A.1-54
The comment expresses concern regarding the discussion presented in Impact AQ-5 and that it
does not state that proposed commercial use is far less than the maximum identified in the City’s
LUE. The referenced discussion has been revised to include a description of the proposed amount
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
commercial use under the Project in comparison to the amount identified in the LUE for the Project
site.
Comment Response A.1-55
The comment states the Project complies with the LUE objectives that are intended to ensure the
Project site is developed primarily with a compact mixed-use development. As described in the
EIR, the Project only proposed 6 percent of the developed acreage to serve commercial uses and
does not feature a compact design, as buildings and structures are dispersed throughout the Project
site. However, additional details related to how the Project conceptual plan would ensure
connectivity within the mix of uses proposed has been included. As described in Section 5.0,
Alternatives Alternative 1 proposes a clustered development to reduce the area of disturbance in
comparison to the proposed Project.
Comment Response A.1-56
This comment notes concern that the Project VMT analysis does not fully capture the unique travel
characteristics of senior housing and the context of the proposed commercial retail use as a
“regional shopping center”. The City’s Travel Demand Forecasting Model is not sensitive to
various forms of multifamily residential housing and it not able to capture trip-making differences
between traditional housing and senior-oriented housing. For this reason, the VMT estimates
presented in the Draft EIR are likely conservative. The Final EIR includes revised VMT analysis
that now includes post-processing adjustments to more accurately reflect the anticipated trip-
making characteristics unique to the senior housing components of the Project.
Regarding commercial retail uses, the City Travel Demand Forecasting Model is sensitive to size
of retail land uses and relationship to nearby population sources in terms of projected travel
characteristics, and ultimately VTM. For commercial retail land uses, the model will first assign
trips to/from these sites based on available population (“customers”) within the immediate
proximity, resulting in predominantly short trips within the city. For large retail land uses, the
model will begin assigning longer-distance trips to/from other population concentrations when the
retail site is more likely to generate demand beyond what is supported within the population in the
immediate vicinity. Based on the magnitude of commercial retail development proposed within
the FRSP Area, it is unlikely that the model is projecting long-distance retail trips representative
of a regional shopping destination.
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Comment Response A.1-57
The comment states that the EIR incorrectly states that transit services would not fully be in place
during early phases of Project development. The referenced text has been revised accordingly.
Comment Response A.1-58
The comment restates concerns regarding comparison of the Project’s anticipated increase in the
City’s and the projections of the Clean Air Plan. Please refer to Comment Response A.1-53.
Comment Response A.1-59
The comment restates concerns regarding comparison of the Project’s anticipated increase in the
City’s and the projections of the Clean Air Plan. Please refer to Comment Response A.1-53.
Comment Response A.1-60
Please refer to Comment Response O.1-5. Subsequent to circulation of the Draft EIR for public
review, the City consulted further with USACE and RWQCB regarding the EIR’s evaluation of
the wetlands that had established within the stormwater basin and both agencies indicated that they
would not consider them to be jurisdictional waters or wetlands due to the fact that the basin was
man-made and located entirely in upland habitat; therefore, the location of the basin would not
have the potential to support wetland vegetation if not for the man-made condition created by
diversion of the Irish Hills Plaza stormwater it retains and treats.
Comment Response A.1-61
The comment states Table 3.4-2 in the EIR provides the incorrect scientific name of the brewers
spineflower. Table 3.4-2 in the EIR lists the scientific name of the brewer’s spineflower as
Chorizanthe ssp. breweri, which is the correct scientific naming.
Comment Response A.1-62
The comment states the Mouse gray Dudleya was observed onsite, so the EIR description of a
moderate to high potential to be present onsite should be describes solely as high potential. To
address this issue, discussion of the Mouse gray Dudleya has been updated to be described as
identified within the western portion of the Project site, instead of identifying likelihood of
occurrence, as consistent with the EIR’s discussion of Special-Status Plant Species.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response A.1-63
The comment states the EIR’s discussion of Froom Creek as a mapped critical habitat for
California red-legged frog is incorrect. As discussed in Section 3.4, Biological Resources, much
of Froom Creek is mapped critical habitat for California red-legged frog, though the portion of
Froom Creek in the Project site does not provide adequate pool habitat for breeding. This section
of the EIR has been clarified to again reference the mapped critical habitat 2.1 miles north of the
Project site. However, during the rainy season, transient individuals could move through Froom
Creek intermittently. California red-legged frog was also documented in the Irish Hills Natural
Reserve – Waddell Ranch Addition within the upper extents of Froom Creek. Despite the long
culverts and other potential barriers that may deter movement from documented occurrences in the
vicinity, it is feasible for California red-legged frog to disperse onto the site under favorable
conditions (i.e., during warm rains) given their ability to travel extensively over land and through
marginal/seasonally dry riparian corridors. Recent upstream observations of adult and juvenile
frogs along Froom Creek indicate that a breeding population is present in the vicinity and could
expand if conditions are suitable. The EIR’s identification of the substantial potential for California
red-legged frog to enter the Project site is based on favorable habitat conditions onsite and site
proximity to mapped California red-legged frog habitat.
Comment Response A.1-64
The comment states the EIR’s discussion of Coastal and Valley Freshwater Marsh does not
reference invasive plants and predators (e.g., crayfish) observed in onsite aquatic habitat along
Calle Joaquin, which would reduce the quality of wetland and aquatic habitat. The Coastal and
Valley Freshwater Marsh, considered by CDFW to be a sensitive natural community, occurs onsite
in Drainages 2 and 3 on the Upper Terrace, the LOVR ditch, and Calle Joaquin wetlands. To
address the comment, discussion of the sightings of crayfish and reed fescue has been added to the
EIR’s discussion of Coastal and Valley Freshwater Marsh. However, invasive species are often
found in many wetlands, particularly those proximate to urban areas, and their presence therefore
does not materially reduce the overall value of such habitats, particularly when compared to other
similar vicinity habitats. Therefore, the potential for this habitat to occur onsite remains high due
to habitat suitability as described in Section 3.4, Biological Resources.
Comment Response A.1-65
The comment states, without providing supporting substantial evidence, that Impact BIO-1 should
not be listed as significant and unavoidable as well as fuel modification impacts are overstated in
the EIR as fuel modification around Villaggio and Madonna areas would occur in grassland
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habitat. The comment also states fuel modifications to grasslands could include mowing and
grazing on a seasonal basis. However, impacts of fuel buffer clearing were calculated based on the
best available habitat mapping and regulatory requirements. For example, clearance of a wildfire
buffer area within internal open space on the Project site would also indirectly result in the
permanent loss or modification of up to 11.0 acres of existing vegetation onsite through vegetation
clearance. Wildfire buffer clearance would impact annual non-native grasslands and serpentine
bunchgrass grasslands, coastal live oak/ California bay woodlands, coastal scrub/chaparral, and
riparian habitats in the Upper Terrace. These grassland habitats support rare plant species and
provide important wildlife habitat. Therefore, wildfire buffer clearance requirements would result
in potential indirect impacts to biological resources both on and off the Project site, including
potentially rare and sensitive habitats, such as serpentine bunchgrass grasslands resulting in
significant and unavoidable impact designation. The comment proposes mowing and/or grazing
activities to reduce the extent of grassland habitat; however, as described in Section 3.4, Biological
Resources, grassland habitats onsite are highly sensitive, and alterations would result in long-term
adverse effects including diminishment in habitat area and potential introduction if invasive
species.
Comment Response A.1-66
The comment states successful mitigation of impacts to wetland and riparian habitat are proven
and that impacts to serpentine bunchgrass grassland can be mitigated onsite. The comment states
impact analysis of the EIR should provide flexibility for the Applicant to implement a monitoring
program and adaptive management strategies (e.g., mowing, grazing, reseeding) to reduce impacts
to serpentine bunchgrass grassland. With regards to mitigation or replacement of wetland and
riparian habitat, the EIR simply identifies the challenges associated with some mitigation options.
First, based upon preliminary hydrologic analysis, the EIR takes a conservative approach in
accounting for successful establishment of wetland and riparian habitats along the realigned Froom
Creek as transitioning what is currently a dry wash to functional wetland and riparian habitats is
somewhat experimental and presents challenges. Similarly, replacement or restoration of unique
wetlands associated with spring and seeps in the Upper Terrace is also challenging due to the
limited distribution and unique nature of such wetlands. With regards to grassland impacts, the
Project would result in the direct loss of serpentine bunchgrass grasslands through Project
development or through removal of vegetation as a result of implementation of defensible space
requirements. The difficulty in successfully establishing or even restoring a serpentine bunchgrass
grassland community is well documented. The comment asserts, without evidence, that mowing,
grazing and reseeding efforts can readily convert nonnative grassland into a serpentine bunchgrass
grassland community. While native bunch grasses have been successfully replanted, replacing the
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
complete range of plant species found in such a serpentine bunchgrass grassland community,
including multiple special status plant species, is far more challenging and actions like moving and
reseeding are unlikely to achieve this result, particularly if underlying soils are not suitable. As
such, successful compensatory replacement and restoration of the Nassella Pulchra Herbaceous
Alliance of equal or greater quality than that which exists onsite is considered unlikely, resulting
in the inability to successfully mitigate associated impacts. Therefore, impacts to these sensitive
natural communities from Project implementation would remain significant and unavoidable.
Comment Response A.1-67
Please refer to Comment Response O.1-5 and A.1-76.
Comment Response A.1-68
The comment states the EIR should not use the existing creek channel conditions for creation of
riparian and wetland habitat but instead use historic creek alignments that will place the realigned
channel in closer proximity to higher groundwater, enhancing the potential restoration success.
While this may have some potential to be the case, no detailed hydrologic or biological studies
have been conducted to conclusively support this assertion. Given the large-scale changes in
hydrology and drainage proposed under the Project and the limited data available on potential
restoration success, the EIR uses a conservative approach on this matter to ensure that impacts are
mitigated. Further, as discussed in Section 3.4, Biological Resources and Section 3.8, Hydrology
and Water Quality, the resiliency of such restored riparian habitat under the Project during major
flood flows is uncertain. Along approximately 1,000 feet of the realigned Froom Creek from the
Project site’s western boundary and through the major bend in the creek, there appears to be the
potential for higher velocity flood flows (5 to 9 feet per second) to scour planted riparian vegetation
from the creek bank leading to potential for repeated damage or removal of such vegetation over
the 75 or more years life of the Project. In the period shortly following construction of the realigned
Froom Creek channel and before riparian vegetation can become fully established, flow velocities
within the creek would become much greater (8 to 12 feet per second). While such scouring is a
natural process along creek corridors, given the engineered nature of this realigned creek habitat,
it is uncertain native riparian habitat would naturally re-establish, potentially requiring repeated
restoration efforts and maintenance over the long term, so impacts remain potentially significant.
The EIR recognizes the requirement to comply with City and RWQCB water quality regulations.
Compliance with these measures will contribute to the mitigation of identified significant impacts.
The comment notes extensive cover of non-native species is overtaking the Calle Joaquin wetlands
and the Project would remove these species as part of the Applicant’s restoration program to reduce
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Project-related impacts to a less than significant level. However, based upon available information,
the Project as described in the FRSP and this EIR does not propose restoration of the Calle Joaquin
wetlands, so these actions are not discussed in Project impact analysis.
Comment Response A.1-69
The EIR presents a conservative analysis of the potential effects of the Project on the environment,
including Froom Creek, San Luis Obispo Creek, and the Calle Joaquin wetlands. The intentions
and goals noted in the comment will be monitored and verified pursuant to comprehensive
mitigation measures, including but not limited to the Biological Mitigation and Monitoring Plan
shall include a Habitat Mitigation and Monitoring Plan (HMMP) (mitigation measures BIO MM-
3).
Comment Response A.1-70
Refer to Comment Responses A.1-68 and A.1-69, above. The comment states maximum flexibility
should be provided to the Applicant to implement appropriate fuel modification methods as new
information is learned regarding potential impacts to sensitive habitats. The comment recommends
seasonally-timed grazing and mowing in grasslands and selective thinning of tree/shrub habitats
should be allowed. The comment additionally recommends the EIR findings for impacts related to
wildfire defensible space clearance to be changed to less than significant with incorporation of
mitigation including additional replanting of native species outside fuel modification zones or
habitat enhancement in areas outside of development. Section 3.4, Biological Resources
acknowledges wildfire fuel management and defensible space requirements for the Project would
be balanced with biological resource protection in mandatory buffer zones, as further analyzed in
Section 3.7, Hazards, Hazardous Materials, and Wildfire. The City retains the ability to adjust
wildfire buffer requirements to implement appropriate fuel modification methods as new
information is learned, as well as seasonally-time grazing and mowing in grasslands and selective
thinning of tree/shrub habitats to meet fire clearance requirements. Further, MM HAZ-2 would
require preparation of a Community Fire Protection Plan and use of a City-qualified biologist to
identify and preserve the integrity of vegetation and habitat surrounding proposed development to
the maximum extent feasible, also reducing impacts. However, it may not be feasible to completely
avoid disturbance of natural and open space areas designated under the Project that contain
sensitive biological resources due to mandatory fire clearance requirements. The proximity of new
development, particularly within the Upper Terrace, may limit the effectiveness of any proposed
measures for mitigating impacts to sensitive upland habitats, particularly the Nassella pulchra
Herbaceous Alliance. It is reasonable to assume that the limited setbacks between proposed
development and known sensitive biological resources would not be sufficient to avoid ongoing
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
indirect impacts associated with continued potential for disturbance from human activities and fire
management requirements. Therefore, Impact BIO-1 remains significant and unavoidable. Please
refer to Section 3.4, Biological Resources for further discussion of Impact BIO-1.
Comment Response A.1-71
Please refer to Comment Response A.1-65 and A.1-70. Select fuel modification practices (e.g.,
irrigation of landscape and selective tree thinning) subject to review and approval by City Fire and
the City’s Natural Resources Manager may assist in ensuring fuel modification reduced impact
levels are met; however, any such practices in sensitive habitat areas will potentially result in
significant and unavoidable impacts because of the loss of some grasslands, including the
serpentine grasslands, which cannot be mitigated successfully.
Comment Response A.1-72
The comment states the LOVR ditch does not provide regular source of inflow to Calle Joaquin
wetlands but is a seasonal source. Comment additionally states during drought years, very little
water may enter the Calle Joaquin wetlands. As described in Section 3.4, Biological Resources,
the EIR acknowledges the LOVR provides a regular source of inflow to the existing wetlands and
includes the stipulation that the primary hydrologic influence supporting the wetlands is upward
groundwater inflow. The comment’s understanding of the hydrologic condition is consistent with
the EIR’s analysis.
Comment Response A.1-73
The comment states that the Applicant disagrees with the discussion presented in the EIR regarding
inability to ensure long-term maintenance of the restored Froom Creek riparian habitat due to
potential for scour and denudation within the Froom Creek corridor. As described in the EIR, while
scouring is a natural process along creek corridors, the engineered nature of the realigned creek
habitat results in uncertainty if native riparian habitat would naturally re-establish potentially
requiring repeated restoration and maintenance long term. However, under MM BIO-5, the
Biological Mitigation and Monitoring Plan would require all temporary and permanent impacts to
riparian habitat to be mitigated at a 2:1 ratio. The Biological Mitigation and Monitoring Plan would
identify adequate restoration and enhancement activities to compensate for impacts to riparian
habitat including detailed planting plans and maintenance plans. MM BIO-5 also requires the
Applicant to prepare a Long-Term Wetland Monitoring Plan for documenting and mitigating any
adverse changes to the Calle Joaquin wetlands that occur over the course of development under
the Specific Plan. Significant loss or adverse change to the Calle Joaquin wetlands would require
compensatory mitigation if observed over 7 years of required monitoring and reporting.
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Implementation of mitigation measures would reduce potential impacts to sensitive riparian and
wetland habitats within the Lower Area (e.g., LOVR ditch and Calle Joaquin wetlands) to less
than significant with mitigation. However, with respect to wetlands in the Upper Terrace, replacing
the unusual seep-fed wetlands present along impacted segments of Drainages 1, 2, and 3 would be
challenging and impacts would be significant and unavoidable. The Applicant’s disagreement with
these conclusions will be noted and provided to City decision makers for consideration.
Comment Response A.1-74
The comment states the EIR’s statement that development would encroach within 20 feet of onsite
drainages is incorrect as drainage setbacks in the Project would follow City policy and Chorro
Creek bog thistle buffers of a minimum of 50 feet. As discussed in Section 3.4, Biological
Resources, the Project proposes to implement the Froom Creek Trail within the 50-foot creek
setback area involving ground disturbing activities. The Froom Creek Trail in some portions, as
shown on the VTTM and described in the FRSP, may encroach as close as 20 feet to the trail
corridor causing potential impacts to creeks and sensitive habitats. These Applicant-provided
materials are the basis for these topics in the EIR impact analysis.
Comment Response A.1-75
The comment states MM BIO-2 should be clarified to state daily monitoring by the qualified
biologist would occur during initial site disturbance and any work within sensitive habitats. The
comment states once the upland portions onsite have been graded, monitoring would not be
required on a daily basis, so the biologist would conduct weekly as needed spot checks. Monitoring
is required under MM BIO-2 for regular construction operations due to sensitive species that are
mobile and may occur within the Project site. As mobile sensitive species locations can vary daily,
daily monitoring is needed. Quarterly monitoring reports are required to be submitted and
approved by the City to ensure compliance.
Comment Response A.1-76
This comment correctly states the mitigation ratios identified in the EIR to mitigate temporary and
permanent impacts to sensitive habitats, but notes concern with regard to the analysis of potential
indirect impacts to the Calle Joaquin wetlands resulting from realignment of Froom Creek and
changes to site hydrology.
As described in Section 3.4, Biological Resources (pages 3.4-45 through 3.4-49) explains the
potential for impacts to the Calle Joaquin wetlands due to changes in site hydrology and drainage.
The EIR explained:
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
The changes in hydrologic balance of this wetland may have consequences to the character,
function, and species composition of these wetlands… This change in frequency and duration of
potential inundation of these wetlands has an unpredictable potential to affect the character and
species composition of the wetlands (and associated use by wildlife), potentially affecting their
qualifying characteristics as Coastal and Valley Freshwater Marsh and a sensitive natural
community.
However, as described above, upward groundwater inflow is the primary hydrologic influence
supporting these wetlands. Though stormwater is a source of water supporting these wetlands, the
presence of groundwater inflows within the area indicates the Calle Joaquin wetland area is likely
to persist with relocation of the stormwater basin and installation of the LOVR ditch, even during
dryer periods. Given the dominant source of water for these wetlands is and would remain
groundwater inflow, alterations in the hydrologic connections and source water for the Calle
Joaquin wetlands is not anticipated to significantly affect the health of these wetlands (Appendix
E)…
Therefore, the EIR clearly recognizes that the Calle Joaquin wetlands may be affected by the
proposed changes in site hydrology and drainage, but are likely to persist onsite and that those
changes are not anticipated to significantly affect the health of these wetlands. The EIR concluded
that a wetland would likely still exist at that location; however, it may have altered wetland
features, characteristics, health, and overall biological integrity.
Due to the uncertainty regarding the extent and type of impacts that could occur to the Calle
Joaquin wetlands, the EIR conservatively determined that there was not substantial evidence to
support and less-than-significant impact determination, and, therefore, requires mitigation of the
Calle Joaquin wetlands at a 2:1 ratio. The Applicant has asserted that there is not a reasonable
nexus or rough proportionality to this requirement, given that the wetlands are likely to persist
onsite after Project implementation.
The City coordinated with the USACE on this issue and during consultation in February 2020,
Jerry Hidalgo, Project Manager of the USACE North Coast Branch Regulatory Division,
confirmed that USACE would likely mitigate a potential indirect impact like the one described
above for the Calle Joaquin wetlands through a long-term wetland monitoring program. In March
2020, the City consulted further with Kathleen Hicks, Environmental Scientist with the Central
Coast Regional Water Quality Control Board, who was generally supportive of the approach
suggested by USACE. Therefore, the EIR has been clarified and corrected to more proportionately
mitigate potential impacts to the Calle Joaquin wetlands through preparation and implementation
of a Long-Term Wetland Monitoring Plan (refer to revisions to MM BIO-5(d)). The Long-Term
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Wetland Monitoring Plan requires annual evaluation of the condition of the wetland through the
use of a regulatory agency approved method for a minimum period of 7 years to determine and
document any degree of change to the wetland as a result of the proposed changes in site hydrology
and drainage. Monitoring shall be extended and/or reinitiated upon commencement of any future
phases of development within the FRSP as determined necessary by the City and appropriate
regulatory agencies. In the event adverse changes to the wetland over the course of Project
development (e.g., extensive ponding that results in bare soils devoid of vegetation, increased
sedimentation/erosion from the realigned channel, bank failure), mitigation would be required to
modify the Project design in coordination with the City and appropriate regulatory agencies. This
mitigation would be equally effective in mitigating potential impacts to the Calle Joaquin wetlands
and would ensure mitigation requirements are proportionate with the ultimate level of change
impact.
Comment Response A.1-77
The comment states MM BIO-1 and MM BIO-6 should be combined to ease public review and
remove duplication. As described in Section 3.4, Biological Resources, MM BIO-1 requires the
Applicant to prepare and implement a Biological Mitigation and Monitoring Plan, as well as
specifies construction-related measures and BMPs required under Project implementation. MM
BIO-6 specifies required components of the Biological Mitigation and Monitoring Plan, including
detailed timing and implementation of required habitat restoration activities under the Project. MM
BIO-1 and MM BIO-6 are distinguished by construction-related measures (MM BIO-1) versus
habitat restoration activities (MM BIO-6), so combining mitigation discussion would reduce
effectiveness of mitigation discussion. Also, the EIR intentionally employs the preparation of a
Biological Mitigation and Monitoring Plan as a vehicle for the required mitigation program,
allowing the Applicant to prepare one document that consolidates requirements for ease of
reference and review by the City. Different mitigation measures result in component of the Plan.
The comment states mitigation monitoring requirements in the EIR are inconsistent as some
mitigations specify 7 years of monitoring and others require a minimum of 5 years. Due to the
sensitivity of onsite vegetation and habitat, as well as the complexity of mitigation requirements
affected by proposed Project construction and operations, it was determined appropriate to require
a 7-year duration for mitigation monitoring. As described by the commenter, 5 years of monitoring
is required for native tree protection as deemed appropriate. The variance in monitoring duration
was deemed appropriate by applicable agencies and based on City recommendations for habitat
restoration.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
The comment states the Applicant feels requirement of maintenance weekly for three years and
quarterly thereafter is too intensive. As described in MM BIO-6, the Biological Mitigation and
Monitoring Plan, including duration of maintenance activities, would be submitted to the City for
review and approval. Due to the extent of habitat restoration efforts required by the Project site
due to special-status species and sensitive habitat extent onsite, the maintenance duration was
deemed appropriate by the City and applicable agencies.
Comment Response A.1-78
The comment states impact to mobile species (e.g., birds) would not be significantly impacted as
the Project is in a region with extensive open space areas and it is likely species will continue using
open space areas onsite. As described in the EIR, removal of habitat (e.g., native trees) for mobile
species will result in species movement to areas outside the impacted area to seek resources (e.g.,
nesting areas, food). Increased competition amongst species will occur if resources are removed,
as proposed under the Project. The comment’s understanding of biological resources and species
competition is inaccurate.
The comment further states Mouse gray Dudleya is incorrectly identified in the EIR as a moderate
to high potential to occur onsite. To address this issue, discussion of the Mouse gray Dudleya has
been updated to be described as identified within the western portion of the Project site, instead of
identifying potential to occur, as consistent with the EIR’s discussion of Special-Status Plant
Species. With regard to comments pertaining to determination of impacts to California red-legged
frog, please refer to Comment Response A.1-63.
Comment Response A.1-79
The comment restates concerns and general disagreement regarding EIR findings pertaining to
setbacks and avoidance of Chorro Creek bog thistle during Project construction. Please refer to
Comment Response A.1-74.
Comment Response A.1-80
Please refer to Comment Responses O.1-5 and A.1-76.
Comment Response A.1-81
The comment states the EIR requires further analysis on required development setback based on
the confluence of Froom Creek’s value for wildlife movement. The USDS Conservation Buffer
Guidelines recommends a minimum of a 330-foot buffer up to a maximum of 3 miles for large
predator mammal buffer areas (see USDA guidelines on conservation buffers:
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https://www.fs.usda.gov/nac/buffers/guidelines/2_biodiversity/9.html). The EIR requires a buffer
of 300 feet, which is below the minimum recommended USDA guidelines. Additionally, the site
has suitable habitat and documented observations of large mammal occurrences (e.g., mountain
lions). Therefore, the EIR’s usage of a 300-foot conservation buffer is quantitatively supported by
applicable agency guidelines. Further, the required buffer is from the centerline of the channels to
protect 150-feet on each side. That buffer includes the channel, which is up to 75 feet wide, bank,
and riparian areas. The buffer ensures consistent distances around the drainages to maintain a
viable corridor for wildlife seeking water and food between the creek and the hills. This mitigation
was directly inspired by the City’s policies about preserving ecotones and wildlife corridors. The
policies address precisely the impacts presented by the Project: development cutting off
interrelated areas that highly depend on each other to support habitat and wildlife.
Comment Response A.1-82
The comment restates concerns regarding inconsistent requirements for duration of biological
mitigation monitoring. Please refer to Comment Response A.1-77.
Comment Response A.1-83
This comment notes the Applicant’s historic architect disagrees with the conclusions in the EIR
but does not address adequacy of the environmental analysis or EIR. The comment and the
Applicant’s general disagreement with the EIR conclusions pertaining to historic resources will be
noted and provided to City decision makers for consideration.
Comment Response A.1-84
The comment states the Applicant Historic Architect disagrees of classification of structures as a
district and sites an example of a project, Sam Maloof Complex in Alta Loma. As defined by the
US Department of the Interior, a district can encompass features that lack individual distinction.
The loss of individual structures including the shed, bunkhouse, and old barn would reduce the
concentration of physical features that are significant to the character and appearance of the Froom
Ranch Dairy complex. The identified example is outside of the City limits and has varying site-
specific details, which resulted in a different finding of historic significant of structures.
Comment Response A.1-85
The comment states that neither the Applicant nor Historic Architect can guarantee publication of
an article in a scientific journal. The text of MM CR-9 has been revised to acknowledge this
limitation and require submittal to a journal under MM CR-9.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment Response A.1-86
The comment states requiring Design Guidelines for a new building under MM CR-13 prior to
issuance of a Phase 1 grading permit and approval of entitlements is premature. Comment
additionally states the commercial portion of the Project will potentially occur several years later.
As described in MM CR-13 prior to the approval of entitlements and issuance of grading permits
for Phase 1, the Applicant is required to submit design guidelines to ensure the proposed design is
consistent with City and CHC policies. Prior submittal of Design Guidelines to the City for
entitlement and grading permits is a standard cultural resources mitigation requirement for Projects
under the City’s jurisdiction.
Comment Response A.1-87
The comment states the Applicant’s Historic Architects disagreement on the findings of Section
3.5, Cultural and Tribal Cultural Resources. The comment and the Applicant’s general
disagreement with the findings of this EIR will be noted and provided to City decision makers for
consideration.
Comment Response A.1-88
The comment references prior comments made regarding EIR findings pertaining to impacts to
historic resources. Please refer to Comment Responses A.1-84 and A.1-87.
Comment Response A.1-89
The comment notes an inconsistency in the discussion of the Project site’s susceptibility to ground
rupture. The appropriate classification of the Project site’s susceptibility to ground rupture is
“moderate.” To address this comment, the inclusion of a “high threat” has been stricken from the
referenced discussion.
Comment Response A.1-90
The comment makes recommendations for clarifications in the text presented in Section 3.6,
Geology and Soils. The requested edits have been incorporated. The use of uniform foundations is
meant to generally describe the site and does not apply to any specific building codes.
Comment Response A.1-91
The comment identifies an incorrect reference to the Project’s Preliminary Engineering Geology
Investigation. The correct reference is the Project’s Soils Engineering Report. This reference has
been corrected.
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Comment Response A.1-92
The comment states that Life Plan Communities such as the proposed Villaggio are mandated by
state regulations to have well-planned and practiced Disaster Plans with emergency evacuation
procedures that would require Villaggio to conduct drills on each shift each quarter of the year on
an annual basis, while the Disaster Plan must also be reviewed and updated annually. In
acknowledgement of these existing regulations which would apply to Villaggio, Section 3.7,
Hazards, Hazardous Materials, and Wildlife has been revised with a brief summary of these
existing regulations.
Comment Response A.1-93
The comment identifies a minor text revision needed throughout Section 3.8, Hydrology and Water
Quality to correct the reference of Appendix J to Appendix H. The requested edit has been
incorporated.
Comment Response A.1-94
The comment states that of discussion of Special Floodplain Management Zone Regulations of the
City’s Floodplain Management Regulations in Section 3.8.2, Regulatory Setting implies that the
Project is in a special floodplain management zone. The discussion presented in Section 3.8.2,
Regulatory Setting regarding the City’s Floodplain Management Regulations describes that
development proposed within a 100-year FEMA floodplain is required to be raised at least 1-foot
above the specific 100-year floodplain and is subject to additional development regulations.
Though the Project is not located within a special floodplain management zone identified in the
City’s Drainage Design Manual, the Project is not designated as an in-fill site and is located within
the 100-year FEMA floodplain. As such, the Project would appear to be subject to these
regulations.
Comment Response A.1-95
The comment states that the conclusion in the EIR that development of the Upper Terrace of
Villaggio would be highly visible from public roads is incorrect and is not supported by the
analysis presented in Section 3.1, Aesthetics and Visual Resources. While the comment does not
provide any evidence or discussion to support this conclusion, the EIR analysis clearly outlines
and supports the reasoning that the Upper Terrace would be highly visible from public roads. For
instance, KVA 1 depicts a clear view of the Upper Terrace from U.S. 101. This KVA represents
just one location from a public road that the Upper Terrace is visible. Other public roadways from
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
which the Upper Terrace is either directly or clearly visible from include Calle Joaquin, LOVR,
the LOVR Overpass.
Comment Response A.1-96
The comment restates previous concerns regarding the conclusion in the EIR that development of
the Upper Terrace of Villaggio would be highly visible from public roads. Please refer to Comment
Response A.1-95.
Comment Response A.1-97
The comment restates previous concerns regarding the conclusion in the EIR that development of
the Upper Terrace of Villaggio would be highly visible from public roads. Please refer to Comment
Response A.1-95.
Comment Response A.1-98
The comment restates previous concerns regarding the conclusion in the EIR that development of
the Upper Terrace of Villaggio would be highly visible from public roads. Please refer to Comment
Response A.1-95.
Comment Response A.1-99
The comment restates previous concerns regarding the conclusions of the EIR relating to impacts
to aesthetic resources and views of recreationalists from trails within the Irish Hills Natural
Reserve. The comment does not provide any evidence or further discussion as to why impacts to
aesthetic resources and views of recreationalists would not be significant and unavoidable. The
comment will be forwarded to City decision makers for consideration.
Comment Response A.1-100
The comment states that the Applicant’s retained expert Historic Architect disagrees with the
conclusion that impacts to historic resources are significant and unavoidable. The comment does
not provide any evidence or further discussion as to why impacts to historic resources would not
be significant and unavoidable. The comment will be forwarded to City decision makers for
consideration.
Comment Response A.1-101
The comment restates previous concerns regarding emergency access and wildfire hazards. Please
refer to Comment Response A.1-92.
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Comment Response A.1-102
The comment restates previous concerns regarding emergency access and wildfire hazards and
conclusion in the EIR that development of the Upper Terrace of Villaggio would be highly visible
from public roads. Please refer to Comment Response A.1-92 and Comment Response 95,
respectively, for detailed response to each of these comment topics.
Comment Response A.1-103
The comment states that the EIR appears to present discussion of impacts from noise generated by
existing commercial uses on future residents of the Project as an environmental impact of the
Project, though this appears to be an impact of the existing environment on the Project. The EIR
discloses this information in support of analysis of the Project’s consistency with the City General
Plan and Noise Ordinance for informational purposes.
Comment Response A.1-104
The comment expresses concern and disagreement regarding the calculation of Project’s potential
population, stating that the EIR analysis utilizes a persons-per-household ratio that overestimates
the population generated by the Villaggio senior independent living components. As discussed in
Section 3.11, Population and Housing, the calculation of Project population is based on the City’s
persons per household ratio and represents an accepted and appropriate approach to calculating
potential resident population increases. Though the final resident population of Villaggio may be
lower than estimated in the EIR, the EIR presents a reasonable and conservative analysis of impacts
of the Project from increases in population based on best available data from the City and vetted
methodology.
Comment Response A.1-105
The comment restates previous concerns regarding the calculation of Project’s potential
population. Please refer to Comment Response A.1-104.
Comment Response A.1-106
The comment restates previous concerns regarding the calculation of Project’s potential population
and relates overestimation of Project’s population to an overestimation of park land needs. With
regard to calculation of the Project’s potential population, please refer to Comment Response A.1-
104. The comment goes on to state that the assessment of park land dedication of in-lieu fees is
significantly overstated as: 1) the use of the public recreation facilities by residents of Villaggio
will not meet the adopted threshold for increased use and resulting physical deterioration of
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
recreational facilities and; 2) Villaggio provides a suite of recreational facilities onsite that would
be utilized by residents of Villaggio. Section 3.12, Public Services and Recreation acknowledges
this aspect of the Project. The comment does not provide any further evidence or discussion
supporting the claims that the Project would not meet the adopted threshold for increased use and
resulting physical deterioration of recreational facilities; however, the comment will be forwarded
to City decision makers for consideration. Regarding the provision of recreational amenities as
part of the Villaggio development under the Project, the EIR acknowledges that Villaggio would
provide a variety of resident-only recreational facilities onsite to serve the needs of senior citizens;
however, the proposed facilities are only considered adequate to serve up to 93 senior residents
with special recreational needs. Based on the needs of residents of the Project, the range of
amenities proposed for Villaggio, and the requirements for amount of park land needed per 1,000
residents outlined in General Plan Parks and Recreation Element (PRE) Policies 3.13.1 and 5.0.2.
For detailed discussion of the need for additional park lands per the requirements of the City
General Plan, please refer to discussion of Impact PS-4 in Section 3.12, Public Services and
Recreation.
Comment Response A.1-107
This comment notes concern regarding timing of transportation mitigation requirements for the
Madonna Froom Ranch development phase. Final EIR mitigation language has been refined to
clarify that mitigation measures related to this development phase are not tied to recordation of the
Final VTM for the overall site, but to later recordation of the VTM for subdivisions of the Madonna
Froom Ranch area. The comment also notes that all transportation mitigation improvements should
be clearly tied to occupancy of building permits and that further clarify should be provided
regarding timing and responsibility of transportation mitigations. The refined mitigation language
in the Final EIR addresses these concerns.
Comment Response A.1-108
This comment requests a revision to MM TRANS-1 to clarify requirements for heavy haul
construction traffic routes. This mitigation language has been revised appropriately in the Final
EIR.
Comment Response A.1-109
This comment requests elimination of MM TRANS-2. This mitigation, which requires
improvements to the intersection of LOVR/U.S. 101 Southbound Ramps cannot be eliminated, as
there are direct Project impacts to this facility. See revised MM TRANS-2 language for additional
clarity on the Project’s required contribution towards these mitigation improvements.
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Comment Response A.1-110
This comment requests more clarity on mitigation responsibility for the Project for improvements
at the South Higuera/Vachell Street intersection, and related extension of Buckley Road. See
revised mitigation language in Final EIR for additional clarity.
Comment Response A.1-111
This comment requests more clarity on mitigation responsibility for the Project for improvements
at the South Higuera/Suburban Road intersection. See revised mitigation language in Final EIR
for additional clarity.
Comment Response A.1-112
This comment requests more clarity on mitigation responsibility for the Project for improvements
at the South Higuera/Tank Farm Road intersection. See revised mitigation language in Final EIR
for additional clarity.
Comment Response A.1-113
This comment requests more clarity on mitigation responsibility for the Project for improvements
at the South Higuera/Tank Farm Road intersection. See revised mitigation language in Final EIR
for additional clarity.
Comment Response A.1-114
This comment requests more clarity on mitigation responsibility for the Project for improvements
at the South Higuera/Prado Road intersection. See revised mitigation language in Final EIR for
additional clarity.
Comment Response A.1-115
This comment claims that there is no nexus between the Project and required bicycle/pedestrian
improvements along LOVR because the Project does not add significant bicycle and pedestrian
trips. LOS impacts to bicycle and pedestrian modes are not solely tied to the number of bicycle
and pedestrian trips using these facilities, but more so to the quality and comfort of these facilities
with respect to adjacent vehicular traffic. The Project contributes towards exacerbating deficient
LOS for pedestrian facilities along LOVR predominantly due to the additional vehicular traffic
added to LOVR, which worsens conditions for pedestrians and bicyclists traveling along this high-
speed roadway with little buffer between motor vehicle traffic. For this reason, there is an
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Froom Ranch Specific Plan
Final EIR
established nexus between the Project and the impacts and mitigation recommendations identified
in the EIR.
Comment Response A.1-116
This comment notes concern for Caltrans coordination and potential challenges with implementing
mitigation measures within Caltrans right of way. The Final EIR includes refinements to the
mitigation language for MM TRANS-9, which includes additional discussion of Caltrans
coordination and alternate design elements to be considered based on Caltrans input.
Comment Response A.1-117
This comment notes that improvements required under MM TRANS-10 are already under
construction. Subsequent to preparation of the Draft EIR, construction of the Madonna Class I
Path has been initiated by others. Final EIR mitigation language has been updated to clarify that
fair-share financial contribution towards this improvement through payment of Citywide
Transportation Impact Fees satisfies the Project’s mitigation obligation.
Comment Response A.1-118
Comment notes that implementation of onsite traffic calming measures should be tied to
occupancy. Per Final EIR MM TRANS-11, submittal of designs is tied to Final VTM recordation,
while implementation is tied to occupancy.
Comment Response A.1-119
This comment claims that there is insufficient nexus for required mitigation at the Foothill/LOVR
intersection. As presented in the Project Transportation Impact Study prepared by TJKM and
included in the Draft EIR Appendix J, the Project contributes six (6) percent of the cumulative
trips added to this intersection, which exacerbates deficient operations at this location. As
discussed in Final EIR MM TRANS-12, the Project is responsible for fair-share mitigation
contribution commensurate with this percentage.
Comment Response A.1-120
This comment notes concern regarding the nexus between the Project and mitigation pedestrian
mitigation requirements at the LOVR/Madonna intersection because the Project adds relatively
few new pedestrian trips to this intersection. See Comment Response A.1-115 for discussion on
how vehicle traffic contributes to degradation of pedestrian LOS. Further, the Final EIR mitigation
language has been refined to clarity that installation of lead pedestrian intervals can be facilitated
by the City and will not require a financial contribution by the Project.
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Comment Response A.1-121
This comment simply notes support for the Project’s fair-share contribution towards the Prado
Road Interchange Project through participation in the Citywide Transportation Impact Fee
Program.
Comment Response A.1-122
This comment questions the nexus between the Project and required pedestrian LOS mitigation at
the South Higuera/Tank Farm intersection. See Comment Response A.1-115 for discussion on
how vehicle traffic contributes to degradation of pedestrian LOS. Further, the Final EIR mitigation
language has been refined to clarity that installation of lead pedestrian intervals can be facilitated
by the City and will not require a financial contribution by the Project.
Comment Response A.1-123
This comment claims that there is insufficient nexus for required mitigation at the South
Higuera/Tank Farm intersection. As presented in the Project Transportation Impact Study prepared
by TJKM and included in the Draft EIR Appendix J, the Project contributes 11 percent of the
cumulative trips added to this intersection, which exacerbates deficient operations at this location.
As discussed in Final EIR MM TRANS-15, the Project is responsible for fair-share mitigation
contribution commensurate with this percentage.
Comment Response A.1-124
This comment claims that there is insufficient nexus for required mitigation at the South
Higuera/Prado intersection. As presented in the Project Transportation Impact Study prepared by
TJKM and included in the Draft EIR Appendix J, the Project contributes 53 AM and 67 PM peak
hour trips to this intersection, which exacerbates deficient operations at this location. As discussed
in Final EIR MM TRANS-7, the Project is responsible for fair-share mitigation contribution
through participation in the Citywide Transportation Impact Fee Program.
Comment Response A.1-125
This comment claims that there is insufficient nexus for required mitigation to address auto LOS
impacts along the LOVR corridor. As presented in the Project Transportation Impact Study
prepared by TJKM and included in the Draft EIR Appendix J, the Project contributes between five
(5) and 24 percent of the cumulative trips added to this intersection, depending on the specific
segment and peak hour, which exacerbates deficient operations at this location. As discussed in
Final EIR MM TRANS-16, the Project is responsible for fair-share mitigation in the form of
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
submittal of a Traffic Engineering Study to identify signal timing optimization recommendations
for City and Caltrans review and implementation.
Comment Response A.1-126
This comment claims that there is insufficient nexus for required mitigation at the LOVR/Madonna
intersection. As presented in the Project Transportation Impact Study prepared by TJKM and
included in the Draft EIR Appendix J, the Project contributes 14 percent of the cumulative trips
added to this intersection, which exacerbates deficient operations at this location. As discussed in
Final EIR MM TRANS-17, the Project is responsible for fair-share mitigation contribution
commensurate with this percentage.
Comment Response A.1-127
This comment claims that there is insufficient nexus for required mitigation at the
Madonna/Dalidio intersection. As presented in the Project Transportation Impact Study prepared
by TJKM and included in the Draft EIR Appendix J, the Project contributes six (6) percent of the
cumulative trips added to this intersection, which exacerbates deficient operations at this location.
As discussed in Final EIR MM TRANS-18, the Project is responsible for fair-share mitigation
contribution commensurate with this percentage.
Comment Response A.1-128
This comment simply confirms that MM TRANS-19, which requires installation of a raised
median along LOVR, will be implemented as part of Project frontage improvements and will be
shown in the Final Specific Plan.
Comment Response A.1-129
This comment simply notes the final emergency vehicle access points to be proposed in the Final
Specific Plan based on further discussion with the Applicant team and City staff. MM TRANS-20
in the Final EIR has been updated to reflect these plans.
Comment Response A.1-130
This comment simply describes the final proposed emergency vehicle access points to the wildland
area adjacent to the Project proposed in the Final Specific Plan based on further discussion with
the Applicant team and City staff. MM TRANS-21 in the Final EIR has been updated to reflect
these plans.
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Comment Response A.1-131
Comment notes that some of the improvements identified in MM TRANS-22 are detailed design
elements to be reflected in later construction-level documents, but may not be illustrated in detail
in the Specific Plan document. Comment noted, with no response required.
Comment Response A.1-132
This comment claims that there is insufficient nexus for required mitigation at the Foothill/LOVR
intersection. See Comment Response A.1-119 for details.
Comment Response A.1-133
This comment claims that there is insufficient nexus for required mitigation at the LOVR/Royal
intersection. As presented in the Project Transportation Impact Study prepared by TJKM and
included in the Draft EIR Appendix J, the Project contributes five (5) percent of the cumulative
trips added to this intersection, which exacerbates deficient operations at this location. As
discussed in Final EIR MM TRANS-23, the Project is responsible for fair-share mitigation
contribution commensurate with this percentage.
Comment Response A.1-134
This comment notes concern regarding the nexus between the Project and pedestrian mitigation
requirements at the LOVR/Calle Joaquin intersection because the Project adds relatively few new
pedestrian trips to this intersection. See Comment Response A.1-115 for discussion on how vehicle
traffic contributes to degradation of pedestrian LOS. Further, the Final EIR mitigation language
has been refined to clarity that installation of lead pedestrian intervals can be facilitated by the City
and will not require a financial contribution by the Project.
Comment Response A.1-135
This comment claims that there is insufficient nexus for required mitigation at the South
Higuera/Tank Farm intersection. As presented in the Project Transportation Impact Study prepared
by TJKM and included in the Draft EIR Appendix J, the Project contributes 11 percent of the
cumulative trips added to this intersection, which exacerbates deficient operations at this location.
As discussed in Final EIR Mitigation TRANS-28, the Project is responsible for fair-share
mitigation contribution commensurate with this percentage.
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Froom Ranch Specific Plan
Final EIR
Comment Response A.1-136
This comment claims that there is insufficient nexus for required mitigation at the
Madonna/Oceanaire intersection. A thorough investigation of the traffic operations analysis at this
intersection revealed that for Cumulative (2035) analysis scenarios, additional refinement was
required to more accurately reflect the unique traffic signal operations at this non-typical
intersection, which includes six approach legs and relatively complicated signal timing/phasing
plans. A revised analysis of this intersection for the Cumulative analysis scenario reveals that
potential queuing impacts at the intersection are no longer anticipated to occur. For this reason,
MM TRANS-29 is no longer warranted. The Project Transportation Impact Study and Final EIR
have been updated to reflect this.
Comment Response A.1-137
This comment claims that there is insufficient nexus for required mitigation at the
Madonna/Dalidio intersection. See Comment Response A.1-127 for details on this item.
Comment Response A.1-138
This comment notes concern that the Project VMT analysis does not fully capture the unique travel
characteristics of senior housing residential uses. See Comment Response A.1-56 for details.
Comment Response A.1-139
As with Comment A.1-138, this comment notes concern that the Project VMT analysis does not
fully capture the unique travel characteristics of senior housing residential uses. See Comment
Response A.1-56 for details.
Comment Response A.1-140
This comment notes concern regarding perceived inconsistency with VMT estimates reported in
the Section 3.13, Transportation & Traffic of the Draft EIR. See Comment Response A.1-56 for
details regarding updated VMT projections.
Comment Response A.1-141
This comment notes that the mitigation measures proposed under Impact TRANS-3, which
addresses Near-Term (2025) conditions with addition of Project traffic and traffic growth related
to other planned and approved development projects within the city, should be considered
cumulatively significant, requiring only a financial fair-share contribution by the Project. The Final
EIR transportation mitigation language has been refined to provide further clarity for
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improvements where the Project is only responsible for a fair-share financial contribution to satisfy
mitigation requirements.
Comment Response A.1-142
This comment notes concern that the Transportation Impact Study applies the City’s thresholds of
significance for intersection queuing impacts to a Caltrans intersection. While the Caltrans
Guidelines for the Preparation of Transportation Impact Studies does not articulate a specific
impact threshold for intersection queuing, the Project Transportation Impact Analysis has been
prepared with the conservative assumption that the City’s queuing thresholds would be applied to
all study intersections. The City’s queuing impact thresholds define a queuing impact based on a
condition where a project either causes or exacerbates a location where turn pocket queues are
projected to exceed the available turn pocket storage; thus, spilling into the adjacent through traffic
lane. Queue spillback can present potential safety concerns, with increased potential for rear-end
collisions. Caltrans has previously expressed concerns regarding queueing at the LOVR/U.S. 101
southbound off-Ramp intersection, which created additional justification for evaluating queueing
impacts closely at this intersection.
Comment Response A.1-143
This comment identifies potential alternate mitigation measures to address Project-related impacts
at the South Higuera/Vachell intersection. The Final EIR includes refined language for MM
TRANS-3 to identify alternate mitigation strategies that could be implemented by the Project if
the intersection improvements planned to be constructed by the Avila Ranch development are not
yet complete prior to development of the applicable phase of the FRSP.
Comment Response A.1-144
This comment suggests that there is insufficient nexus for required mitigation at the South
Higuera/Tank Farm intersection. As presented in the Project Transportation Impact Study prepared
by TJKM and included in the Draft EIR Appendix J, the Project contributes 11 percent of the
cumulative trips added to this intersection, which exacerbates deficient operations at this location.
As discussed in Final EIR MM TRANS-6a, the Project is responsible for fair-share mitigation
contribution commensurate with this percentage.
Comment Response A.1-145
This comment suggests that there is insufficient nexus for required mitigation at the South
Higuera/Prado intersection. As presented in the Project Transportation Impact Study prepared by
TJKM and included in the Draft EIR Appendix J, the Project contributes 53 AM and 67 PM peak
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Froom Ranch Specific Plan
Final EIR
hour trips to this intersection, which exacerbates deficient operations at this location. As discussed
in Final EIR MM TRANS-7, the Project is responsible for fair-share mitigation contribution
through participation in the Citywide Transportation Impact Fee Program.
Comment Response A.1-146
This comment claims that there is insufficient nexus between the Project and required
bicycle/pedestrian mitigation improvements along LOVR. See Comment Response A.1-115 for
details.
Comment Response A.1-147
Discreet comment #163
Comment Response A.1-148
This comment notes concern that the Project VMT analysis does not fully capture the unique travel
characteristics of senior housing residential uses. See Comment Response A.1-56 for details.
Comment Response A.1-149
This comment notes concern that the Project VMT analysis does not fully capture the unique travel
characteristics of senior housing residential uses. See Comment Response A.1-56 for details.
Comment Response A.1-150
This comment notes concern that the Project VMT analysis does not fully capture the unique travel
characteristics of senior housing residential uses. See Comment Response A.1-56 for details.
Comment Response A.1-151
The comment references or provides similar comments to Section 3.3, Air Quality and Greenhouse
Gas Emissions regarding VMT calculations presented throughout the EIR analysis and taken from
the Transportation Impact Study. With regard to use of VMT measures in the analysis of air
pollutant and GHG emissions, please refer to Comment Response A.1-37.
Comment Response A.1-152
The comment states that Chapter 4.0, Other CEQA Issues improperly characterizes the Project as
being of an “automobile-oriented nature” and that the VMT analysis presented in the EIR contains
errors. Please refer to Comment Response A.1-37, Comment Response A.1-138, Comment
Response A.1-139, and A.1-140.
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Comment Response A.1-153
The comments states that the EIR could acknowledge that many future residents of Villaggio
would come from the existing City resident population that would move out of their existing homes
within the City, making these homes available and adding to the City’s housing inventory. The
referenced discussion in Chapter 4.0, Other CEQA Issues has been revised to acknowledge the
Applicant’s current deposit list and potential origination of future residents of the Project.
However, it is also noted in the revised discussion that though future residents of the Project are
likely to be existing residents of the City, the action of moving to the Project and vacate their
homes has potential to attract new residents to the City from outside the existing population. Given
this circumstance and the fact that the origin of future residents of the Project cannot reliably be
anticipated, the EIR continues to assume that the Project will result in a residential population
growth of approximately 1,231 persons.
Comment Response A.1-154
The comment requests Figure 5-2 of the EIR be revised to exclude the 150-elevation line as the
line implies a height limit rather than a development area limitation. Figure 5-2 has been revised
as requested by the comment.
Comment Response A.1-155
The comment expresses concerns regarding the inclusion of an emergency access route to Calle
Joaquin from the Lower Area of Villaggio as: 1) the area is subject to inundation during high flor
storm events; 2) Calle Joaquin is a cul-de-sac street having only one way out toward LOVR; 3)
design of the access at this location may force encroachment into an existing County Open Space
Easement area and construction of a retaining wall in the vicinity of Froom Creek; and 4) require
construction of a bridge at the confluence of Drainages 1, 2, and 3 and Froom Creek. An additional
emergency access road connecting from the Lower Area of Villaggio to Calle Joaquin could
feasibly be accomplished through the proposed stormwater detention basin area such that impacts
to Froom Creek and egress on the existing County Open Space Easement could be minimized or
avoided. In addition, the access road could be designed such that it does not require construction
of a retaining wall in the vicinity of Froom Creek. The feasibility of the design and alignment of
the proposed emergency access road at this location is based upon input provided by the Applicant
and the City. Nevertheless, the final design of this access would be subject to more detailed
engineering/design and approval by the City and SLOFD as part of the City’s permitting process,
if this alternative is approved by the City. A potentially feasible conceptual alignment of this
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
emergency access roadway is depicted in Figure 5-1, while potential design of the access roadway
is depicted in Figure 5-3.
With regard to use of Calle Joaquin, which is a cul-de-sac, evacuees along this route would
ultimately funnel to LOVR further south and would connect to U.S. 101. Access to the Project site
is limited due to existing roadway design, adjacent developments and topography. As such, there
is no ideal solution for emergency access and each approach involves tradeoffs. Emergency
responders could access this location directly from Calle Joaquin via LOVR. Evacuees or
emergency responders would not be directed towards the cul-de-sac at the end of Calle Joaquin.
Development of an emergency access road at this location would provide more direct access from
Calle Joaquin compared to the proposed Project, which proposes access be provided via the
Mountainbrook Church property at the end of the Calle Joaquin cul-de-sac. Such an access would
serve well for fire evacuation which should not be affected by flooding as most fires occur during
the dry season.
Comment Response A.1-156
The comment expresses concern regarding location of the public trailhead park within the area of
the existing quarry as being in conflict with the intent of restoring and adaptively reusing the
historic structures. Relocation of the trailhead park to this location would not hide the park and
restored historic structures from the general public as their destination would be the park. Residents
of the development who visit the park and the Irish Hills would also experience the restored historic
structures. Placing the restored buildings at the end of a cul-de-sac would not increase the difficulty
of adaptive reuse, particularly given the attractive view location adjacent to the Irish Hills. This
location would also provide better access to public trails within the Irish Hills Natural Reserve
compared to the Project and would better align with the City’s adopted policies prohibiting
development above the 150-foot elevation line compared to the Project. The buildings would be
relocated and reconstructed on graded terrain to maintain the historic configuration and
proportional relationship of the buildings to each other In addition, location of the trailhead park
at this location is not believed to hinder emergency access, as the trailhead park would continue to
be directly accessible via the proposed internal circulation.
Location of the trailhead park in this location would also reduce impacts associated with location
of residences within close proximity to high wildfire hazard areas compared to the Project. Though
there is potential that historic structures would be constructed with less fire-resistant materials than
proposed multi-family residences, removal of high-density residences from this location would
provide a greater level of safety for residents from wildfire hazards, even if there is some increased
exposure for historic structures.
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Regarding location of residences nearer to the Irish Hills Plaza rather than the existing quarry area
under Alternative 1, additional noise measurements collected by the Applicant since release of the
Draft EIR at this location and which have been included in Section 3.10, Noise demonstrate that
noise generated by existing uses of the Irish Hills Plaza while represented a nuisance for future
residential uses if they were located in the area of the trailhead park proposed under the Project.
Any such impacts could be mitigated through construction of a berm and/or sound wall. With
regard to safety, relocation of the park above the 150-foot elevation is not anticipated to result in
increased safety concerns.
Comment Response A.1-157
This comment references prior comments regarding proposed emergency access along the
drainage basin to Calle Joaquin. Please refer to Comment Response A.1-55.
Comment Response A.1-158
This comment references prior comments regarding proposed emergency access along the
drainage basin to Calle Joaquin. Please refer to Comment Response A.1-55.
Comment Response A.1-159
This comment references prior comments regarding proposed emergency access along the
drainage basin to Calle Joaquin. Please refer to Comment Response A.1-55.
Comment Response A.1-160
This comment references prior comments made to Section 3.11, Population and Housing
regarding use of population estimates that are too high and do not accurately reflect the proposed
Project or alternatives population and housing impacts analysis. Please refer to Comment Response
A.1-104.
Comment Response A.1-161
This comment references prior comments made to Section 3.1, Aesthetics and Visual Resources
regarding characterization of U.S. 101 as a designated State scenic highway. Please refer to
Comment Response A.1-3. Appropriate discussions provided in Chapter 5.0, Alternatives have
been revised accordingly.
Comment Response A.1-162
The comment states that no individually eligible buildings are proposed for removal under the
proposed Project or Alternative 1, per the Froom Ranch Historic Resource Assessment prepared
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Froom Ranch Specific Plan
Final EIR
for the Project by FirstCarbon Solutions and Chattel, Inc. As discussed in Section 3.5, Cultural
and Tribal Cultural Resources, and summarized in Section 5.4.2.2, Alternative 1 – Clustered
Development Below the 150-foot Elevation Alternative (the Actionable Alternative), the Project
and Alternative 1 would relocate and adaptively reuse (within the proposed public park) four
Froom Ranch Dairy buildings (i.e., main residence, creamery, dairy barn, and granary) that are
eligible for listing on the NRHP, CRHR, and City’s Master List of Historic Resources. The main
residence would be relocated and rehabilitated, and the creamery, dairy barn, and granary would
be disassembled, relocated, and reconstructed, while the shed, bunkhouse, old barn, and non-
historic storage building and outhouse structures would be demolished. While the shed,
bunkhouse, and old barn are not individually significant historic resources, they contribute to the
historic setting and integrity of the Froom Ranch Dairy complex based upon their association with
the Froom family, connection to the historic dairy operation, character-defining features of
Craftsman-style or vernacular architecture, and good integrity. The Applicant-prepared HRE
characterizes these structures as secondary contributors to the historic district and concludes their
demolition would not affect the integrity or historic value of the historic district; however, per
NRHP Bulletin 15, a district possesses a significant concentration, linkage, or continuity of site,
buildings, structure, or objects united historically or aesthetically by plan or physical development.
The loss of the shed, bunkhouse, and old barn would reduce the concentration of physical features
that make up the character and appearance of the Froom Ranch Dairy complex. While the proposal
for relocation and reconstruction of the Froom Ranch Dairy complex would continue to retain
sufficient integrity to convey its significant association with the dairy industry and the Froom
family, the Project would result in the loss of historic materials and character defining features that
existed during the resource’s period of significance. With application of the City’s Historic
Preservation Guidelines criteria for historic resources, Section 14.01.070 (3)(C), demolition of the
shed, bunkhouse, and old barn would reduce the degree to which the Froom Ranch Dairy complex
retains its design, setting, workmanship, and “feeling” (aesthetic or historical sense of a particular
period). Therefore, the EIR characterizes the loss of these structures as a potential impact on the
character and quality of the Froom Ranch Dairy complex historic district. Please refer to discussion
of Impact CR-3 in Section 3.5, Cultural and Tribal Cultural Resources for detailed discussion of
these impacts.
Comment Response A.1-163
The comment references prior comments made to Section 3.7, Hazards, Hazardous Materials, and
Wildlife regarding impairment of emergency response. Please refer to Comment Response A.1-92.
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Comment Response A.1-164
The comment references prior comments made to Section 3.3, Air Quality and Greenhouse Gas
Emissions regarding GHG calculations. Please refer to Comment Responses above.
Comment Response A.1-165
The comment references prior comments made to Section 3.13, Transportation and Traffic
regarding provision of emergency access to the Irish Hills Natural Reserve and the indication of
emergency vehicle access at to surrounding properties. Please refer to Comment Response A.1-
129.
Comment Response A.1-166
The comment references prior comments made to Section 3.5, Cultural and Tribal Cultural
Resources regarding the loss of contributing structures to the Froom Ranch Dairy complex historic
district. Please refer to Comment Response A.1-162.
Comment Response A.1-167
The comment references prior comments made to Section 3.13, Transportation and Traffic
regarding provision of emergency access to the Irish Hills Natural Reserve and the indication of
emergency vehicle access at to surrounding properties. Please refer to Comment Response A.1-
129.
Comment Response A.1-168
The comment references prior comments made to Section 3.4, Biological Resources regarding lack
of quantifiable rational for proposed buffer distances around Drainage 1, 2, 3, and Froom Creek.
Please refer to Comment Response A.1-81.
Comment Response A.1-169
The comment references prior comments made to Section 3.5, Cultural and Tribal Cultural
Resources regarding the loss of contributing structures to the Froom Ranch Dairy complex historic
district. Please refer to Comment Response A.1-162.
Comment Response A.1-170
The comment states that the solid waste generation factors utilized in the analysis of solid waste
impacts for Alternative 1 incorrectly applies a waste generation rate typical for hospital uses for
the proposed health care units of the Villaggio development, and should instead utilize the solid
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
waste generation factor for the Nursing/Retirement Home use. Please refer to Comment Response
A.1-147.
Comment Response A.1-171
The comment references prior comments made to Section 3.13, Transportation and Traffic
regarding provision of emergency access to the Irish Hills Natural Reserve and the indication of
emergency vehicle access at to surrounding properties. Please refer to Comment Response A.1-
129.
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8.4.6 Oral Responses
8.4.6.1 Cultural Heritage Commission Hearing – November 18, 2019
Public Commenter – Commissioner Ulz
Comment OT.1-1
Commission Ulz requests clarification on whether historic resources are considered as a district,
individual resources, or as a multi-component resource in the FRSP and EIR. Commission Ulz
suggests multi-component resource consideration may be the most effective classification.
Response
Thank you for your comments regarding the FRSP and EIR. As described in EIR Section 3.5,
Cultural and Tribal Cultural Resources, the Project site contains the historic Froom Ranch Dairy
Farm (P-40-040991), including seven existing contributing structures associated with the historic
dairy and Froom family. Four structures (i.e., main residence, creamery, dairy barn, and granary)
are considered significant historic resources as individual structures. These four structures together
with the three other contributing structures (i.e., the old barn, shed/storage building, and
bunkhouse) constitute an eligible historic district under the City’s Historic Preservation Ordinance
and the CRHR. The landscape and layout of these seven buildings comprising the Froom Ranch
Dairy complex is historically significant under CEQA. The Froom Ranch Dairy complex, as
described in the EIR complies with applicable guidelines for historical resources, including the
City’s Historic Preservation Program Guidelines, The City’s Historic Preservation Ordinance, and
CRHR so the EIR’s analysis is consistent with existing City policy and regulations. Per City
guidelines, it appears as the Froom Ranch Dairy complex may be classified as a historic district;
however, the City has discretion of classification under the Project approval process.
Comment OT.1-2
Commission Ulz recommends MM CR-8 require native plantings and seek consultation guidance
from tribal representatives. The comment states monitoring is not a mitigation, so the EIR should
more clearly state how the City is working with Native Americans.
Response
Based on the comment’s recommendation, the word “native” has been incorporated to describe
the vegetation requirements in the MM CR-8 of the EIR. The Applicant as well as the City will
continue to consult Native American tribal representation to protect sensitive resources throughout
the ongoing process. Regarding consultation with local tribes on the proposed Project, please refer
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
to Section 3.5, Cultural and Tribal Cultural Resources. Presented therein is a detailed summary
of the Native American consultation process conducted by the City for the proposed Project, as
well as the results of the consultation process.
Comment OT.1-3 Commissioner Ulz states MM CR-10 does not provide a HABS level, and
photography alone is not sufficient to meet HABS guidelines. Commissioner Ulz recommends
selecting an appropriate HABS level based on the significant of each resource to be documented
and follow the NPS recommendations. Additionally, the comment states the HABs documentation
should be treated as pertaining to the entire complex to shore functional relationships between
buildings.
Response
As described in Section 3.5, Cultural and Tribal Cultural Resources, MM CR-10 requires a HABS
Level II documentation to be completed by a qualified professional photographer. Further, all
documentation components under MM CR-10 would be completed in accordance with applicable
guidelines including the Guidelines for Architectural and Engineering Documentation, which is
consistent with photograph-based HABS. The Project would additionally be required to provide
the National Park Service with original, archivally-sound negatives and prints of the HABS.
Comment OT.1-4 Commission Ulz recommends the Project include documentary tools
beyond HABS, including oral histories and/or LIDAR/photogrammetry via drones to generate 3D
documentation.
Response
MM CR-10 is in alignment with applicable HABS documentation standards as defined under the
Guidelines for Architectural and Engineering Documentation. Nevertheless, language has been
incorporated to MM CR-10 to identify additional surveys such as oral histories, LIDAR surveys,
and/or photogrammetry may be complete.
Comment OT.1-5 Commissioner Ulz states under MM CR-11 pamphlets are an ancillary vehicle
for distributing an interpretive message, whose primary form should be semi-permanent and
presented onsite. The comment recommends focusing on the development of an interpretive plan
for the Froom Ranch Dairy complex and/or traditional tribal uses that encompass a multi-
disciplinary approach to interpretation, as well as installation of signage for mitigation.
Additionally, the comment suggests the measure should be the interpretive plan, not simply the
pamphlet. If digital content will be available, consider reconfiguration into a mobile-friendly form
to accompany physical signage.
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Response
Based on the comment, language has been added to MM CR-11 to require the Applicant to
document the potential historic district and its cultural and architectural heritage by additional
means (e.g., signage, interpretive plan, mobile-friendly content), if deemed mandatory by the City.
As discussed in MM CR-11, digital copies of the pamphlets would be available to ensure
information is available permanently to the public and decision makers.
Public Commenter – Commissioner Papp
Comment OT.2-1 Commissioner Papp recommends clarification in the EIR of how the elevation
changes at the quarry location.
Response
The FRSP is a programmatic analysis of potential impacts related to changes in land uses based
on the City’s LUE requirement for adoption of a Specific Plan prior to development; therefore, the
EIR does not need to include specific site elevation analysis. However, based on information
provided by the property owner and Applicant, John Madonna, the quarry operation pre-dates the
Madonna purchase of the property. The quarry operational elevations appear to have varied by
approximately 50 feet over time since the Madonna purchase in 1976. It is estimated that, since
that time, the maximum elevation was approximately 190 feet and the lowest elevation of the
quarry was approximately 135 feet.
Public Commenter – Commissioner Matteson
Comment OT.3-1 Commissioner Matteson recommends overlaying site plans over satellite or
aerial imagery to visually identify where buildings would be located in comparison to their existing
location.
Response
As described in Comment Response OT.2-1, the FRSP would serve as a programmatic analysis of
potential impacts related to changes in land uses. The current locations of the existing buildings
are shown in Figure 2-2 of the EIR. Under Alternative 1, the buildings would be relocated to the
west approximately 400 feet up the hill. They would be reconstructed above the 150-foot elevation
in the area shown on Figure 2-2 as the quarry. A detailed park plan has not yet been developed and
the EIR analysis is programmatic. Therefore, the proposed locations of the structures are intended
to be approximate.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Public Commenter- Commissioner Haydu
Comment OT.4-1 Commissioner Haydu recommended having the third unrecorded site evaluated
to the same level as the previous two sites through the preparation of a Phase 1. The comment
states further evaluation may be necessary to provide a clear and accurate baseline to identify
appropriate mitigation and confirm the site would be avoided.
Response
The unrecorded potential site comprising three mapped stone isolates was identified through EIR
analysis and is addressed through MM CR-1 and MM CR-2, which would require 50-foot buffers
to protect the potential site during construction. The location of the potential site outside the
FRSP’s proposed development footprint makes this mitigation program feasible. However,
Alternative 1, which is the Environmentally Superior Alternative, would avoid impacts to the
potential unrecorded site by eliminating development above the 150-foot elevation line in the
Upper Terrace of Villaggio. Under Alternative 1, no earthwork is proposed within 50 feet of the
site. As such, additional work to record this site is not required to support the findings of the EIR.
Public Commenter – Commissioner Papp
Comment OT.5-1 Commission Papp requests discussion of the impacts of a modified
Alternative 1 that proposes keeping the proposed public park at the Applicant’s preferred location.
Commissioner Papp asks if this discussion should be included in the EIR.
Response Impacts associated with the location of the proposed park in the Applicant’s
preferred location is evaluated throughout the EIR as a component of the proposed Project.
Additional evaluation of the relocation of the proposed park to the Applicant’s preferred location
as a changed component of Alternative 1 (which the Applicant has publicly stated they intend to
pursue) is not necessary to include in the Final EIR because impacts associated with its location
have already been fully analyzed and disclosed in the document, both at the Applicant’s preferred
location under the proposed Project and in the area above the 150-foot elevation under Alternative
1. Any variation of Alternative 1 that relocates the park to the Applicant’s preferred location is not
required to be added to the EIR because both park locations have already been evaluated and
disclosed in the document.
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8.4.6.2 Parks and Recreation Commission Hearing – December 4, 2019
Public Commenter – Parks and Recreation Commission
Comment OT.6-1 The Parks and Recreation Commission majority agreed Villaggio should be
given some number of park acreage credits for providing the Froom Creek Trail.
Response
The analysis of Project demand for parks and recreational facilities presented in Section 3.12,
Public Services and Recreation is based upon standard City methodology and General Plan
policies, such as Policy 3.13.1, which requires that neighborhood and community park facilities
be provided at a ratio of 10 acres of parkland per 1,000 persons in expansion areas, and Policy
3.15.3, which requires all residential annexation areas to provide neighborhood parks at a rate of
five acres per 1,000 residents. The EIR analysis presented in Section 3.12, Public Services and
Recreation acknowledges the credit provided by the Project’s proposed recreational facilities such
as the Froom Creek Trail; however, provision of a trail does not satisfy City General Policies for
provision of park area. The EIR, therefore, identifies the need for provision of additional park
space up to the necessary amount required under existing City General Plan policies (refer to MM
PS-1 and MM PS-2). However, the mitigation measures are developed in such a way that would
allow the City discretion in the final amount of park area to be provided. If the City deems the
recreational facilities proposed under the Project satisfy some portion of the requirements under
the City General Plan, the City may require less additional park acreage be provided by the
Applicant.
8.4.6.3 Active Transportation Committee Hearing – December 11, 2019
Public Commenter – Active Transportation Committee
Comment OT.7-1 The EIR struggles with a lack of well laid out maps showing proposed
features. The Final EIR needs more maps, including one that shows Collector A.
Response
The EIR includes several figures depicting each of the proposed transportation improvements and
roadways proposed under the Project. For a figure depicting preliminary design of the Commercial
Collector A roadway, please refer to Figure 2-11.
Comment OT.7-2 The Final EIR should include a reference to the Avila Ranch Development
Plan for the proposed Buckley/Vachell intersection improvement requirement.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Response
The Final EIR Section 3.13, Transportation and Traffic includes expanded discussion regarding
improvements anticipated to be constructed as part of the Avila Ranch development located to the
east across U.S. 101 from the Project.
Comment OT.7-3 Costco/Target/LOVR/Froom Ranch Way – There are no crosswalks
proposed in all directions. Queue time is double that for cars, but the impact is not addressed in
mitigation.
Response
The City does not have an adopted threshold of significance that requires all legs of a signalized
intersection to include pedestrian crossings. The City evaluates potential impacts to pedestrian
travel at intersection based on the Highway Capacity Manual Pedestrian LOS methodology. The
methodology considers factors such as sidewalk width, length of pedestrian crossings and delays
for pedestrians. Based on this methodology, the absence of a pedestrian crossing at a single leg of
an intersection does not necessarily result in a LOS impact. No Project-related pedestrian LOS
impacts were identified in the transportation impact study for the intersection of LOVR/Froom
Ranch Way. That said, there are improvements already planned or proposed as part of the Project
that will improve pedestrian crossing convenience and safety along the LOVR corridor. As part of
the San Luis Ranch development, the LOVR/Froom Ranch Way intersection is to be reconstructed
as a protected intersection, which includes addition of high-visibility crosswalk markings and
pedestrian refuges to shorten pedestrian crossing distances. As part of the Project proposal and
mitigation requirements, the LOVR/Auto Park Way intersection is to be signalized, with
pedestrian refuge islands, high-visibility crosswalks, lead pedestrian crossing intervals, and
signalized pedestrian crossings at each leg of the intersection.
Comment OT.7-4 The location of the proposed bus stop is 0.5-mile away and will impact
ridership. This is a big red flag about why transit is not closer, particularly to the Villaggio
population.
Response
The proposed Project includes addition of a new bus turnout and SLO Transit stop at the southwest
corner of the LOVR/Auto Park intersection, adjacent to the Project site. This stop will be within a
five-minute walk for most residents of the FRSP Area. Further, the Villaggio development will be
operating a free shuttle service for Villaggio residents and employees, offering and additional
option for users to connect with other local transit services.
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Comment OT.7-5 The Draft EIR is confusing regarding who is responsible to pay for
transportation improvements. Are there enough parties to pay for completion of identified
mitigation?
Response
The Final EIR transportation mitigation discussion has been refined to provide more clarity
regarding timing and responsibility for mitigation improvements.
Comment OT.7-6 The Healthy Communities Committee wants to see an increase in mode
share. Is there an opportunity to increase (e.g., cycle tracks, walking easier than driving, more
progressive mitigation measures)?
Response
The Project proposal and proposed mitigation measures include numerous physical improvements
and transportation demand management programs that are intended to increase access and use of
sustainable transportation options. These improvements include installation of protected bike lanes
(“cycle tracks”), construction of a bicycle protected intersection at LOVR/Auto Park, more
convenient access for pedestrians and bicyclists than for drivers between the Project site and
adjacent land uses. As discussed in previous comments, the estimated Project trip generation by
mode used in the Project Transportation Impact Study is conservative in nature and based on
existing mode share trends within the City, not necessarily based on the mode share potential with
effective implementation of new planned and proposed infrastructure and programs.
Comment OT.7-7 Need additional clarity that shows the features of the mitigation measures
regarding the bus stop and bike paths. The EIR needs additional maps. The EIR should clarify
what is proposed regarding protected bike lanes and pedestrian crossings as a priority.
Response
The Final EIR includes additional graphics and description of the proposed new bus stop location
and recommended multimodal transportation improvements.
Comment OT.7-8 Move the definition of Class I bike path up before first mention of Class I
bike path.
Response
The text in Section 3.13, Transportation and Traffic has been revised as requested by the
commenter.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment OT.7-9 The EIR should clarify whether wait times are for cars only. The EIR should
also include wait times for pedestrians and bicyclists.
Response
Pedestrian LOS is the performance measure adopted by the City for evaluation of potential
pedestrian impacts at intersections. Pedestrian LOS grades are based on a metric called “LOS
Score”, which is calculated based on a combination of factors that affect the pedestrian
environment, including intersection crossing delays, sidewalk width, presence of street trees or
other physical buffers, and intersection crossing distance. Similarly, Bicycle LOS at intersections
is calculated based on several factors, including delays at intersection crossings, volume and speed
of adjacent vehicle traffic lanes, bicycle facility width and type (i.e. Class I, II, III or IV bikeway).
Comment OT.7-10 The EIR should include a separate bike facility during construction.
Response
The most recent update to the City’s Standard Specifications and Engineering Standards includes
additional construction traffic control requirements to maintain safe and efficient bicycle and
pedestrian access through work zones. The updated requirements include a stipulation that
precludes closure of bike lanes and sidewalks on higher-speed/volume streets unless no other
option is feasible. For example, the updated standards require closure of adjacent vehicle travel
lanes on multilane streets with speed limits of 35 mph or greater in order to retain bicycle lanes.
Similarly, the updated standards require addition of physically-protected temporary pedestrian
walkways when sidewalk closures are required for an extended period.
Comment OT.7-11 The EIR is hard to read. There are concerns about fair-share versus actual
implementation. Suggest creation of a fund with a formula that considers the Climate Action Plan
and mode increases (developer pays money towards program/fund).
Response
See Comment Response OT.7-5.
8.4.6.4 Planning Commission Hearing – December 12, 2019
Public Commenters – Sherry Eisenlen and David Richards
Comment OT.8-1 Concern about the Villaggio park acreage calculations/requirements. It is
an unfair burden on the Project and Project costs.
Response
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The analysis of Project demand for parks and recreational facilities presented in Section 3.12,
Public Services and Recreation is based upon standard City methodology and General Plan
policies, such as Policy 3.13.1 The Parks System which requires the City develop and maintain a
park system at a rate of 10 acres per 1,000 residents, and Policy 3.15.3 Neighborhood Parks
requiring all residential annexation areas provide neighborhood parks at a rate of five acres per
1,000 residents. The EIR analysis presented in Section 3.12, Public Services and Recreation
acknowledges the credit provided by the Project’s proposed recreational facilities such as the
Froom Creek Trail; however, provision of a trail does not satisfy City General Policies for
provision of park area. The EIR therefore identifies the need for provision of additional park space
up to the necessary amount required under existing City General Plan policies (refer to MM PS-1
and MM PS-2). However, the mitigation measures are developed in such a way that would allow
the City discretion in the final amount of park area to be provided. If the City deems the
recreational facilities proposed under the Project satisfy some portion of the requirements under
the City General Plan, the City may require less additional park acreage be provided by the
Applicant.
Public Commenter –Gary Havas
Comment OT.8-2 The City has established a goal for carbon neutrality by 2035. Not sure the
EIR goes far enough to achieve this. The Project could be precedent setting for GHG reductions.
Response
The EIR analysis of Project impacts from GHG emissions in Section 3.3, Air Quality and
Greenhouse Gas Emissions acknowledges the City’s efforts in updating the Climate Action Plan
and GHG inventory, as well as the City’s declaration to adopt a target for citywide carbon
neutrality by the year 2035. Due to the significance of the City’s intent to achieve carbon neutrality
and its exceedance of the GHG emissions targets established under current State law, the analysis
of impacts from the Project’s stationary GHG emissions is based upon consistency with this
stringent new target. To meet this target, the EIR identifies several mitigation measures requiring
the Project implement a variety of strategies and measures to achieve net zero emissions for
operational stationary-source emissions, and reduction of mobile-source emissions to the
maximum extent feasible. The analysis presented in this EIR with regard to analysis of compliance
with the City’s intent to achieve carbon neutrality by 2035 is highly stringent and unlike any other
analysis that has been conducted within the City to date.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Public Commenter –Lisa Schott, Los Verdes
Comment OT.9-1 Los Verdes representative reiterates the concerns of traffic circulation, air
quality, creek impacts, noise, flooding, and road improvements. The commenter wants to be
certain all environmental impacts are mitigated in a way that will benefit the community and
surrounding neighborhoods. The commenter provides the following traffic-related concerns: 1)
LOVR is already greatly impacted and notes a recent fatality on LOVR, 2) the right turn-lane onto
U.S. 101 is inadequate and causes traffic back up on LOVR, 3) Higuera is contested and too
narrow, so mitigation is necessary, and 4) trucks are tearing up the roads. Additionally, the
commenter states dust and dirt are not sufficiently mitigated and trees at San Luis Ranch were
butchered. The City’s Climate Action Plan includes tree planting, but it will take many years to
see benefits of the Climate Action Plan.
Response
The comment notes that recent approved development within the City has resulted in cumulative
impacts to traffic, fugitive dust emissions, biological resources, changes in hydrology, noise, and
safety. The City understands these issues and pursuant to the requirements of CEQA, fully
evaluated the direct impacts of the Project individually, as well as the cumulative impacts of the
Project and other development within the City. These impacts are evaluated in detail within each
of the respective resource analysis sections of the EIR. Where significant direct or cumulatively
significant impacts the Project are identified, the EIR identifies and requires all feasible mitigation
to reduce impacts to the extent feasible. See Comment Response O.5-1 through O.5-4 for detailed
discussion of traffic concerns for LOVR and Higuera Street.
Public Commenter –Bill Waycott, CNPS
Comment OT.10-1 The comment states that San Luis Obispo is a unique location, surrounded
by a series of serpentine hills that are not found elsewhere in the world with a variety of very rare
plant species. The representative emphasizes a need to consider the long-term implications of the
Project as it is the last area in front of the Irish Hills that remains undeveloped. Additionally, the
commenter states water flow is significant issue as well as wetlands/creek/steelhead impacts.
Commenter urges consideration of whether the Project would be the right choice for future
generations. Additionally, the creek leads to storm drains and flood control is a concern. Comment
states CNPS supports Alternative 1 to the long-term responsibility of protecting the area.
Response
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The FRSP and EIR acknowledges San Luis Obispo and specifically the serpentine hills in the Irish
Hills Preserve are unique and provide significant visual and biological value to the community and
region at large. The EIR recognizes the proposed Project would be potentially inconsistent with
the City’s hillside protection policies regarding the limitation to development to below the 150-
foot elevation line in Section 3.9, Land Use and Planning. While the EIR identifies a potential
inconsistency for the Project with this adopted policy, the EIR includes analysis of Alternative 1,
which would be designed to be consistent with City policies for hillside development. As analyzed
in Chapter 5.0, Alternatives, Alternative 1- Clustered Development Below the 150-foot Elevation
would involve the consolidation of proposed development towards the lower elevation areas of the
site below the 150-foot elevation line to ensure consistency with City hillside development
policies. Due to Alternative 1’s consistency with these City policies, as well as redesign of the
Project to address or reduce significant impacts associated with the Project, Alternative 1 is
identified as the Environmentally Superior Alternative. Selection of Alternative 1 will reduce the
long-term implications of development in the vicinity of the Irish Hills Natural Preserve while
maintaining open space for future generations. CNPS support of Alternative 1 will be provided to
City decision makers in the planning process.
Please refer to additional responses to CNPS written comments (Comment Response O.1-2 and
O.1-3 related to flooding and waterflow).
Public Commenter – David Chipping
Comment OT.11-1 The comment expresses concern regarding the Project hydrology report’s
conclusions that hydrology impacts can be mitigated. The comment states historic flow of the
Froom Creek did not turn within the Project site until it was diverted in the 1940s. The current
flow is one-foot descent per every 100 feet. Froom Creek, LOVR ditch, and the Irish Hills will
carry flow into the jurisdictional wetlands and the existing stormwater basin would be removed
from the site, which may result in flash flooding. The comment states in Appendix H on page 156
details show during a 2-year storm event, current flows into the wetland, which are 253 cfs would
increase to 518 cfs and over 1,000 cfs at high storm events. David Chipping states there is no
analysis on where the water will go and does not include an assessment of the exit drainage onsite.
Additionally, there is a new wall on the U.S. 101 on-ramp, which will block flows, and the Taco
Temple may be impacted based on its location.
Response
Please refer to responses to comments I.1-3 through I.1-12.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Public Commenter – Neil Havlik
Comment OT.12-1 The comment expresses concern regarding unacceptable environmental
impacts imposed on the community and the potential of a negative precedent by changing the 150-
foot development limit. The commenter supports the Applicant’s intent to move forward with the
Project under Alternative 1, which avoids development in the Upper Terrace; however, the
commenter feels all areas should be preserved above 150 feet. Additionally, realignment of the
Froom Creek is inconsistent with the Creek Setback Ordinance. The commenter addresses there is
a potential legal issue with adjusting the boundaries of the existing conservation easement on the
property and also asserts that it would set a negative precedent.
Response
Please refer to Comment Response OT.10-1. As described by the comment, Alternative 1 would
consolidate all development below the 150-foot elevation line, except the public trailhead park.
Regarding setbacks from the realigned Froom Creek, the Project’s potential consistency or
inconsistency with policies or requirements of the City’s Creek Setback Ordinance are discussed
in Section 3.9, Land Use and Planning. As discussed in Section 3.2, Agricultural Resources, the
2010 annexation and development of Prefumo Creek Commons project across LOVR from the
Project site established an open space and agricultural conservation easement of a 7.1-acre portion
of the Project site to meet LAFCO Policy 2.9.12, Agricultural Policies. The easement is managed
by the City and the easement language specifies that it may be amended with written consent of
Irish Hills Plaza, LLC, and the City. The existing onsite open space and agricultural easement
would be amended through dedication of an equivalent continuous area of comparable soils and
open space currently conserved under this easement, which meets the legal requirements of the
agricultural easement established by the City. Please refer to Section 3.2, Agricultural Resources
and Section 3.9, Land Use and Planning for a comprehensive analysis of the easement.
Public Commenter –Brian Ackerman
Comment OT.13-1 The comment requests consideration of a balance of environmental impacts
and the needs of seniors as the facility will need to be dynamic to community needs.
Response The comment does not pertain to the analysis of the FRSP or EIR; however, the
Project includes features to serve seniors (e.g., health care facilities, Senior Shuttle Service) while
maintaining Project consistency with environmental protection. The comment will be provided to
City decision makers for consideration.
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Public Commenter – Commissioner McKenzie
Comment OT.14-1 The comment suggests adding a trail map to show how close the Project is
to the open space trails.
Response
Figure 3.12-1 has been revised to include existing trails within the vicinity of the Project.
Comment OT.14-2 The comment requests addition of a provision to delay LOVR vegetation
removal to the greatest extent possible to screen construction activities. The comment states
additional language is needed on robust riparian planting to achieve visual screening along Froom
Creek.
Response
MM VIS-1 has been revised to include requirements to delay removal of vegetation associated
with LOVR to the greatest extent feasible to screen construction activities. Additional language
has also been added to require robust riparian planting to achieve visual screening along Froom
Creek.
Comment OT.14-3 The comment requests addition of reference to using muted, earth tone
colors, and brown roofs to recede into the background, especially for development above 150 feet.
Response
The FRSP currently includes policies and programs requiring limitations on use of retaining walls,
locating development behind natural landforms, and use of earth tone colors for main building
walls and roofs to reduce visual intrusion, especially for development above the 150-foot elevation
limit. See FRSP Program 3.5.2a.
Comment OT.14-4 The comment asks if it is appropriate to require visual treatment of retaining
walls above a certain height as well as fencing. Comment states white is very bright, so at what
height should treatments use dark colors or muted earth tones.
Response
Please refer to response to Comment OT-14.3.
Comment OT.14-5 The comment asks if there is a Class I impact to air quality and GHG
emissions, is it appropriate to include requirements for solar or other measures to reduce emissions
(e.g., solar on sun-facing roofs) and offset impacts.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Response
The EIR in Section 3.3, Air Quality and Greenhouse Gas Emissions does identify significant and
unavoidable impacts associated with GHG emissions. Please refer to discussion under Impact AQ-
3. To reduce impacts, the EIR identifies a variety of mitigation measures requiring the Project
implement strategies to reduce GHG emissions, including installation of solar arrays and use of
carbon-free energy supplies. Refer to Response to Comment OT.8-2, above.
Comment OT.14-6 The comment suggests addition of a biological mitigation measures for
worker environmental awareness training.
Response
As presented in Section 3.4, Biological Resources, MM BIO-11 requires that the Biological
Mitigation and Monitoring Plan outlined in MM BIO-1 include a worker environmental awareness
program.
Comment OT.14-7 The comment suggests addition of a biological mitigation measures for
good housekeeping (e.g., to prevent nesting in construction equipment).
Response
As presented in Section 3.4, Biological Resources, MM BIO-1, which outlines the Biological
Mitigation and Monitoring Plan, includes several construction-related BMPs to avoid or minimize
impacts to biological resources. These BMPs commonly include typical good housekeeping.
Comment OT.14-8 The comment recommends rethinking the use of “container” and instead
refer to something more generic. Not all plants for landscaping and habitat restoration will come
in “containers” (e.g., willow tubes)
Response
The biological mitigation measures referenced by the comment in Section 3.4, Biological
Resources (MM BIO-3, MM BIO-5, and MM BIO-15) require restoration of habitat based on
specific and objective performance criteria methods, including minimum success criteria of at least
70 percent survival of container plants and 70 percent relative cover by vegetation type. This
success criteria would ensure the establishment and success of container plants, as well as other
forms of plantings, such as willow tubes or seeding (vegetation cover).
Comment OT.14-9 The comment requests the EIR identify how much of the realigned Froom
Creek will be armored and to describe what riparian vegetation would look like in armored
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sections. The comment further questions what quality of riparian vegetation can establish in
armored sections.
Response
Please refer to EIR Appendix H, Chapter 3 of the PHHC (Froom Creek Restoration Program).
Conceptual sections of the creek realignment are shown in PHHC Section 3.7 (Froom Creek
Restoration Sections); this description notes that “boulders, cobbles, logs, and embedded tree roots
will be placed in key locations along the Channel Bank and Channel Bottom to provide habitat
areas.” In the area of the bridge crossing, a “Conspan” natural bottom culvert is proposed, and
would be “enhanced with a railing and decorative concrete, and armored with boulders, cobble
and vegetation.” Vegetation proposed on the channel banks include milkweed, needle spikerush,
blue wildrye, California meadow barley, creeping wild rye, seep monkeyflower, and creeping
snowberry. Channel bottom vegetation would include water paintain, umbrella sedge, rush, and
bulrush. The Restoration Program will be further refined through compliance with mitigation
measures, consultation and approval by the City’s Natural Resources Manager and state and
federal resource agency review.
Comment OT.14-10 The comment requests confirmation (in geology mitigation measures or in
the Project Description) that no habitable structures are proposed within the fault setbacks. The
comment recommends inclusion of a reference to City regulations prohibiting this.
Response
As described in Section 3.6, Geology and Soils, the Draft FRSP incorporates the recommendations
of the Subsurface Fault Investigation (Appendix G) requiring that habitable structures (structures
occupied more than 2,000 hours per year) are constructed outside the recommended fault setbacks
(refer to FRSP Section 3.2.3, Fault Lines).
Comment OT.14-11 The comment states that the Project site needs more than one way in and
one way out. The comment supports any effort to include a full access to Calle Joaquin to increase
evacuation alternatives.
Response
The comment aligns with the analysis presented within the EIR relating to impacts from
emergency access. The comment will be provided to City decision makers for consideration.
Please also refer to the Response to Comment L.1-8.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment OT.14-11 The comment states that the Project would create need for one new fire
fighter and one new police officer and that funding for these is a “soft” impact. The comment
questions whether the impact should be Class I or discussed further, since the creation of those
positions is outside of the Applicant’s control.
Response
Project impacts on public services, including law enforcement and emergency response services,
are analyzed in Section 3.12, Public Services and Recreation. As discussed therein under Impact
PS-1 and Impact PS-2, SLOPD and SLOFD currently anticipate adequate resources exist to serve
the Project such that department service levels and response times would not be adversely affected
and such that construction of a new facility would not be required to serve the Project. CEQA only
requires an analysis of physical changes to the environment. Since no new facilities would be
required, and therefore no physical change would occur, impacts of the Project on these services
were determined to be less than significant.
Comment OT.14-13 The comment states that the Project would be adding 300-400 new dogs and
that the EIR should look into dog park area at the offsite retention basin, as retention basins are
common areas for dog park uses.
Response
Neither the FRSP nor the Project Description presented in the EIR include consideration of the
proposed retention basin as a dog park. This comment will be provided to City decision makers
for consideration.
Comment OT.14-14 The comment suggests the EIR include clarifying language in each
mitigation measure referenced in the EIR (e.g., key descriptors) so the reader does not have to flip
back and forth to figure out what mitigation measure is being reference.
Response
The key descriptors for each reference to mitigation is included in the MMRP to the EIR to
improve readability. Please see Section 8.0, Mitigation Monitoring and Reporting Program.
Public Commenter – Commissioner McKenzie & Commissioner Wulkan
Comment OT.15-1 The commenters disagree with the Class I visual impact discussion. If the
discussion is retained, the EIR should include landscaping along sections visible from the trail
(e.g., shrubs, trees, native plants) to soften impacts.
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Response
The comment’s disagreement with the findings of the EIR with regard to impacts to aesthetic and
visual resources will be noted. Section 3.1, Aesthetic and Visual Resources includes MM VIS-1
which would require the Applicant install screening vegetation along the Project site boundaries
visible from public views, including those of the trail.
Public Commenter – Commissioner Stevenson
Comment OT.16-1 The comment notes that the Project site is potentially a very significant
cultural site. The Project should do full subsurface investigations of these sites. The comment
questions whether MM CR-11 (develop interpretive project that documents cultural and
architectural heritage) should be replicated for Chumash history. The development of more
information as mitigation should be built into the Project (e.g., ethnobotanical garden, public art,
interpretational signage informing public, incorporated into historic site, etc.). The Project should
stress the Chumash use of the site.
Response
A summary of the Project site’s archaeological significance is provided in Section 3.5, Cultural
and Tribal Cultural Resources. This summary is informed by existing literature, the various
cultural resource reports conducted for the Project and presented in Appendix F, and consultation
with tribal representatives. As described under Impact CR-1, based on review of these resources
and consultation with Chumash tribal representatives, the Project site contains a number of known
or potential archaeologically sensitive resources, as well as has the potential to contain unknown
archaeological resources that may be disturbed during Project construction; however, the Project
is not currently known to contain substantial archaeological resources or to contain an
archaeological site that is so significant it would warrant mitigation requiring development of an
interactive project documenting the cultural and archaeological heritage of the local Chumash
tribes. Local tribes were consulted with regarding the Project and raised no concerns with the
Project as designed (which avoid direct impacts to known sites) and with the implementation of
identified mitigation. Mitigation is identified to reduce impacts to known and unknown resources
consistent with the City’s Archaeological Resource Preservation Program Guidelines, CEQA, and
requests or recommendations made by the tribal representatives during the consultation process.
Comment OT.16-2 The comment questions whether the 174 units in Madonna Froom Ranch be
considered for senior housing, including age restricted housing. Inclusion of this component could
serve as a sub-alternative.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Response
While the Project does not propose inclusion of a senior housing component to the proposed 174
units in Madonna Froom development, the Project is not precluded from providing addition senior
housing restrictions on these units. The comment will be noted and provided to City decision
makers for consideration.
Comment OT.16-3 The comment states that Caltrans stated they have no capacity within their
right-of-way to handle water, so if not accommodated onsite, flooding could be an issue (flooding
on the highway).
Response
The proposed Project does not impede or alter the functionality of the existing box culverts and
does not intend to upgrade facilities at U.S. 101. The Preliminary Hydrology and Hydraulic
Calculations (PHHC) present a condition that is improved from the existing condition that includes
a substantial increase in flood storage immediately upstream of the double box culverts to provide
peak flow management. The November 2010 report titled “LOVR/US 101 Interchange
Improvement Project Revised Location Hydraulic Study” prepared by Wreco investigated the
existing box culverts capacity and on page 9 of the Wreco report it is identified that the capacity
of the culverts is overtopped during the 10-year event. Flow characteristics of the box culverts are
identified on page 22 of the Wreco report ranging from a 10-year event at 547 cfs to a 100-year
event at 1066 cfs. This information was the basis of the PHCC culvert analysis. The proposed
Project improves the condition where the box culverts do not overtop until the 25-year event and
provides storage to approximately 25-acre-feet upstream of the culverts far exceeding the existing
condition. The City will coordinate with Caltrans and provide improvement plans and supporting
documentation.
Public Commenter – Commissioner Jorgensen
Comment OT.17-1 The comment questions whether the EIR is the appropriate place to discuss
things like cement roofs or other features in buildings that would help protect residents from
wildfires.
Response
As described in Section 3.7.2, Regulatory Setting, the Project is subject to the requirements of the
California Fire Code (CFC), which lists specific requirements for emergency water supply, access
roads, roofing, construction techniques, hazards abatement, and inspection and safety to minimize
risks to public health from building fires or wildfires. While not explicitly stated, the CFC may
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require the Project utilize fire-resistant building materials such as cement or tile roofing to help
protect residents from wildfires.
Comment OT.17-2 The comment states the Project proposes 4-story buildings with elevators
and senior/assisted living populations, and questions if there if power loss, perhaps the EIR should
mitigate with requirements for backup power.
Response
The Project proposes development of a senior residential care facility and is subject to relevant
sections of the California Health and Safety Code and California Code of Regulations. Applicable
sections include California Health and Safety Code Section 1569.695 and CCR Title 22, Section
87212, both of which require the facility establish plans for emergency and disaster scenarios. The
California Health and Safety Code Section 1569.695 requires that the Project plan for the senior
residential care facility to be self-reliant for a period of not less than 72 hours. A summary of these
existing regulations as they would apply to the Project has been provided in Section 3.7.2,
Regulatory Setting.
Public Commenter – Commissioner Wulkan
Comment OT.18-1 The comment states that the study of impacts from noise generated by Irish
Hills Plaza should not be deferred, and questions why the analysis could not be conducted now in
the interest of full disclosure.
Response
A supplemental noise analysis has been provided by the Applicant and incorporated into the EIR
(refer to Final EIR Section 3.10 Noise). The report concluded that existing CNEL levels of
approximately 70 dBA may occur at the northern boundary of the Project site during a 24-hour
scenario with a maximum amount of activity and noise from adjacent businesses such as Costco,
Home Depot, TJ Maxx, and Whole Foods. These levels would decrease to 60 dBA approximately
150 feet into the Project site from its northern border with Irish Hills Plaza (refer to Final EIR,
Appendix I). As an entitlement request for development of the Madonna Froom portion of the
Specific Plan area has not been submitted, MM NO-4 remains to ensure that the specific elements
of future development are taken into consideration with a Project-specific noise study. In addition
to site planning, which will be considered at the entitlement review phase, mitigation would
potentially include a planted earthen berm, sound wall, or similar noise attenuating feature along
the site boundary with Irish Hills Plaza, as identified in the measure.
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8.0 RESPONSE TO COMMENTS
Froom Ranch Specific Plan
Final EIR
Comment OT.18-2 The comment states the EIR should explain the rationale for Villaggio being
responsible for full parks acreage requirements and questions why the EIR analysis does not
acknowledge credit for onsite facilities being provided.
Response
The EIR fully acknowledges that Villaggio would provide a variety of resident-only recreational
facilities onsite to serve the needs of senior citizens; however, the proposed facilities are only
considered adequate to serve up to 93 senior residents with special recreational needs. Based on
the needs of residents of the Project, the range of amenities proposed for Villaggio, and the
requirements for amount of park land needed per 1,000 residents outlined in General Plan PRE
Policies 3.13.1 and 5.0.2. For detailed discussion of the need for additional park lands per the
requirements of the City General Plan, please refer to discussion of Impact PS-4 in Section 3.12,
Public Services and Recreation. Refer also to Response to Comment OT.8-1.
Public Commenter – Commissioner Kohn
Comment OT.19-1 The comment states that traffic on LOVR is bad and going to get worse.
The mitigation measures identified in the EIR actually need to get built. The comment agrees with
the mitigation measures and encourages the City/Applicant to complete them as quickly as
possible.
Response
The comment does not directly pertain the analysis presented in the EIR. The comment will be
provided to City decision makers for consideration.
Comment OT.19-2 The comment agrees with a restricted turn at Buckley Road and Vachell
Lane, but states that this restriction will worsen traffic on Hwy 227, as people use it as a short-cut.
Response
The extension of Buckley Road has been evaluated in detail as part of several recently approved
planning documents, including the City’s General Plan Circulation Element and Avila Ranch
Development Plan and EIR. Each of these plans included environmental review and analysis of
potential traffic and circulation impacts to other roadways in conjunction with the roadway
extension. The Avila Ranch Development Plan is required to construct this roadway extension,
with fair-share financial contributions from the Project. The Buckley Road Extension to South
Higuera allows for left-turn restrictions to be implemented at the South Higuera/Vachell
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intersection, which has operated at deficient levels of service and has been identified on the City’s
high collision rate network for several years.
Comment OT.19-3 The comment agrees with requirement for traffic calming within the Project
site, but requests the Applicant not utilize speed humps as they are bad on emergency vehicles.
Response
The City Transportation Division coordinates closely with the City Fire Department and other
local emergency service providers prior to installation of traffic calming features in order to
minimize potential negative impacts to emergency response. Over the years, the City has refined
speed hump designs and dimensions to develop a standard that is supported by City Fire
Department.
Public Commenter – Commissioner Jorgensen & Commissioner Stevenson
Comment OT.20-1 The comment states the transportation analysis is from 2016/2017. The
comment expresses concern regarding the age of data (e.g., LOVR overpass was just constructed
and it is immediately full to the brim) and notes that traffic is getting worse every day. The goal
of LOS D may be optimistic. The comment further expresses concern regarding the traffic
projections based on current conditions, not based on the Project itself.
Response
See Comment Response S.2-6 for detailed discussion of traffic data and adequacy of traffic
projections.
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9.0 MITIGATION MONITORING AND REPORTING PROGRAM
Froom Ranch Specific Plan 9-1
Final EIR
9.0 MITIGATION MONITORING AND REPORTING PROGRAM
9.1 PURPOSE
This Mitigation Monitoring and Reporting Program (MMRP) provides a summary of each
mitigation measure for the proposed Froom Ranch Specific Plan (Specific Plan; Project)
and the monitoring implementation responsibility for each measure. The MMRP for the
Specific Plan will be in place through all phases of the Project, including design,
construction, and operation.
9.2 RESPONSIBILITIES
The California Environmental Quality Act (CEQA) requires the adoption of feasible
mitigation measures to reduce the severity and magnitude of potentially significant
environmental impacts associated with Project development.
State CEQA Guidelines Section 15091(d) states:
When making the findings required in subdivision (a)(1), the agency shall also
adopt a program for reporting on or monitoring the changes which it has either
required in the project or made a condition of approval to avoid or substantially
lessen significant environmental effects. These measures must be enforceable
through permit conditions, agreements, or other measures.
The City of San Luis Obispo (City) will act as the lead agency and approve a program for
reporting or monitoring of the approved mitigation measures for this Project to ensure that
the adopted mitigation measures are implemented as defined in the Final Environmental
Impact Report (EIR) for the Project. For each MMRP activity, the Applicant will either
administer the activity or delegate it to staff, consultants, or contractors. The Applicant will
ensure that monitoring is documented and provided to the City as required and that
deficiencies are promptly corrected. The designated environmental monitor depending on
the provision specified below (e.g., City staff, environmental monitor, certified
professionals, etc.) will track and document compliance with mitigation measures, note any
problems that may result, and take appropriate action to remedy problems. The City or its
designee(s) will ensure that each person delegated any duties or responsibilities is qualified
to monitor compliance.
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9.0 MITIGATION MONITORING AND REPORTING PROGRAM
9-2 Froom Ranch Specific Plan
Final EIR
9.3 MONITORING PROCEDURES
Many of the monitoring procedures will be conducted during the construction phase of the
Project. The City or its designee(s) and the environmental monitor(s) are responsible for
integrating the mitigation monitoring procedures into the construction process in coordination
with the Applicant. To oversee the monitoring procedures and to ensure success, the
environmental monitor assigned to a monitoring action must be onsite during the applicable
portion of construction that has the potential to create a significant environmental impact
or other impact for which mitigation is required. The environmental monitor is responsible
for ensuring that all procedures specified in the monitoring program are followed.
9.4 MONITORING TABLE
For each mitigation measure, Table 9-1 identifies 1) the full text of the mitigation; 2) plan
requirements and applicable timing; 3) how the action will be monitored and the agency
responsible for verifying compliance; and 4) the applicability of the mitigation measure to
Alternative 1 – Clustered Development Below the 150-foot Elevation Alternative (the
Actionable Alternative).
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9.0 MITIGATION MONITORING AND REPORTING PROGRAM Froom Ranch Specific Plan 9-3 Final EIR Table 9-1. Mitigation Monitoring and Reporting Program Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Aesthetics and Visual Resources MM VIS-1. Landscape Screening Guidelines. The Draft Froom Ranch Specific Plan (FRSP) shall be revised to include the following Landscape Screening Guidelines to provide effective screening of proposed structural massing as experienced from public views along Los Osos Valley Road (LOVR) and the LOVR Overpass. The Project landscape plan shall be prepared by a qualified landscape architect and include the following: 1. Maximize protection of existing vegetation along the Project site boundary to provide visual screening during Project construction and operation. 2. Retain existing vegetation fronting the Project site along LOVR to the greatest extent feasible to screen construction activities. 3. Specify a plant palette and landscape plan that ensure a vegetated site boundary of sufficient height and density to provide visual screening of the proposed development from public views. Robust riparian planting shall be included in landscape plans to achieve visual screening along the proposed realigned Froom Creek. 4. Native tree specimens and shrubs capable of reaching or exceeding the heights of the adjacent proposed structures shall be planted along Project site boundaries visible from public views. 5. Screening planting specimen selection and location shall emphasize the ability to interrupt the contiguous massing of structures as experienced from area roadways and scenic vistas. Spacing shall be sufficient to minimize views of structures within the Project site. 6. Screening planting specimen selection shall emphasize the ability of planting species to effectively establish and thrive over the life of the Project, such that smaller sizes shall be considered rather than exclusively larger box sizes. Planting establishment rates shall be considered but shall not preclude the use of slower-growing species, such as coast valley oak and willows. 7. Native tree specimens capable of reaching or exceeding the heights of adjacent structures shall be planted adjacent to multi-The Specific Plan Landscape Screening Guidelines and landscape bond shall be reviewed and approved by the City Community Development Department prior to vesting tract map recordation. Landscape plantings, including irrigation, outside of building sites shall be in place prior to issuance of building permits for each phase of the Project. Landscape plantings, including irrigation, within buildings sites shall be in place prior to occupancy for each phase. A landscape architect approved by the City shall provide verification of landscaping establishment pursuant to the Screening Plan to the City’s Community Development Department for review and approval prior to relinquishment of the bond. The City Community Development Department shall review and approve the Specific Plan Landscape Screening Guidelines. The Applicant shall ensure that all landscape planting and irrigation are in place and shall prepare a memo verifying condition compliance. The City Community Development Department shall review and approve the landscaping establishment bond letter. This measure would also apply to Alternative 1. 02152
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-4 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 family and commercial structures located within the interior of the Specific Plan area consistent with the specifications above. 8. A bond for screening landscaping and irrigation shall be provided to ensure establishment of plantings. The bond shall be revoked upon satisfactory establishment of screen planting vegetation according to the plan. Air Quality and Greenhouse Gas Emissions MM AQ-1. Construction Activity Management Plan. A Construction Activity Management Plan (CAMP) shall be included as part of Project grading and building plans and shall be submitted to SLO County APCD and to the City for review and approval prior to the start of construction. The plan shall include but not be limited to the following elements: 1. A Dust Control Management Plan that encompasses the following dust control measures: Reduce the amount of disturbed area where possible; Water trucks or sprinkler trucks shall be used during construction to keep all areas of vehicle movement damp enough to prevent dust from leaving the site and from exceeding the APCD’s limit of 20 percent opacity for greater than 3 minutes in any 60-minute period. At a minimum, this would require twice-daily applications. Increased watering frequency would be required when wind speeds exceed 15 miles per hour (mph). Reclaimed water or the onsite water well (non-potable) shall be used when possible. The contractor or builder shall consider the use of a SLO County APCD-approved dust suppressant where feasible to reduce the amount of water used for dust control; All dirt stock-pile areas shall be sprayed daily as needed; Permanent dust control measures identified in the approved Project revegetation and landscape plans of any development within the Specific Plan area should be implemented as soon as possible following completion of any soil disturbing activities; Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading The CAMP shall be submitted to SLO County APCD and to the City for review and City approval prior to issuance of grading and construction permits and recordation of the final VTM. All required fugitive dust and emissions control measures shall be noted on all grading and building plans and all construction activities shall adhere to measures throughout all grading, hauling, and construction activities. The contractor or builder shall provide the City Community Development Director and SLO County APCD with the name and contact information for an assigned onsite dust and emissions control monitor(s) who has the responsibility to: a) assure all dust control requirements are complied with including those covering weekends and holidays, b) order increased watering as necessary to prevent transport of dust offsite, and c) attend the pre-construction meeting. The dust monitor shall be designated prior to grading permit issuance for each Project phase. The dust control components apply from the beginning of any City staff shall ensure measures are depicted on the CAMP and all submitted grading and construction plans for each Project phase. The Applicant shall be responsible for compliance during construction activities, including holidays or weekends when work may not be in progress. City grading and building inspectors shall spot check and ensure compliance onsite. This measure would also apply to Alternative 1. 02153
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-5 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 shall be sown with a fast germinating native grass seed and watered until vegetation is established; All disturbed soil areas not subject to revegetation shall be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by SLO County APCD; All roadways, driveways, sidewalks, etc. to be paved should be completed as soon as possible. In addition, building pads should be laid as soon as possible after grading unless seeding or soil binders are used; Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site; All trucks hauling dirt, sand, soil, or other loose materials are to be covered or shall maintain at least 2 feet of freeboard in accordance with California Vehicle Code Section 23114; Designate access points and require all employees, subconsultants, and others to use them. Install and operate a “track-out prevention device” where vehicles enter and exit unpaved roads onto paved streets. The track-out prevention device can be any device or combination of devices that are effective at preventing track-out, located at the point of intersection of any unpaved area and a paved road. If utilized, rumble strips or steel plate devices shall be cleaned periodically. If paved roadways accumulate tracked-out soils, the track-out prevention device shall be modified or replaced to prevent track-out; Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers with reclaimed water should be used where feasible; All of these fugitive dust mitigation measures shall be shown on grading and building plans; and The contractor or builder shall designate a person or persons to monitor the fugitive dust control emissions and enhance the implementation of the measures as grading or construction throughout all development activities until occupancy is issued and landscaping is successfully installed. 02154
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-6 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 necessary to minimize dust complaints, reduce visible emissions below 20 percent opacity, and to prevent transport of dust offsite. Their duties shall include holiday and weekend periods when work may not be in progress. The name and telephone number of such persons shall be provided to SLO County APCD Compliance Division prior to the start of any grading, earthwork or demolition. 2. Implementation of the following BACT for diesel-fueled construction equipment. The BACT measures shall include: Use of at least Tier 3 off-road equipment and 2010 on-road compliant engines; Repowering equipment with the cleanest engines available; and Installing California Verified Diesel Emission Control Strategies. 3. Implementation of the following standard air quality measures to minimize diesel emissions: Maintain all construction equipment in proper tune according to manufacturer’s specifications; Fuel all off-road and portable diesel-powered equipment with CARB-certified motor vehicle diesel fuel (non-taxed version suitable for use off-road). Use on-road heavy-duty trucks that meet the CARB’s 2007 or cleaner certification standard for on-road heavy-duty diesel engines and comply with the State On-Road Regulation; Construction or trucking companies with fleets that do not have engines in their fleet that meet the engine standards identified in the above two measures (e.g. captive or NOx exempt area fleets) may be eligible by proving alternative compliance; On- and off-road diesel equipment shall not be allowed to idle for more than five minutes. Signs shall be posted in the designated queuing areas to remind drivers and operators of the five-minute idling limit; Diesel idling within 1,000 feet of sensitive receptors is not permitted; 02155
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-7 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Staging and queing areas shall not be loated within 1,000 feet of sensitive receptors; Electrify equipment when feasible; Substitute gasoline-powered in place of diesel-powered equipment, where feasible; and, Use alternatively fueled construction equipment onsite where feasible, such as compressed natural gas (CNG), liquefied natural gas (LNG), propane or biodiesel. 4. Tabulation of on- and off-road construction equipment (age, horse-power, and miles and/or hours of operation); 5. Schedule construction truck trips during non-peak hours (as determined by the Public Works Director) to reduce peak hour emissions; and 6. Limit the length of the construction work-day period to 8 hours max. MM AQ-2. Application of Low or Zero VOC Paints. To reduce ROG and NOx levels during the architectural coating phase, low or no Volatile Organic Compound (VOC)-emission paint shall be used with levels of 50 grams per liter (g/L) or less (Odorless, Zero VOC Paint). The schedule for architectural coatings application shall be extended, limiting the daily coating activity to a level determined acceptable by SLO County APCD. The Applicant shall verify the measures through written documentation submitted to the City and SLO County APCD for review and approval. Measures shall be indicated on all building and construction plans and submitted to SLO County APCD and to the City for review and approval prior to issuance of building permits and recordation of the final VTM. City shall verify measures with the Applicant and SLO County APCD. City staff shall ensure measures are depicted on all building and construction plans. City building inspectors shall perform site inspections to ensure compliance. This measure would also apply to Alternative. MM AQ-3. Offsite ROG and NOx Emissions Reductions. If required, an offsite mitigation strategy shall be developed and agreed upon by the Applicant, City, and SLO County APCD at least three months prior to the issuance of grading permits. Offsite mitigation strategies may be in the form of cash payment, circulation improvements above the Project’s fair share, or funding for ongoing transit improvements. The Applicant may provide appropriate funding necessary to offset the Project’s residual construction-related ROG+NOx emissions beyond SLO County APCD’s daily threshold; in the event funding is required, it shall be provided at least two months prior to the start of construction to The Applicant shall prepare and submit the offsite mitigation strategy to SLO County APCD for review and to the City for approval at least three months prior to the issuance of grading permits for Phase 1 construction. The Applicant shall provide any necessary funding to SLO County APCD at least two months prior to the start of construction. SLO County APCD and City staff shall ensure offsite mitigation measures are appropriate. If the Applicant elects to pay mitigation fees, SLO County APCD shall verify the receipt of funding to the City. If the Applicant elects to provide improvements, proposed improvements shall be reviewed by the City and SLO County APCD and approved by the City This measure would also apply to Alternative 1. 02156
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-8 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 help facilitate emission offsets that are as real-time as possible. Cash payment of offsite mitigation fees shall be calculated based on the most current ARB-approved Carl Moyer Guidelines at the time of commencement of each Project phase. Offsite mitigation strategies shall include one or more of the following: Develop or improve park-and-ride lots; Fund a program to buy and scrap older, higher emission passenger and heavy-duty vehicles; Retrofit or repower heavy-duty construction equipment, or on-road vehicles; Subsidize vanpool programs; Contribute to funding of new bike lanes; Replace/repower San Luis Obispo Regional Transit Authority (SLORTA) transit buses; Purchase Verified Diesel Emission Control Strategies (VDECS) for transit buses or construction fleets; and Fund expansion of existing SLORTA transit services. prior to implementation. City and SLO County APCD staff shall monitor proposed improvements to ensure compliance. MM AQ-4. SLO County APCD ROG and NOx Emissions Reduction Strategies. Consistent with standard mitigation measures set forth by SLO County APCD, Projects generating more than 50 lbs/day of combined ROG + NOx shall implement all feasible measures within Table 3-5 of the Air Quality Handbook. The following mitigation measures shall apply to the Project (see following table). The Applicant shall include the mitigation measures in Table 3-5 of the 2012 SLO County APCD CEQA Air Quality Handbook (as amended by the 2017 Clarification Memorandum), as indicated in the column “How the Project Will Include This Measure” in Table 3.3-9, above. All feasible standard mitigation measures shall be included in the FRSP prior to approval of the final FRSP and these measures shall also be included on the final VTM prior to recordation. City staff shall ensure the above measures are incorporated into the FRSP, final VTM, and building plans prior to permit issuance. City staff shall ensure measures are listed on final plans submitted for review and approval by the City. City staff shall work with the Applicant to ensure that these strategies are implemented. The City shall conduct periodic site visits to ensure compliance, in consultation with the SLO County APCD. This measure would also apply to Alternative 1. 02157
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-9 Final EIR SLO County APCD ROG and NOx Emissions Reduction Strategies per Table 3-5 of the CEQA Air Quality Handbook Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure 1 R SD Install gas or electric fireplace in place of U.S. EPA-certified Tier 2 residential wood burning appliances. GHG, O, P D The Project does not propose any wood burning appliances. If fireplaces are proposed, they shall be electric. 2 C, R SD, T Design and build high-density, compact development within the urban core or URL to encourage alternative transportation (walk, bike, bus, etc.). GHG, O, P D The Project would include residential and commercial development within the URL and would provide access to transit and non-vehicular transportation; however, the Project site lies on the southern edge of the City and is not located within an urban core area. To encourage alternative transportation, the Project shall provide a range of transit options and incentives to employees and residents of Villaggio, and commercial and residential developments within Madonna Froom. 3 C, I, R SD, T Provide a pedestrian-friendly and interconnected streetscape with good access to/from the development for pedestrians, bicyclists, and transit users to make alternative transportation more convenient, comfortable and safe (may include: appropriate signalization and signage; safe routes to school; linking cul-de-sacs and dead ends; orienting buildings towards streets with automobile parking in the rear, etc.). GHG, O, P D The Draft FRSP includes guidelines for incorporating pedestrian walkways, outdoor seating, and landscape areas where possible. Public commercial collector roads shall be connected to adjacent development to allow pedestrian and bicyclist access, and public pedestrian trails will connect public roads to the existing trail system in the Irish Hills Natural Reserve. 4 C, I, R SD, T Provide shade over 50 % of parking spaces to reduce evaporative emissions from parked vehicles. O D Shade trees in surface parking areas are to be provided as part of the Project per City requirement. The Applicant shall amend the Draft FRSP to require shade over a minimum of 50 % of proposed parking spaces. 5 C, I, R SD, T Reduce fugitive dust from roads and parking areas with the use of paving or other materials. P D No unpaved roads, driveways, or parking areas are proposed as part of the Project. 6 C, I, R SD, T Implement driveway design standards (e.g., speed bumps, curved P D The City has a requirement that the design speeds in local and collector roads not exceed 25 mph. 02158
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-10 Froom Ranch Specific Plan Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure driveway) for self-enforcement of reduced speed limits on unpaved driveways. Bulb-outs, traffic circles, chicanes, and other features are also included in the Project. There are no unpaved roads or driveways in the development. 7 C, I, R SD, T Use an APCD-approved suppressant on private unpaved roads leading to the site, unpaved driveways and parking areas, applied at a rate and frequency that ensure compliance with APCD Rule 401: Visible Emissions, and ensures offsite nuisance impacts do not occur. P O No unpaved roads, driveways, or parking areas are proposed as part of the Project. 8 C, I, R SD, T Incorporate traffic calming modifications to Project roads to reduce vehicle speeds and increase pedestrian and bicycle usage and safety. GHG, O, P D City has a requirement that the design speeds in local and collector roads not exceed 25 mph. Bulb-outs, traffic circles, chicanes, and other features are included. 9 C, I, R SD, T Work with SLOCOG to create, improve, or expand a nearby ‘Park-and-Ride’ lot with car parking and bike lockers in proportion to the size of the Project. GHG, O, P D In coordination with the City and SLOCOG, the Project Applicant shall fund and install an EV charging station at the nearby Calle Joaquin Park & Ride Lot. If station has not been installed prior to Project occupancy, and if approved by the City Community Development Director, the Applicant my provide a fair share mitigation payment to the City not to exceed $75,000 for installation of the EV charging station by the City or others. 10 C SD, T Implement onsite circulation design elements in parking lots to reduce vehicle queuing and improve the pedestrian environment. GHG, O, P D The Applicant shall amend the Draft FRSP to require onsite circulation design in parking lots to reduce vehicle queueing and improve the pedestrian environment. 11 C, I SD, T Provide employee lockers and showers to promote bicycle and pedestrian use. One shower and five lockers for every 25 employees is recommended. GHG, O, P D The City’s Zoning Ordinance requires showers and lockers based on the square-footage of each land use. The Project would be consistent with the intent of this measure through consistency with the City’s Zoning Regulations. 12 C, I, R SD, T Increase bicycle accessibility and safety in the vicinity of the Project; for example: provide interconnected GHG, O, P D The Project includes a number of improvements to pedestrian and bicyclist environment, including those required in MM TRANS-5, -8, -9, and -10. 02159
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-11 Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure bicycle routes/lanes or construction of bikeways. 13 C, I, R SD, T Exceed Cal Green standards by 25 % for providing onsite bicycle parking: both short-term racks and long-term lockers, or a locked room with standard racks and access limited to bicyclists only. GHG, O, P D The Applicant shall amend the Draft FRSP to require onsite bicycle parking consistent with 2019 Cal Green Section 5.106.4, A4 106.9, A5 106.4.3m and Table A5 106.4.3 (or the Cal Green standards in effect at the time of adoption of the Specific Plan), and the City Zoning Regulations. 14 C, I, R SD, T Develop recreational facility (e.g., parks, trails, gym, pool, etc.) within 0.25 mile from site. GHG, O, P D The Project includes development of various facilities to meet the recreational needs of the residents of Villaggio. The Project also includes the development of a 2.9-acre neighborhood park within the Project site. 15 C, I, R SD, T If the project is located on an established transit route, provide improved public transit amenities (e.g., covered transit turnouts, direct pedestrian access, bicycle racks, covered bench, smart signage, route information displays, lighting, etc.). GHG, O, P D The Project site is located along LOVR and residential development is less than 0.25 mile from bus stops for Transit Line 2A and the Laguna Tripper. The Project would include installation of a new transit stop for these routes to improve public transit amenities and access. 16 C, I, R T Provide bicycle-share program for development. GHG, O, P O The Applicant shall work with Public Works to amend the Draft FRSP to identify the location of a hub/node of the City’s bicycle share network at the Project site. The location of the hub/node site shall be developed/preserved to allow the development of such a hub/node in the future. 17 C, I T Require 15 % of fleet vehicles to be zero emission vehicles. DPM, GHG, O O The Project proposes uses that could include the use of fleet vehicles and/or shuttles (i.e. hotel/airport shuttle). The Applicant shall amend the Draft FRSP to require the use of zero emission vehicles for all proposed fleet, shuttle, or group-transport vehicles for the Villaggio Life Plan Community and to provide the sufficient electric vehicle charging infrastructure to support it, in addition to the chargers required for private vehicles. The Applicant shall amend the Draft FRSP to require the provision of electric vehicle charging infrastructure 02160
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-12 Froom Ranch Specific Plan Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure for fleet, shuttle, or group-transport vehicles within the commercially zoned areas of the Specific Plan. 18 C, I T Project includes alternative fuel fleet vehicle(s). DPM, GHG, O O The Project proposes uses that could include the use of fleet vehicles and/or shuttles (i.e. hotel/airport shuttle). The Applicant shall amend the Draft FRSP to require the use of alternative fuel fleet, shuttle, or group-transport vehicles for the Villaggio Life Plan Community and to provide the sufficient electric vehicle charging infrastructure to support it, in addition to the chargers required for private vehicles. The Applicant shall amend the Draft FRSP to require the provision of electric vehicle charging infrastructure for fleet, shuttle, or group-transport vehicles within the commercially zoned areas of the Specific Plan. 19 C, I, R T Provide neighborhood EV/car-share program for the development. GHG, O O The City has consulted with car share programs in other areas and researched the requirements of such a program, and have determined that a car share program is not feasible for this Project. 20 C, I, R T Provide dedicated parking for carpools, vanpools, and/or high-efficiency vehicles to meet or exceed Cal Green Tier 2. GHG, O, P O The Applicant shall amend the Draft FRSP to require the provision of dedicated parking for carpools, vanpools, and high-efficiency vehicles that meet Cal Green Tier 2 standards. 21 C, I T Provide vanpool, shuttle, mini bus service (alternative fueled preferred). GHG, O, P O The Applicant or developer of the FRSP shall promote carpool, vanpool, shuttle, and EV vehicles. See also MM AQ-6. 22 C, I, R T Work with SLO Regional Rideshare to educate occupants with alternative transportation and smart commute information (e.g., transportation board, electronic kiosk, new hire packets, web portal, newsletters, social media, etc.). GHG, O, P O The FRSP shall be amended to include measures for encouraging and incentivizing residents and employees of the proposed development to participate in the San Luis Obispo Regional Rideshare program. See also MM AQ-6. 23 C, I T Provide child care facility onsite. GHG, O, P O The Applicant shall amend the Draft FRSP to include policies that allow for the provision of child care facilities onsite. 02161
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-13 Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure 24 C, I T Implement programs to reduce employee vehicle miles traveled (e.g. incentives, SLO Regional Rideshare trip reduction program, vanpools, onsite employee housing, alternative schedules (e.g., 9–80, 4–10, telecommuting, satellite work sites etc.). GHG, O, P O The Project is required to implement mitigation programs and strategies to reduce employee VMT and mobile-source emissions at commercial uses. Refer to MM TRANS-5, -8, -9, -10, MM AQ-6. 25 C, I T Provide a lunchtime shuttle to reduce single occupant vehicle trips and/or coordinate regular food truck visits. GHG, O, P O The Applicant shall amend the Draft FRSP to include policies for provision of lunchtime shuttles to the Project site to reduce trips associated with onsite commercial businesses, as feasible. 26 C T Provide delivery service in clean fueled vehicles. GHG, O, P O The Applicant shall amend the Draft FRSP to provide the electric vehicle charging infrastructure to support clean fueled vehicles for commercial uses, in addition to the chargers required for private vehicles. 27 C T At community event centers (i.e., amphitheaters, theaters, and stadiums), provide free valet bicycle parking. GHG, O, P O The Project does not propose development of any community event centers or other communal gathering areas. 28 C, I T Implement a “No Idling” vehicle program which includes signage, enforcement, etc. DPM, GHG, O O The Applicant shall amend the Draft FRSP to include programs and policies requiring implementation of a “No Idling” vehicle program for commercial development which shall include standards for signage. 29 R T Provide free-access telework terminals and/or wi-fi access in multi-family projects. GHG, O, P O The Applicant shall amend the Draft FRSP to include programs and policies requiring provision of free-access telework terminals and/or wi-fi access in multi-family developments where an indoor common area is proposed. 30 C, I T Meet or exceed Cal Green Tier 2 standards for providing EV charging infrastructure. GHG, O, P D The FSRP includes Program 4.7.2f, which states that individual garages are to be electric vehicle (EV) ready and shared parking areas for apartments shall incorporate EV charging stations. In addition, compliance with City Zoning Regulations or Cal Green Tier 2 standards regarding EV parking 02162
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-14 Froom Ranch Specific Plan Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure spaces (whichever is greater at the time of building permit submittal) shall be required. 31 C, I T Install 1 or more level 2 or better EV charging stations. GHG, O, P D The Draft FRSP includes Program 4.7.2f, which states that individual garages are to be “EV -ready” and shared parking areas for apartments shall incorporate EV charging stations. In addition, compliance with City Zoning Regulations regarding EV parking spaces shall be required. All electric vehicle chargers shall be, at a minimum, level 2 chargers. 32 C, I, R EE Meet or exceed Cal Green Tier 1 standards for building energy efficiency. GHG, O D The Applicant shall amend the Draft FRSP to include programs and policies for ensuring new development, at a minimum, meets or exceeds Cal Green Tier 1 standards for building efficiency. 33 C, I, R EE Meet or exceed Cal Green Tier 2 standards for building energy efficiency. GHG, O D The Applicant shall amend the Draft FRSP to include programs and policies for ensuring new development, at a minimum, meets or exceeds Cal Green Tier 1 standards for building efficiency. 34 C, I, R EE Meet or exceed Cal Green Tier 2 standards for utilizing recycled content materials. GHG D The Applicant shall amend the Draft FRSP Program 4.7.4a to encourage, at a minimum, use of recycled content materials consistent with Cal Green Tier 2 standards. 35 C, I, R EE Meet or exceed Cal Green Tier 2 standards for reducing cement use in concrete mix as allowed by local ordinance and conditions. GHG D The Applicant shall amend the Draft FRSP to include a policy for encouraging construction of the Project, at a minimum, meets Cal Green Tier 2 standards for reducing cement use in concrete mix, as allowed by local ordinance and conditions. Recipe for cement mix shall be verified by the City prior to Project construction and subject to inspection by City permit compliance staff. 36 C, I, R EE All built-in appliances shall be Energy Star certified or equivalent. GHG D The Draft FRSP includes Program 4.7.4a, which requires that all new residential units shall incorporate high-efficiency Energy Star compliant appliances. 37 C, I, R EE Utilize onsite renewable energy systems (e.g., solar, wind, GHG D The Project is required to comply with MM AQ-5, requiring the Draft FRSP be amended to include measures necessary to reduce Project operational 02163
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-15 Final EIR Measure # Land Use1 Measure Type2 Mitigation Measure Pollutant Reduced3 Phase4 How the Project Will Include This Measure geothermal, biomass and/or bio-gas) to offset at least 10 % of energy use. stationary-source emissions, including utilization of 100 % carbon-free energy. 38 C, I, R EE Meet or exceed Cal Green Tier 2 standards for the use of greywater, rainwater or recycled water. GHG D The Project includes the use of recycled water for public landscaping in parks, landscaped buffers, the commercial mixed-use area, and common outdoor areas in multi-family residential projects. Commercial mixed-use and multi-family development projects will include reclaimed water irrigation systems in their landscaping plans. Any irrigation needed to establish or maintain vegetation in the stormwater detention and riparian enhancement areas would also be required to use recycled water, consistent with the intent of this policy. 39 C, I, R EE Provide and require the use of battery powered or electric landscape maintenance equipment for new development. GHG, O D The Applicant shall amend the Draft FRSP to include requirements for outdoor plugs for electric powered landscape equipment and programs or policies requiring contracted landscaping companies to use battery powered or electric landscape maintenance equipment. 40 C, I, R EE Meet or exceed Cal Green Tier 2 standards for using shading, trees, plants, cool roofs, etc. to reduce “heat island” effect. GHG D The Applicant shall amend the Draft FRSP to include programs or policies requiring the use of shading, trees, plants, cool roofs, and/or other measures to reduce “heat island” effect, which at a minimum, meets Cal Green Tier 1 standards. 41 C, I, R EE Design roof trusses to handle dead weight loads of standard solar-heated water and photovoltaic panels. GHG, O D The Applicant shall amend the Draft FRSP to include programs and policies requiring the design of roof trusses to handle dead weight loads of standard solar-heated water and photovoltaic panels. This requirement shall not apply to historic structures within the Froom Ranch Dairy Complex to be relocated to the proposed trailhead park. 1 Land Use: C = Commercial; I = Industrial; R = Residential 2 Measure Type: SD = site design; T = transportation; EE = energy efficiency 3 Pollutant Reduced: DPM = diesel particulate matter; GHG = greenhouse gas; O = ozone; P = particulate 4 Phase: D = design; O = operational EV – Electric Vehicle SLOCOG - San Luis Obispo Council of Governments 02164
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-16 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Aesthetics and Visual Resources MM AQ-5. Net-Zero GHG Emissions Strategies. The Applicant shall revise the Draft FRSP to include measures necessary to reduce Project operational stationary-source GHG emissions to achieve net zero emissions, consistent with the City’s 2035 net-zero GHG emissions target. These measures shall include Best Available Mitigation strategies for reducing operational emissions, including but not limited to the following: Electricity shall be the only energy source for the entirety of Project operations including but not limited to space conditioning, water heating, illumination, cooking appliances, and plug loads (exemptions to this requirement shall be limited to appliances in commercial kitchens, emergency backup generators, and medial end-uses that have no viable electric alternative). Electrical power for the entirety of Project operations including but not limited to illumination, heating, cooling, and ventilation shall be provided by alternative or carbon-free energy sources according to the following priority: 1) on-grid power with 100-percent renewable or carbon-free source (a planned product of Monterey Bay Community Power available to the City in 2020), or 2) a combination of grid power and on site renewable generation to achieve annual zero net electrical energy usage, or 3) purchase of carbon offsets of any portion of power not from renewable or carbon-free sources. As a first priority, carbon-free sourced energy shall be purchased from Monterey Bay Community Power. For new buildings, onsite solar photovoltaic systems shall be required, and retrofitted buildings shall be encouraged to install onsite solar photovoltaic systems to offset energy demand, regardless of building size. At a minimum, for nonresidential, mixed-use, and mid-rise residential buildings, a solar photovoltaic system shall fill the entirety of the Solar Zone (as defined in Section 110.10 and specified in Joint Appendix JA1 of the 2019 California Energy Code). All proposed commercial and health care facilities shall exceed the minimum standards of Title 24, Part 11 (Cal The Applicant shall include the above measure in the Final FRSP prior to approval and shall include the above measure on the final VTM prior to recordation. Plans submitted for building permits shall incorporate Best Management Strategies, and for the selected Best Management Strategies, the Applicant shall work with City and SLO County APCD staff to calculate estimated stationary-source emissions to ensure achievement of net-zero stationary source operational emissions for the Project. City and SLO County APCD staff shall ensure the above measures are incorporated into the FRSP, final VTM, and building plans prior to permit issuance. City staff shall ensure measures are listed on final plans submitted for review and approval by the City. City and SLO County APCD staff shall work with the Applicant to ensure that these strategies are implemented. The City shall verify compliance in consultation with the SLO County APCD. This measure would also apply to Alternative 1. 02165
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-17 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Green) by adopting all or some elements of Cal Green Tier 1 and/or 2 voluntary elective measures to increase energy efficiency in new buildings, remodels and additions. These measures shall prioritize upgrading lighting (e.g., using light-emitting diode [LED] lights), heating and cooling systems, appliances, equipment and control systems to be more energy efficient. This requirement shall not apply to historic structures within the Froom Ranch Dairy Complex to be relocated to the proposed trailhead park. MM AQ-6. GHG Emissions Reduction Best Management Practices. The Applicant shall revise the FRSP to include measures necessary to reduce the Project’s operational, mobile-source emissions, and VMT to the maximum extent feasible, including, but not limited to the following: Rideshare and Employee Ridership Programs: The FRSP shall be amended to include measures for encouraging and incentivizing residents and employees of the proposed development participate in the San Luis Obispo Regional Rideshare program. Senior Shuttle Service: Villaggio shall provide clean fuel shuttle services and shall provide sufficient onsite electric vehicle charging infrastructure to support the services. Electric vehicle charging infrastructure included to meet requirements for personal vehicles may not be used to fulfill this requirement. All Electric Small Vehicles: The FRSP shall require all personal small vehicles (e.g., golf carts) be 100 percent electric powered. Promote Carpools, Vanpools, and Electric Vehicle (EV) Vehicles: Provide dedicated parking for carpools, vanpools, and high-efficiency vehicles in exceedance of Cal Green Tier 2 standards. The Applicant shall include all feasible Best Management Strategies as part of the final FRSP. For the selected Best Management Strategies, the Applicant shall work with City and SLO County APCD staff to calculate estimated mobile-source emissions to ensure emissions are reduced to the maximum extent feasible as vehicles are the largest source of operational emissions, noting that vehicle emissions are regulated on a state and federal level. City and SLO County APCD staff shall ensure the above measures are incorporated into the FRSP prior to recordation. City staff shall ensure measures are listed on the final FRSP submitted for review and approval by the City. City and SLO County APCD staff shall work with the Applicant to ensure that these strategies are implemented. The City shall verify compliance in consultation with the SLO County APCD. This measure would also apply to Alternative 1. Biological Resources MM BIO-1. Biological Mitigation and Monitoring Plan. The Applicant shall prepare and implement a Biological Mitigation and Monitoring Plan that identifies both construction and operational related avoidance, reduction, and mitigation measures for impacts to sensitive natural communities. The Biological Mitigation and The Biological Mitigation and Monitoring Plan shall be submitted for review and approval by the City prior to issuance of grading permits and recordation of The City shall review and approve the Biological Mitigation and Monitoring Plan to ensure that all BMPs and appropriate mitigation measures have been This measure would also apply to Alternative 1. 02166
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-18 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Monitoring Plan shall include Best Management Practices (BMPs) to avoid or minimize impacts to biological resources, and implementation of on and offsite habitat replacement as follows: 1) The Biological Mitigation and Monitoring Plan shall include the following construction-related measures and BMPs: a) Construction equipment and vehicles shall be stored at least 100 feet away from existing and proposed drainage features and adjacent riparian habitat, and all construction vehicle maintenance shall be performed in a designated offsite vehicle storage and maintenance area approved by the City. b) Prior to commencement of construction, Drainages 1, 2, 3, and 4 and all associated springs, seeps, and wetlands shall be protected with construction fencing located a minimum of 25 feet from the edge of the stream channel or top of bank and signed to prohibit entry of construction equipment and personnel unless authorized by the City. Fencing shall be maintained throughout the construction period for each phase of development. Fencing and signage shall be removed following completion of construction. c) During any construction activities within 50 feet of the existing Froom Creek channel, realigned Froom Creek channel, LOVR ditch, Drainages 1, 2, 3, or 4, or other existing or proposed drainage features, a City-approved biological monitor shall be present and have the authority to stop or redirect work as needed to protect biological resources. d) All construction materials (e.g., fuels, chemicals, building materials) shall be stored at designated construction staging areas, which shall be located outside of designated sensitive areas. Should spills occur, or if any unanticipated hazardous materials are discovered, materials and/or contaminants shall be cleaned immediately and recycled or disposed of to the satisfaction of the RWQCB, Department of Toxic Substances Control, and/or San Luis Obispo County Public Health Environmental Services, as applicable. the final VTM. The plan shall incorporate any additional measures or requirements identified by state and federal agencies, including but not limited to CDFW, RWQCB, NMFS, and USFWS. The Applicant shall prepare a Biological Mitigation Plan that identifies and incorporates all required measures identified in MM BIO-2 through MM BIO-12 below. The plan shall specify all mitigation site locations, timing of surveys and activities, species composition, habitat compensation, species avoidance measures, and other required information, including identification of appropriate onsite construction staging locations. The plan shall demonstrate compliance with all required measures and any required permits shall be obtained from state and federal regulatory agencies prior to the issuance of grading or building permits. A 7-year site mitigation monitoring plan shall also be prepared by the City-approved biologist and incorporated into the Biological Mitigation and Monitoring Plan prior to issuance of grading permits and recordation of the final VTM, with annual reports submitted to the City Natural Resources Manager and Community Development Department. included. The City shall ensure compliance with requirements of the Biological Mitigation and Monitoring Plan through frequent monitoring and inspection, and receipt of quarterly monitoring reports provided by the Applicant’s Environmental Coordinator required per MM BIO-2. The Applicant’s Environmental Coordinator shall also ensure compliance during habitat compensation and/or restoration activities through routine monitoring, inspection, and reporting of restoration activities. 02167
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-19 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 e) All trash and construction debris shall be properly disposed at the end of each day and dumpsters shall be covered either with locking lids or with plastic sheeting at the end of each workday and during storm events. All sheeting shall be carefully secured to withstand weather conditions. f) The Applicant shall implement measures designed to minimize construction-related erosion and retain sediment on the Project site, including installation of silt fencing, straw waddles, or other acceptable construction erosion control devices. Such measures shall be installed along the perimeter of disturbed areas and along the top of the bank of the existing and proposed Froom Creek channel and other existing or proposed drainage features and 25 feet from the edge of Drainages 1, 2, 3, and 4. All drainage shall be directed to sediment basins designed to retain all sediment onsite. g) Concrete truck and tool washout shall occur in a designated location such that no runoff will reach the creek, onsite drainages, or other sensitive areas. h) All open trenches shall be constructed with appropriate exit ramps to allow species that fall into a trench to escape. All open trenches shall be inspected at the beginning of each work day to ensure that no wildlife species is present. Any sensitive wildlife species found during inspections shall be gently encouraged to leave the Project site by a qualified biologist or otherwise trained and City-approved personnel. Trenches will remain open for the shortest period necessary to complete required work. i) Existing disturbed areas shall be used for construction staging and storage to the maximum extent possible to minimize disturbance of undeveloped habitats. All construction access roads and staging areas shall be located to avoid known/mapped habitat and minimize habitat fragmentation. MM BIO-2. Biological Construction Monitoring. The Applicant shall retain a qualified Environmental Coordinator/qualified biologist, subject to review and approval by the City to oversee The City shall approve the Applicant’s qualified Environmental The Environmental Coordinator shall monitor all grading and construction activities occurring This measure would also apply to Alternative 1. 02168
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-20 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 compliance with the Biological Mitigation and Monitoring Plan. The Applicant’s Environmental Coordinator shall monitor all construction activities, conduct a biological resources education program for all construction workers prior to the initiation of any clearing or construction activities, and provide quarterly reports to the City regarding construction activities, enforcement issues, and remedial measures. The Applicant’s Environmental Coordinator shall be responsible for conducting inspections of the work area each work day to ensure that excavation areas and sensitive or restored habitats do not exhibit construction-related impacts or hazards to wildlife. If any exposure risk is identified, the Environmental Coordinator shall implement measures that could include, but not be limited to, hazing, fencing, and wildlife removals to eliminate the exposure risk. In addition, the Applicant’s Environmental Coordinator shall monitor and regulate all construction occurring within 50 feet of the existing and proposed Froom Creek channel, other existing or proposed drainage features, riparian habitat, Drainages 1, 2, 3, and 4, and seasonal or permanent wetlands. During appropriate flowering, nesting, breeding, migration, and dispersal seasons, the Environmental Coordinator shall also conduct sensitive species surveys immediately prior to construction activities and shall monitor construction activities in the vicinity of habitats to be avoided. The work area boundaries and other off-limit areas shall be identified by the biologist and/or Environmental Coordinator on a daily basis. The biologist and/or Environmental Coordinator shall inspect construction and sediment control fencing each work day during construction activities. Any vegetation clearing activities shall be monitored by the biologist and/or Environmental Coordinator. Coordinator/qualified biologist prior to issuance of grading and building permits for each phase of construction. The Environmental Coordinator shall be present onsite to monitor construction activities pursuant to the approved Biological Mitigation and Monitoring Plan. within the vicinity of sensitive habitats or known location of sensitive species, shall conduct regular site inspections throughout the entire site, and shall be responsible for compliance of the construction activities and the above BMPs within MM BIO-1 and MM BIO-3 through MM BIO-8. During construction, the Environmental Coordinator shall submit quarterly monitoring reports to the City to ensure compliance with the Biological Mitigation and Monitoring Plan and applicable laws, regulations, and policies. The Environmental Coordinator/qualified biologist shall be onsite during all construction activities which take place within 50 feet of sensitive creek, wetland, and riparian habitat areas. MM BIO-3. Habitat Mitigation and Monitoring Plan. The Biological Mitigation and Monitoring Plan shall include a Habitat Mitigation and Monitoring Plan (HMMP) with details on timing and implementation of required habitat restoration, enhancement, or creation measures. The Biological Mitigation and Monitoring Plan and HMMP shall be prepared under the direction of, and approved by, the City’s Natural Resources Manager in conjunction with regulatory agencies with permitting authority over the Project. All requirements shall be included on the Biological Mitigation and Monitoring Plan to be submitted to the City for review and approval prior to issuance of grading permits and recordation of the final VTM. The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP to ensure that all BMPs and appropriate mitigation measures have been included. The City shall ensure compliance with requirements for the Biological This measure would also apply to Alternative 1. 02169
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-21 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 The HMMP shall contain, at a minimum, the following components (or as otherwise modified by regulatory agency permitting conditions): a) Pre-construction surveys and delineation of vegetation communities, habitat, and wetland features, including clear maps and a summary of onsite habitats to be protected and acreage, design, and locations of required habitat mitigation sites. b) A description of the location and boundaries of the mitigation site and description of existing site conditions. c) A description of measures to be undertaken to enhance the mitigation site for the target species and to protect sensitive resources. d) Record necessary replacement of disturbed, altered, and/or lost area of habitat. e) A binding long-term agreement with the Applicant to implement and maintain protected and restored sensitive habitats, including native bunch grassland, wetlands, springs, seeps, tributary drainages, and other sensitive or restored native habitats. These measures shall identify typical performance and success criteria deemed acceptable by the City and CDFW based on measurable goals and objectives. Said criteria for restored habitats shall be, at a minimum, at least 70-percent survival of container plants and 70-percent relative cover by vegetation type. f) A description of habitat and species restoration and monitoring measures, including specific and objective performance criteria, monitoring methods, data analysis, reporting requirements, and monitoring schedule. (At a minimum, success criteria shall be at least 70-percent survival of container plants and 70-percent relative cover by vegetation type and will include a replacement ratio of 2:1 and determination by a City-approved biologist that the mitigation site provides ecological functions and values for the focal species equal to or exceeding the impacted habitat.) g) Plan requirements that ensure mitigation elements that do not meet performance or final success criteria within 5 years are completed through an extension of the plan for an additional 2 years or at the discretion of the City Natural Mitigation and Monitoring Plan through frequent monitoring and inspection. The Environmental Coordinator shall also ensure compliance during habitat compensation and/or restoration activities through routine monitoring and inspection of restoration activities. 02170
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-22 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Resources Manager with the goal of completing all mitigation requirements prior to the HMMP end date. h) Monitoring of the mitigation and maintenance areas shall occur for the period established in the HMMP, or until success criteria are met; an endowment may be required in some cases as determined by the City. If success criteria cannot be met through the HMMP, the City Natural Resources Manager shall specify appropriate commensurate measures (e.g., onsite or offsite restoration, endowment, or bond to the City for completion of necessary mitigation). i) A binding long-term agreement with the Villaggio Life Plan Community to fund and retain a qualified biologist to train all landscaping crew staff hired over the life of the development on sensitive plant species and habitat within the vicinity of the development, including the identification and avoidance of sensitive plants and habitat. The qualified biologist shall conduct annual monitoring of vegetation surrounding the development and prepare a report summarizing the avoidance or disturbance of sensitive resources from operational activities of the Villaggio development, and identifying necessary replacement or restoration of affected resources. Necessary mitigation shall be subject to the same standards for performance, monitoring, and success identified in subitems b through h, above. The report shall be submitted to the City annually for review and approval. j) A plan for fencing and/or signage around the Upper Terrace of the Villaggio development, prohibiting residents, guests, and employees from accessing and disturbing the surrounding sensitive resources. k) Requirements for payment of annual fees to the City to fund City review and inspection of the site and Biological Mitigation and Monitoring Plan and HMMP requirements. MM BIO-4. Avoidance, Restoration, or Replacement of Sensitive Natural Communities. The Biological Mitigation and Monitoring Plan shall require avoidance of sensitive natural communities outside approved development footprints such as the Nassella pulchra Herbaceous Alliance, Central Coast Arroyo Willow Scrub Community, Coastal and Central Valley Freshwater Marsh, and All requirements shall be included in the Biological Mitigation and Monitoring Plan and HMMP to be submitted to the City for review and approval prior to issuance of The City shall review and approve the BMMP and HMMP to ensure that all BMPs and appropriate mitigation measures have been included. The Applicant’s Environmental This measure would also apply to Alternative 1. 02171
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-23 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 wetland areas to the maximum extent feasible. Mitigation for impacted sensitive natural communities that cannot be avoided shall be achieved through one or more of the following options, subject to City approval: a) Onsite restoration, enhancement, or creation of suitable replacement habitat, if feasible onsite restoration opportunities exist and at ratios consistent with those identified in MM BIO-5; b) Offsite restoration or creation of suitable habitat for the impacted species at the minimum replacement ratio of 2:1 for sensitive natural communities, native grasslands, and riparian habitat; c) Financial contribution to an in-lieu fee program that results in restoration or creation of suitable habitat for the impacted natural communities and/or species; and/or d) Purchase of mitigation credits at a USFWS- and/or CDFW-approved mitigation bank. grading permits and recordation of the final VTM. Coordinator shall ensure compliance during habitat compensation and/or restoration activities through routine monitoring, inspection, and reporting of restoration activities pursuant to the approved Biological Mitigation and Monitoring Plan and HMMP. The City shall ensure compliance with requirements for the Biological Mitigation and Monitoring Plan and HMMP through receipt and review of monitoring reports, and site inspections. MM BIO-5. Wetland Restoration. The Biological Mitigation and Monitoring Plan shall require all temporary and permanent direct and indirect impacts to wetlands, grasslands, and riparian habitat be mitigated, as follows: a) Temporary direct impacts to wetland, native grassland, and riparian habitat shall be mitigated at a minimum 1:1 mitigation ratio (area of restored habitat to impacted habitat). b) Permanent direct impacts to sensitive natural communities, such as native grasslands, and riparian habitat shall be mitigated at a 2:1 ratio (area of restored and enhanced habitat to impacted habitat). c) Permanent direct impacts to wetlands shall be mitigated at a minimum 3:1 ratio unless otherwise directed by state and federal agencies, including but not limited to the CDFW, RWQCB, NMFS, and USFWS (as appropriate). d) Potential indirect impacts to the Calle Joaquin wetlands affected by the Froom Creek realignment and changes to site hydrology shall be mitigated as follows. As a part of the HMMP prepared for the Project, the Applicant shall prepare and implement a Long-Term Wetland Monitoring Plan that is designed to quantitatively and qualitatively assess the All requirements shall be included in the Biological Mitigation and Monitoring Plan to be submitted to the City for review and approval prior to issuance of grading permits and recordation of the final VTM. The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP (including the Long-Term Wetland Monitoring Plan) to ensure that all BMPs and appropriate mitigation measures have been included. The Environmental Coordinator shall ensure compliance during habitat compensation and/or restoration activities through routine monitoring, inspection, and reporting of restoration activities. The City shall ensure compliance with requirements for the Biological Mitigation and Monitoring Plan and Long-Term Wetland Monitoring Plan through receipt of monitoring reports and site inspections. This measure would also apply to Alternative 1. 02172
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-24 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 effectiveness of the HMMP over time to ensure its objectives are achieved. The Long-Term Wetland Monitoring Plan shall be supported by a Baseline Conditions Assessment that identifies the pre-construction condition of the Calle Joaquin wetlands and establishes success criteria for sustained wetland conditions. The Baseline Conditions Assessment shall provide qualitative and quantitative information that will be used in comparing data obtained during subsequent monitoring years to determine if a significant deviance from baseline conditions has occurred at the site. The Long-Term Wetland Monitoring Plan will establish the parameters of a significant deviance from baseline conditions. A significant deviance from baseline may be defined as a “change in wetland area greater than 10%”. The Baseline Conditions Assessment shall be updated prior to the start of construction to support agency permitting and guide implementation of the Long-Term Wetland Monitoring Plan. This updated baseline shall be considered in combination with existing and past baseline documentation to provide an expanded baseline reflective of a range of acceptable conditions to compare post Project conditions. The Baseline Conditions Assessment shall include a focused description of the site’s hydrologic setting, vegetative cover and composition, quantified wetland areas and classifications, and shall establish the threshold for a significant deviance from wetland area based on the presence of hydrophytic plant species, hydric soil indicators, and wetland hydrology. At minimum, the condition of the wetland shall be evaluated on an annual basis through completion of a wetland assessment using a regulatory agency approved model (such as, but not limited to, the California Rapid Assessment Method [CRAM]) to document and facilitate long-term monitoring of changes to the wetland. The annual evaluation shall determine and document any degree of change to the wetland as a result of the proposed changes to site hydrology and development throughout build-out under the Specific Plan. Reports documenting the annual wetland assessment shall be provided to the City and relevant regulatory agencies. 02173
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-25 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Long-Term Wetland Monitoring for the Calle Joaquin wetlands shall occur continuously for a period of no less than 7 years following Phase I build-out of the Froom Ranch Specific Plan area. After the initial 7-years of minimum annual monitoring, the frequency of long-term evaluations shall be determined in coordination with regulatory agencies and per the requirements of the Long-Term Wetland Monitoring Plan. The Long-Term Wetland Monitoring Plan shall include (at minimum) the following requirements. Additional detailed criteria and performance standards will be established in the HMMP prepared for the project and approved by regulatory agencies, but they shall not be any less stringent than the following criteria and performance standards: i. Annual monitoring shall evaluate and track the wetland health and biological integrity of the Calle Joaquin wetlands. ii. Annual evaluations shall utilize intensive site assessments to provide a more thorough and detailed measure of wetland condition by gathering direct measurements of biological taxa and hydrogeomorphic functions. iii. Typical industry standards for the quantitative evaluation of plant cover will be used (e.g., Bonham 1989 and Daubenmire 1968) to evaluate plant composition and structure as well as direct inspections of soil conditions and hydrologic functions. iv. Annual or semi-annual evaluations shall observe and document the following, at a minimum: whether groundwater recharge from Froom Creek to the shallow aquifer is being sustained, whether the onsite artesian well has been discharging to the wetland, evidence of overflows entering the Calle Joaquin wetland from the realigned Froom Creek, excessive ponding, as evidenced by changes in vegetation related to increased duration of ponding, 02174
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-26 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 measured depth to groundwater in the onsite artesian well and the relationship of these conditions with conditions in the wetland, specific conductance and temperature in the wetland and other surface sources, the presence or absence of salt efflorescences in the wetland, any persistent green vegetation patches or changes in willow/grass ecotone, and representative photo points. v. Monitoring of the realigned creek’s hydrology would be required following large storm events during the rain season that are sufficient to initiate flowing water through the site. If after the 3rd year of monitoring, vegetation has successfully established along the creek corridor and sedimentation and erosion are not observed beyond what is determined to be a normal level, then the rainy season monitoring could be scaled back to occur on a quarterly or as-needed basis for the remainder of the monitoring schedule, upon review and approval of the City’s Natural Resources Manager and applicable regulatory agencies and consistent with the Long-Term Wetland Monitoring Plan. vi. Success criteria to determine whether the Calle Joaquin wetland functions are sustained shall include the following, at a minimum: The constructed bank between the realigned Froom Creek channel and the Calle Joaquin wetlands remains functional and does not recurrently scour or fill to a degree that impairs its operation or impedes circulation through the wetland, Excessive surface water does not pond for periods of long duration, Salts do not accumulate such that discernible increases in salt efflorescences at the ground surface are not visible, 02175
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-27 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Evidence of deposition by high flows is not found within the wetland (e.g., silt, organics, or other flood deposits). vii. If success criteria are not achieved within the 7-year initial monitoring period, a hydrologic assessment will be conducted by a USACE-approved specialist in groundwater supported wetlands to establish whether non-attainment is attributable to onsite conditions or actions beyond the effective control of the Project Applicant. The specialist shall be a registered hydrologist or certified hydrogeologist with statewide expertise, familiarity with groundwater supported wetlands in central coastal California and verifiable experience conducting functional analyses of such wetlands. Recommendations for remedial actions will be submitted by the groundwater specialist to the USACE for review and written approval prior to implementation. If wetland failures are determined to be directly related to the realignment of Froom Creek and development within the Froom Creek Specific Plan area, possible remedial actions would include, at minimum, the following: Engineering controls include biotechnical erosion controls such as the installation of willow wattles and brush mattressing and addition of native cobble to reinforce the low flow berm separating the creek channel from the wetland area to help contain flows into the wetland area. If vegetation establishment is taking longer than expected, remedial measures such as re-seeding bare soils, replanting areas of mortality, and increased maintenance and monitoring may be prescribed. If there is significant evidence of scouring, collapse, or filling of the overflow bank between the realigned low-flow Froom Creek channel and the Calle Joaquin wetlands, a registered professional engineer shall re-evaluate bank type, 02176
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-28 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 size, and slope and recommend a solution, such as augmentation or replacement. If there is excessive ponding (spatial or temporal), a registered professional engineer shall assess access to and capacity of existing drainage outlets and recommend a solution, such as augmentation or replacement if necessary. If salt efflorescence is observed and specific conductance in the wetland is greater than baseline conditions, a registered professional engineer shall re-evaluate the bank type, slope, size, and conveyance between the realigned Froom Creek low-flow channel and the Calle Joaquin wetlands to increase the frequency of salt flushing, such as altering surface flows to more frequently overflow to the wetland area. viii. If through monitoring it is determined that the Project does not adversely impact the Calle Joaquin wetland areas (as defined above), the Applicant shall provide documentation annually (at minimum) to the City, for review and approval by the City’s Natural Resources Manager, that no significant signs of hydrological interruption, erosion (including bank failure), or sedimentation have occurred, that the wetland is sustained in biological integrity and health with existing hydrologic inputs, and that channel migration has not adversely affected existing wetland features adjacent to Calle Joaquin. ix. If through monitoring it is determined that the Project adversely impacts the Calle Joaquin wetland area, recommendations shall be made for modifications to the Project design in consultation with the City and appropriate regulatory agencies for review and concurrence, as described in subsection viii above. The annual reports would detail the issue or problem area and proposed remedial actions. x. If through monitoring it is determined that the Calle Joaquin wetland condition and function cannot be remediated with implementation of all feasible 02177
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-29 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 remedial actions and recommendations identified through long-term monitoring and as described in subsection vii above and the Long-Term Wetland Monitoring Plan, then adversely affected wetland areas shall be delineated and mitigated on- or offsite at a minimum 3:1 ratio unless otherwise directed by state and federal agencies, including but not limited to the CDFW, RWQCB, NMFS, and USFWS (as appropriate), consistent with subsection (c) above. xi. Funding for long-term wetland monitoring, adaptive management, and any recommended contingency measures shall be the responsibility of the Applicant. Payment of a bond by the Applicant would be required to ensure the availability of adequate funds to ensure successful implementation and completion of the Long-Term Wetland Monitoring Plan throughout build-out under the Specific Plan. e) Habitat revegetation or creation shall occur in the fall or winter no more than 1 year following habitat disturbance. Revegetation shall be monitored monthly for 7 years with a goal of at least 70-percent survival of container plants and 70-percent relative cover by vegetation type at the end of the 7-year period. Irrigation shall be provided during this period or until otherwise determined necessary by the Applicant’s Environmental Coordinator. f) Riparian vegetation along Froom Creek shall be maintained in perpetuity to the satisfaction of the City by the Applicant or a City-approved designee. Froom Creek conditions shall be monitored annually following winter storm seasons to assess damage to riparian vegetation and need for maintenance restoration. Monitoring and maintenance of riparian vegetation conditions shall be conducted consistent with the requirements of the Habitat Mitigation and Monitoring Plan outlined in MM BIO-3. MM BIO-6. Habitat Restoration Requirements. The Biological Mitigation and Monitoring Plan shall detail timing and implementation of required habitat restoration and shall be submitted to the City’s Natural Resources Manager for review and approval, including requirements for consultation with CDFW, All requirements shall be included on the Biological Mitigation and Monitoring Plan and HMMP to be submitted to the City for review and approval prior to issuance of The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP to ensure that all BMPs and appropriate mitigation measures This measure would also apply to Alternative 1. 02178
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-30 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 NMFS, and USACE as needed. A copy of the final plan shall be submitted to the City for review and approval. The plan shall be implemented by the Project Applicant, under supervision by the City and the Applicant’s Environmental Coordinator, and shall: a) Describe replacement of sensitive natural community habitats removed, lost, or adversely impacted by the Project, including a list of the soil, plants, and other materials that will be necessary for successful habitat restoration/ replacement, and a description of planting methods, location, spacing, erosion protection, and irrigation measures that will be needed. Restoration and habitat enhancement shall be limited to use of appropriate native species. Habitat restoration or enhancement areas shall be designed to facilitate establishment of appropriate native plants such as willows, cottonwoods, bunchgrass, and rushes. b) Habitat restoration or enhancement areas shall be established within the Project boundaries, adjacent to and contiguous with existing habitats to the maximum extent possible. c) Habitat restoration or enhancement sites shall be placed within existing or additional necessary deed-restricted area(s) and shall be maintained and monitored for a minimum of 7 years. If sufficient onsite mitigation area is not practicable, an offsite mitigation plan shall be prepared as part of the Biological Mitigation and Monitoring Plan and approved by permitting agencies. d) The Biological Mitigation and Monitoring Plan shall identify appropriate restoration and enhancement activities to compensate for impacts to creek, wetland, native bunch grass and riparian habitat, including a detailed planting plan and maintenance plans using locally obtained native species, and shall include habitat enhancement to support native wildlife and plant species. e) A weed management plan and weed identification list shall be included in the Biological Mitigation and Monitoring Plan. f) Habitat restoration or enhancement areas shall be maintained weekly for the first three years after Project completion and quarterly thereafter. Maintenance shall grading permits and recordation of the final VTM. have been included. The Environmental Coordinator shall ensure compliance during habitat compensation and/or restoration activities. The City shall ensure compliance with requirements for the Biological Mitigation and Monitoring Plan and HMMP through receipt of monitoring reports and site inspections. 02179
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-31 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 include replacement of unsuccessful planted specimens and eradication of noxious weeds found on California Department of Food and Agriculture (CDFA) Lists A and B. Noxious weeds on CDFA List C may be eradicated or otherwise managed. g) Quarterly and annual reports documenting site inspections and site recovery status shall be prepared and sent to the City and appropriate agencies. MM BIO-7. Horizontal Directional Drilling Requirements. Utility line installation shall be timed so that sensitive habitat areas are not disturbed (e.g., prior to the development and restoration of the new Froom Creek realignment, after removal of riparian areas along the LOVR Ditch due to LOVR widening). In the event a utility line is proposed to be installed across the existing or realigned Froom Creek, or the sensitive riparian areas along the LOVR Ditch, while these features are in their natural or restored conditions, installation via horizontal directional drilling (HDD) to avoid impacts to sensitive habitats. Prior to installation of utility lines, a site-specific geotechnical investigation and frac-out clean-up plan shall be completed in areas proposed for HDD. The geotechnical investigation shall provide recommendations for avoidance of frac-outs and/or other HDD related impacts and to determine appropriate HDD methods (i.e., appropriate drilling mud mixtures for specific types of sediments). The investigation shall include results from at least three borings, a geologic cross-section, a discussion of drilling conditions, and frac-out clean-up plan. The frac-out clean-up plan shall identify methods for minimizing potential for frac-outs and addressing any necessary clean-up or remediation in case of a frac-out. The boring operation would be stopped immediately if a frac-out occurs and steps would be taken to contain and minimize the effects of any spill of drilling mud. The Applicant shall comply with all recommendations of the geotechnical investigation. Geotechnical investigations shall be conducted, and a report of findings submitted to the City for approval. The findings shall be incorporated into the final Utilities Plan prior to issuance of grading permits and recordation of the final VTM. The City shall review the findings of the geotechnical investigations and final Utilities Plan and confirm compliance through review of grading and improvement plans. This measure would also apply to Alternative 1. MM BIO-8. Stabilization of the Froom Creek Channel to Prevention Creek Migration. The Applicant shall submit a Froom Creek restoration plan that identifies measures for securing the proposed low-flow channel berm along the stretch of Froom Creek proposed adjacent to the Calle Joaquin wetlands to protect the bank from erosion and prevent migration of the Froom Creek channel The Applicant shall submit a Froom Creek restoration plan for review and approval by the City, which incorporates these requirements in addition to all requirements identified by state The City shall review the final plans, and shall inspect the Project site during construction to confirm installation of proposed stabilization measures. This measure would also apply to Alternative 1. 02180
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-32 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 into these wetlands. Measures for securing the bank may include a mix of natural and biotechnical measures capable of prevention erosion based on the anticipated erosive velocity of the creek under 100-year storm conditions. and federal resource agencies. The proposed bank stabilization measures shall be depicted on final plans prior to issuance of grading permits and recordation of the final VTM. MM BIO-9. Froom Creek Habitat Restoration. Construction and grading of the realigned portion of Froom Creek, including planting of riparian vegetation, watering, and bank stabilization, shall be conducted prior to removal of the existing creek segment to ensure a habitat for special-status species within the creek is maintained through the Project site with no interruption during construction. Project phasing shall be adjusted as needed to accommodate this sequence of construction activities. The Applicant shall demonstrate phasing and creek restoration within the final VTM, and the Biological Mitigation and Monitoring Plan. The Applicant shall submit the plan to the City for review and approval prior to issuance of grading permits and recordation of the final VTM. The City shall review the Biological Mitigation and Monitoring Plan, and final VTM for compliance. The Applicant’s Environmental Coordinator shall monitor creek realignment activities to ensure compliance with this mitigation measure. This measure would also apply to Alternative 1. MM BIO-10. Chorro Creek Bog Thistle and Special-Status Plant Management. Prior to issuance of grading and building permits, the Applicant shall submit or fund a site survey for special-status plants, including Chorro Creek bog thistle, and: 1. All individual locations of special-status species, including Chorro Creek bog thistle, and suitable habitat areas shall be mapped using GPS coordinates. No construction activities or disturbance shall occur within 50 feet of mapped special-status species, including Chorro Creek bog thistle, or suitable habitat areas. This setback shall be delineated and maintained with construction fencing and clear signage for the duration of grading and construction. If the site survey results identify Chorro Creek bog thistle that may be disturbed or lost from Project construction, the Project shall be redesigned to ensure a minimum 50 foot buffer from mapped Chorro Creek bog thistle occurrences. 2. Development adjacent to Drainages 1, 2, and 3 shall be set back a minimum of 50 feet from the top of the bank of these drainages and the edge of delineated associated wetlands. 3. Drainages 1, 2, and 3 and associated wetlands shall be fenced a minimum of 50 feet from the top of the bank or edge of delineated wetland during construction. The Applicant shall ensure and demonstrate to the City through frequent reporting requirements approved by the City that these areas All requirements shall be included on the Biological Mitigation and Monitoring Plan to be submitted to the City for review and approval prior to issuance of grading permits and recordation of the final VTM. The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP to ensure that all BMPs and appropriate mitigation measures have been included. The City shall ensure compliance with requirements for the Biological Mitigation and Monitoring Plan. The Applicant’s Environmental Coordinator shall also ensure compliance during habitat compensation and/or restoration activities. This measure would also apply to Alternative 1. 02181
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-33 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 are managed and maintained in perpetuity to maintain wetland and Chorro Creek bog thistle habitat values to the extent feasible. 4. If the site survey results identify special-status plant species, including Chorro Creek bog thistle, or suitable habitat that may be disturbed or lost from Project construction, the Project shall be redesigned to ensure a minimum 50-foot buffer from mapped individual occurrences and suitable habitat areas. If buffers cannot be maintained, then consultation with CDFW shall occur to determine appropriate minimization and mitigation measures for impacts to special-status plant species, or in the case of plant species listed pursuant to CESA or the Native Plant Protection Act, to determine if take can be avoided. If take cannot be avoided, take authorization prior to any ground-disturbing activities may be warranted. Take authorization would occur through issuance of an ITP by CDFW, pursuant to Fish and Game Code section 2081(b). MM BIO-11. Special-Status Wildlife Species Management. The Biological Mitigation and Monitoring Plan shall address special-status wildlife species management. Grading and construction activities shall avoid the rainy season (typically October 15 to April 15) to the extent practicable, particularly within 50 feet of the existing and proposed Froom Creek channel, and other existing or proposed drainage features, riparian or wetland habitat, and any suitable nesting sites as determined by the City-approved biologist. Injury, mortality to, or significant disturbance of onsite sensitive species, including the California red-legged frog, south-central California coast steelhead, and white-tailed kite, shall be avoided. The plan shall include the following measures: pre-construction surveys; worker awareness; cessation of work in occupied areas if individuals are identified; relocation (if necessary) of frogs and steelhead from the work area by a professional biologist authorized by the USFWS and/or CDFW; and monitoring of construction activities within the vicinity of sensitive habitats by a qualified biologist during construction, consistent with MM BIO-2. Necessary permits shall be obtained from the state (CDFW) and federal (USACE and USFWS) regulatory agencies with jurisdiction and/or permitting authority over a portion of the Project. Any other All requirements shall be included on the Biological Mitigation and Monitoring Plan to be submitted to the City for review and approval prior to issuance of grading permits and recordation of the final VTM. The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP to ensure that all BMPs and appropriate mitigation measures have been included. The City shall ensure compliance with requirements in the Biological Mitigation and Monitoring Plan. The Applicant’s Environmental Coordinator shall also ensure compliance during habitat compensation and/or restoration activities. This measure would also apply to Alternative 1. 02182
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-34 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 sensitive species observed during the pre-construction surveys shall be relocated by the qualified biologist into the nearest suitable habitat outside the disturbance area as determined in consultation with the appropriate jurisdictional resource agency. MM BIO-12. Animal Migration and Nest/Burrow and Roost Avoidance. The Biological Mitigation and Monitoring Plan shall address the habitation and movement of special-status wildlife species, as follows: 1. Migratory and Nesting/Burrowing Bird Management. Grading and construction activities shall avoid the breeding season (typically from February 15 to August 15) to the extent practicable, particularly within 50 feet of riparian or wetland habitat and mature trees and within onsite grasslands. If Project activities must be conducted during this period and within the vicinity of riparian or wetland habitat, grasslands, and/or mature trees, pre-construction nesting bird surveys shall take place no more than one week prior to habitat disturbance associated with each phase; if active nests or burrows are located during these surveys, the following measures shall be implemented: a. Construction activities within 50 feet of active nests shall be restricted until chicks have fledged, unless the nest belongs to a raptor or burrowing owl, in which case a minimum 500-foot activity restriction buffer shall be observed. b. Construction shall be limited to daylight hours (7:00 AM to 7:00 PM or sunset, whichever is sooner). c. A pre-construction survey report shall be submitted to the City immediately upon completion of the survey. The report shall detail appropriate fencing or flagging of the buffer zone and make recommendations on additional monitoring requirements. A map of the Project site and nest locations shall be included with the report. If any sensitive species are observed during pre-construction surveys, the Project biologist shall coordinate with appropriate resource agencies to determine appropriate procedure for handling or avoidance of the specimen. The Biological Mitigation and Monitoring Plan shall include a management plan for migrating and nesting birds and bat colonies and shall be submitted for review and approval by the City prior to issuance of grading and construction permits and recordation of the final VTM. Construction shall be conducted between August 16 and February 14 unless pre-construction surveys are completed. Reports summarizing pre-construction species surveys (i.e., nesting, bat surveys, etc.) shall be submitted to the City within 10 days of survey completion. Construction work shall not commence until after the completion of surveys and City review of corresponding reports. Any required permits shall be obtained from appropriate state and federal agencies prior to issuance of grading and construction permits and recordation of the final VTM. The City shall review and approve the Biological Mitigation and Monitoring Plan and HMMP to ensure that appropriate requirements have been included to address potential impacts to bird and bat species. The City shall ensure compliance with requirements for the Biological Mitigation and Monitoring Plan. The Applicant’s Environmental Coordinator shall also ensure compliance during habitat compensation and/or restoration activities. This measure would also apply to Alternative 1. 02183
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-35 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 d. The Project biologist conducting the nesting survey shall have the authority to reduce or increase the recommended buffer depending upon site conditions and the species involved. A report of findings and recommendations for bird protection shall be submitted to the City prior to vegetation removal. If sensitive or special-status species are observed during pre-construction surveys, the Project biologist shall coordinate with appropriate resource agencies to determine appropriate procedures for handling or avoidance of the specimen. e. If burrowing owls are found onsite and avoidance is not possible, burrow exclusion shall be conducted by City-approved qualified biologists and only during the non-breeding season, before breeding behavior is exhibited and after the burrow is confirmed empty through non-invasive methods, such as surveillance. CDFW recommends replacement of occupied burrows with artificial burrows at a ratio of one burrow collapsed to one artificial burrow constructed (1:1) To avoid recolonization, ongoing surveillance shall be provided by the City-approved Project biologists throughout Project construction at a rate that is sufficient to detect burrowing owls if they return. 2. Bat Colony Management. Prior to removal of any trees over 20 inches diameter-at-breast-height (DBH) or demolition/relocation of existing onsite structures, a survey shall be conducted by a City and CDFW-approved biologist to determine if any tree or structure proposed for removal, trimming, demolition, or relocation harbors sensitive bat species or maternal bat colonies. Maternal bat colonies shall not be disturbed, and grading and construction activities shall avoid the bat breeding season to the extent feasible. If disturbance of structures must occur during the bat breeding season, buildings must be inspected and deemed clear of bat colonies/roosts within 7 days of demolition and an appropriately trained and approved biologist must conduct a daily site-clearance during demolition. If bats are roosting in a structure or tree in the Project site during the daytime but 02184
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-36 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 are not part of an active maternity colony, then exclusion measures shall be utilized and must include one-way valves that allow bats to leave but are designed so that the bats may not re-enter the structure. For each occupied roost removed, one bat box shall be installed in similar habitat as determined by the Project biologist and shall have similar cavities or crevices to those which are removed, including access, ventilation, dimensions, height above ground, and thermal conditions. If a bat colony would be eliminated from the Project site, appropriate alternate bat habitat shall be installed within the Project site. To the extent practicable, alternate bat house installation shall occur near onsite drainages. MM BIO-13. Froom Creek Confluence Buffer Requirements. The Applicant shall amend the FRSP to establish a 300-foot development buffer on the centerline of the confluence of Drainage 1, 2, and 3 and the realigned Froom Creek to maintain natural vegetation, ecological, hydrologic, and wildlife connectivity between the Irish Hills Natural Reserve and the Froom Creek corridor. The required buffer shall extend from the point at which the proposed realigned Froom Creek exits the Specific Plan area, upstream along the centerlines of Drainages 1, 2, and 3 for 600 linear feet. The Applicant shall relocate residential uses to areas outside of this buffer and should not exacerbate biological resource impacts in other areas of the site. The above requirements shall be integrated into the Final FRSP and final VTM prior to recordation. City staff shall ensure the above measures are incorporated into building plans prior to issuance. The City shall ensure the above measure is incorporated into the Final FRSP prior to Project approval. This measure would also apply to Alternative 1. MM BIO-14. Design of Safe Wildlife Passage. Proposed roadway/pathway crossings over any drainage shall be designed to ensure adequate passage for wildlife, consistent with the design standards and guidelines of the Federal Highway Administration Wildlife Crossing Structure Handbook. The above requirements shall be integrated into the Final FRSP. City staff shall ensure the above measures are incorporated into the improvement plans prior to approval. The City shall ensure the above measure is incorporated into the Final FRSP prior to Project approval. This measure would also apply to Alternative 1. MM BIO-15. Native Tree Protection. To ensure protection of native protected trees with respect to the tree trunk, canopy, and root zone, the Applicant shall hire a City-approved arborist or qualified biologist to conduct a daily, pre-construction survey of all activities occurring within the protected root zones of protected trees, and shall make recommendations for avoidance, and for any necessary remedial work to ensure the health and safety of trees that are encroached, and any measures necessary to reduce and/or All requirements shall be included on final grading plans. The qualified biologist shall monitor for the health of trees during and following construction activities, for a period of up to 5 years if determined necessary by the City. The qualified biologist shall monitor all construction activities, and if necessary, periodically monitor the placement and planting program. City staff shall monitor for the health of affected individuals to determine compliance and This measure would also apply to Alternative 1. 02185
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-37 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 remove potential safety hazards posed by any of these trees. Following construction, the health of affected trees shall be monitored by the arborist or qualified biologist for up to 5 years if necessary and as determined at the discretion of the City. Should Project activities result in the compromised health of native trees resulting from encroachment, the Applicant shall submit a native tree replacement planting program, prepared by a qualified biologist, arborist, or other resource specialist, which specifies replacement tree locations, tree or seedling size, planting specifications, and a monitoring program to ensure that the replacement planting program is successful, including performance standards for determining whether replacement trees are healthy and growing normally, and procedures for periodic monitoring and implementation of corrective measures in the event that the health of replacement trees declines. Where the worsened health of a tree results in the loss of protected tree species, mitigation measures in the native tree replacement program shall include the planting of replacement trees on the Project site, if suitable area exists. Riparian trees 4 inches or greater measured at DBH shall be replaced in-kind at a minimum ratio of 3:1 (replaced: removed). Trees 24 inches or greater inches DBH shall be replaced in-kind at a minimum ratio of 10:1. Willows and cottonwoods may be planted from live stakes following guidelines provided in the California Salmonid Stream Habitat Restoration Manual for planting dormant cuttings and container stock (CDFW 2010). Tree replacement shall be conducted in accordance with a Natural Habitat Restoration and Enhancement Plan to be approved by the City’s Natural Resources Manager. The Natural Habitat Restoration and Enhancement Plan shall prioritize the planting of replacement trees on-site where feasible, but shall allow that replacement trees may be planted off-site with approval of the City’s Natural Resources Manager. Replacement trees may be planted in the fall or winter of the year in which trees were removed. All replacement trees will be planted no more than 1 year following the date upon which the native trees were removed. potential need for further mitigation. 02186
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-38 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Where onsite mitigation through planting replacement trees is not feasible, mitigation shall be provided by one of the following methods: Off-site mitigation shall be provided by planting no less than 10:1, at a suitable site that is restricted from development or is public parkland. The Applicant shall plant seedlings – less than 1-year old – in an area providing suitable habitat. In the case of oak trees, the seedlings shall be grown from acorns collected in the area; or An in-lieu fee shall be provided for the unavoidable impacts of the loss of native tree habitat. The fee shall be based on the type, size and age of the tree(s) removed. MM BIO-Alt. 1. Emergency Access Roadway Riparian and Wetland Restoration. The additional emergency access roadway across Froom Creek and the LOVR ditch and the southern emergency access route entering the site from Calle Joaquin shall be reviewed by the City’s Public Works Department, Community Development Department, Natural Resources Manager, and Fire Department prior to adoption of the Final FRSP and approval of the Vesting Tentative Tract Map to ensure that design is adequate for City emergency ingress/egress standards and minimizes impacts to riparian vegetation and wildlife passage, and that adequate on- and offsite mitigation of impacted riparian and wetland vegetation is provided. The City shall ensure review and approval of these features as part of the Final FRSP considers the siting, alignment, width, materials, and access controls. The Applicant is required to implement the above mitigation measures prior to FRSP and VTM approval. The access roads shall be integrated into the VTM preliminary grading plan. City staff shall ensure the above measures are incorporated into the FRSP and VTM prior to acceptance of the final FRSP. The City shall ensure the above measure is incorporated into the Final FRSP and VTM prior to Project approval. This measure would apply only to Alternative 1. Cultural Resources MM CR-1. Phase 2 - Subsurface Archaeological Resources Evaluations. A Phase 2 – Subsurface Archaeological Resource Evaluation (SARE) investigation shall be conducted prior to any grading or development proposed within 200 feet of the recorded P-40-000783 and P-40-001195 sites, or the unrecorded site comprising three mapped stone isolates, to evaluate the potential for unknown buried resources within these “archaeologically sensitive” areas, including but not limited to stone, bone, glass, ceramics, fossils, wood, or shell artifacts, or features including hearths, structural remains, or historic dumpsites, consistent with City Archeological Resource Preservation Program Guidelines. If discovery of unknown buried archaeological resources occurs Any required Phase 2 SARE investigations shall be conducted by a City-approved archaeologist prior to approval of the VTM or Project entitlements. The City shall ensure the Phase 2 SARE investigations are completed by a City-approved archaeologist and consistent with City Archeological Resource Preservation Program Guidelines. Any potential modifications to the Project design shall be reviewed and approved by the City prior to approval of any subdivision map or other entitlement. This measure would also apply to Alternative 1. 02187
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-39 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 through the SARE, a City-approved archaeologist shall evaluate the significance of the discovery pursuant to City Archaeological Resource Preservation Program Guidelines and CEQA. If the discovery is found to be a significant cultural resource, Project design shall be modified to avoid modification, disturbance, or destruction of the archeological resource. If the Phase 2 SARE investigations do not discover unknown buried archaeological resources but conclude there is a possibility that cultural resources exist within the archaeologically sensitive areas that were evaluated, the Community Development Department Director shall require that the Applicant retain a City-approved archaeologist and local Native American observer to monitor construction activities to identify and protect archaeological resources in accordance with the Archaeological Monitoring Plan described in MM CR-3. MM CR-2. Designation of Environmentally (Culturally) Sensitive Areas. If any ground disturbing activities are proposed within 100 feet of the recorded sites P-40-000783, P-40-0011195, or the unrecorded site comprising three mapped stone isolates, on preparation of construction plans, the plans shall delineate a 50-foot buffer surrounding the boundaries of the recorded sites. The area shall be labeled as an “Environmentally Sensitive Area”. Highly visible temporary construction fencing shall be installed along the boundary of the 50-foot buffer and shall remain in place until the archaeological monitor recommends removal. If feasible, no ground disturbance, construction worker foot traffic, storage of materials, or storage or use of equipment shall occur within the “Environmentally Sensitive Area”. Archaeological monitoring shall occur during all construction activities occurring within 50 feet of the delineated boundary. Upon completion of archaeological monitoring, an archaeological monitoring report shall be prepared and submitted to the City Community Development Department and the Central Coast Information Center at the University of California Santa Barbara. Prior to recordation of the final VTM and issuance of grading permits, plans shall incorporate the delineation of the “Environmentally Sensitive Area” and associated protection measures. The City shall verity that required elements are shown on the final VTM and grading permits. Compliance shall be verified pursuant to the approved Archaeological Monitoring Plan. This measure would also apply to Alternative 1. MM CR-3. Archaeological Monitoring Plan. Prior to issuance of grading or building permits, and recordation of the final map, an Archaeological Monitoring Plan (AMP) shall be prepared. The AMP should include, but not be limited to, the following: a. A list of personnel involved in the monitoring activities; b. Description of Native American involvement; The AMP shall be prepared by a City-approved archaeologist prior to issuance of grading or building permits and recordation of the final map. The City shall ensure the AMP is prepared by a City-approved archaeologist and consistent with City Archeological Resource Preservation Program Guidelines. This measure would also apply to Alternative 1. 02188
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-40 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 c. Description of how the monitoring shall occur; d. Description of location and frequency of monitoring (e.g., full time, part time, spot checking); e. Description of what resources are expected to be encountered; f. Description of circumstances that would result in the halting of work at the project site; g. Description of procedures for halting work on the site and notification procedures; h. Description of monitoring reporting procedures; and i. Provide specific, detailed protocols for what to do in the event of the discovery of human remains. MM CR-4. Archaeological Construction Monitoring. The Applicant shall retain a City-approved archaeologist and local Native American observer to monitor Project-related ground-disturbing activities that have the potential to encounter previously unidentified archaeological resources, as outlined in the AMP prepared to satisfy MM CR-1. Archaeological and tribal monitoring may cease only if the City-approved archaeologist determines in coordination with the Applicant, Community Development Director, and the Native American monitor that Project activities do not have the potential to encounter and/or disturb unknown resources. The conditions for monitoring and treatment of discoveries shall be printed on all building and grading plans. Prior to issuance of building and grading permits for each phase of the Project, the Applicant shall submit to the City a contract or Letter of Commitment with a qualified archaeologist and Native American monitor. The City shall review and approve the selected archaeologist to ensure they meet appropriate professional qualification standards, consistent with the City’s Archeological Resource Preservation Guidelines. City permit compliance staff shall confirm monitoring by the archaeologist and tribal representative and City grading inspectors shall spot check fieldwork. The Native American monitor and Project archaeologist shall ensure that actions consistent with this mitigation measure are implemented in the event of any inadvertent discovery. This measure would also apply to Alternative 1. MM CR-5. Inadvertent Discovery of Archaeological Resources. In the event of any inadvertent discovery of prehistoric archaeological resources, including but not limited to stone, bone, glass, ceramics, fossils, wood, or shell artifacts, or historic-period archaeological resources, all work within 100 feet of the discovery shall immediately cease (or greater or lesser distance as needed to protect the discovery and determined in the field by the City-approved archaeologist). The Applicant and/or contractor shall immediately notify the City Community Development Department. The City-approved archaeologist shall evaluate the significance of the discovery pursuant to City Archaeological Resource Preservation Program Guidelines prior to resuming any activities The conditions for monitoring and treatment of discoveries shall be printed on all building and grading plans. Prior to issuance of building and grading permits for each phase of the Project, the Applicant shall submit to the City a contract or Letter of Commitment with identified Project archaeologist and Native American monitor. The City shall review and approve the selected archaeologist to City permit compliance staff shall confirm monitoring by the archaeologist and tribal representative and City grading inspectors shall spot check fieldwork. The Native American monitor and Project archaeologist shall ensure that actions consistent with this mitigation measure are implemented in the event of any inadvertent discovery. This measure would also apply to Alternative 1. 02189
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-41 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 that could impact the site/discovery. If the City-approved archaeologist or Native American monitor determine that the find may qualify for listing in the CRHR or as a tribal cultural resource, the site shall be avoided or shall be subject to a Phase II or III mitigation program consistent with City Archeological Resource Preservation Program Guidelines and funded by the Applicant. Work shall not resume until authorization is received from the City. ensure they meet appropriate professional qualification standards, consistent with the Archeological Resource Preservation Program Guidelines. MM CR-6. Construction Worker Cultural Resource Education Program. Prior to construction of each phase, workers shall receive education regarding the recognition of possible buried cultural remains and protection of all cultural resources, including prehistoric and historic resources, during construction. Such training shall provide construction personnel with direction regarding the procedures to be followed in the unlikely event that previously unidentified archaeological materials, including Native American burials, are discovered during construction. Training shall also inform construction personnel that unauthorized collection or disturbance of artifacts or other cultural materials is not allowed. The training shall be prepared by a City-approved archaeologist and shall provide a description of the cultural resources that may be encountered in the Project site, specify areas of known sensitivity, outline steps to follow in the event that a discovery is made, and provide contact information for the City-approved archaeologist, Native American monitor, and appropriate City personnel. The training shall be conducted concurrent with other environmental or safety awareness and education programs for the Project, provided that the program elements pertaining to archaeological resources is provided by a qualified instructor meeting applicable professional standards. Prior to ground disturbance for each phase, construction workers shall participate in an educational program that will enable them to recognize and report possible buried cultural remains and protect all cultural resources, including prehistoric and historic resources. The educational program shall be outlined within the Archaeological Monitoring Plan and submitted to the City for approval prior to issuance of grading permits for each phase. The City-approved archaeologist shall verify the training has been completed by all construction workers and shall ensure construction workers follow cultural resource discovery protocols. This measure would also apply to Alternative 1. MM CR-7. Inadvertent Discovery of Human Remains. If human remains are exposed during construction, the City Community Development Department shall be notified immediately. The Applicant and City shall comply with State Health and Safety Code Section 7050.5, which states that no further disturbance shall occur until the County Coroner has been notified and can make the necessary findings as to origin and disposition of the remains pursuant to PRC Section 5097.98. Construction shall halt around the discovery of human remains, the area shall be protected, and consultation and treatment shall occur as prescribed by law. The conditions for monitoring and treatment of discoveries shall be printed on all building and grading plans and reflected in the AMP. City permit compliance staff shall confirm monitoring by the City-approved archaeologist and tribal representative and City grading inspectors shall spot check fieldwork. The Native American monitor and City-approved archaeologist shall ensure that actions consistent with this mitigation measure are This measure would also apply to Alternative 1. 02190
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-42 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 implemented in the event of any inadvertent discovery. MM CR-8. Avoidance of Prehistoric and Tribal Cultural Resource Sites. No designated recreational areas, facilities, pedestrian paths, or roadways shall be located with 50 feet of a known prehistoric or tribal cultural resource site. All archaeological site soils within 100 feet of a known prehistoric or tribal cultural site shall be seeded with native shallow rooted native vegetation unless existing natural vegetation (i.e., existing grasslands) can screen the cultural resource from view. The Draft FRSP shall be amended to incorporate these measures as they apply to P-40-000783 or P-40-001195 and the unrecorded site, prior to adoption of the Final FRSP. A City-qualified archaeologist shall review and approve the established buffer between Project development and known cultural resource sites and review vegetation seeding covering the archaeological site boundaries prior to issuance of occupancy. This measure would also apply to Alternative 1. MM CR-9. Historic Resource Construction Monitoring. The Applicant shall retain a qualified professional historic architect meeting the Secretary of the Interior’s Professional Qualifications Standards (36 CFR Part 61) to review and comment on design and construction drawings and monitor construction to ensure conformance with the Secretary of the Interior’s Standards. The role of the historic architect shall include collaboration on a range of items relating to materials selection, construction methods, design of exterior and interior alterations, and monitoring of construction activities. The historic architect and Applicant shall resolve any unforeseen circumstance in a manner that conforms with the Secretary of the Interior’s Standards. The qualified professional historic architect shall work with the Applicant team to ensure: a) Deteriorated historic features would be repaired to the greatest extent feasible. Where features are deteriorated beyond repair, they would be replaced to exactly match the old. b) All character-defining features are retained. c) Physical treatments to historic material would use the gentlest means possible and would not damage material. d) Reconstruction would be clearly identified as a contemporary re-creation. e) Interpretative signage would clearly provide information regarding the history of the buildings and their reconstruction. Artifacts, features, and other materials recovered through this process shall be described, illustrated, and analyzed fully in a technical report of findings; the analysis shall include comparative research with other sites of similar age. In addition to the technical The historic architect shall submit a report documenting conformance with the Secretary of the Interior’s Standards to the City for review and approval prior to issuance of any building permits for the Project. Artifacts, features, and other materials recovered through this process shall be described, illustrated, and analyzed fully in a technical report of findings; the analysis shall include comparative research with other sites of similar age. In addition to the technical report, the findings from this research shall be submitted to an appropriate scientific journal. The Applicant shall fund all technical reporting and subsequent publication. The historic architect shall notify the Applicant if any unforeseen circumstance arises during construction that could potentially result in nonconformance with the Secretary of the Interior’s Standards. The City shall ensure the report is reviewed and approved prior to issuance of grading permits for Phase 3. The historic architect shall participate in a pre-construction meeting with the general contractor and subcontractors and periodically monitor construction to completion of construction. This measure would also apply to Alternative 1. 02191
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-43 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 report, the findings from this research shall be published in an appropriate scientific journal. The Applicant shall fund all technical reporting and subsequent publication. MM CR-10. Historic American Building Survey Level II Documentation Requirements. The Applicant shall retain a qualified professional photographer to prepare Historic American Building Survey (HABS) Level II documentation and investigate additional applicable surveys (e.g. oral histories, LIDAR, and/or photogrammetry). This documentation shall record the existing appearance of all seven contributing buildings in large and medium format HABS photographs. HABS Level II documentation shall pertain to the entire Froom Ranch Dairy complex so that functional relationships between the buildings can be documented. All documentation components shall be completed in accordance with the Guidelines for Architectural and Engineering Documentation (HABS standards). The photographs shall consist primarily of large format, 4-inch by 5-inch, black and white negatives (one set), contact prints (one set) and 8-inch by 10-inch prints (two sets), archivally processed and printed on fiber-based paper. The set of original negatives shall be made at the time the photographs are taken. The original, archivally-sound negatives and prints shall be and distributed as follows: (1) the Library of Congress in Washington, DC through the National Park Service (one set of negatives and contact prints). The draft documentation shall be assembled and submitted to the qualified professional historic architect and the City for review and approval prior to submittal to the repository. The HABS documentation shall be completed prior to the issuance of grading permits for Phase 1. A digital copy of the HABS documentation shall be reviewed by the City and approved prior to the issuance of grading permits. This measure would also apply to Alternative 1. MM CR-11. Interpretive Project for the Historic, Cultural, and Architectural Heritage of the Froom Ranch Dairy. The Applicant shall work with the City to develop an interpretive project that documents the potential historic district and its cultural and architectural heritage by means of a pamphlet and additional means (e.g., signage, interpretive plan, mobile-friendly content), if deemed mandatory by the City. This interpretive project will highlight the former Froom Ranch Dairy, both primary and secondary contributors, in a social (Froom family) and industrial (dairy industry) context, with an emphasis on how these buildings were used on the dairy farm, and how this property relates to the larger dairy farm context in San Luis Obispo, the Central Coast, and California. Five hundred copies of the pamphlet shall be published. These professionally researched, written and printed materials shall be offered at no cost through the local museums and The Applicant shall prepare and submit draft documentation to the City and Cultural Heritage Committee (CHC) for review and approval prior to the issuance of grading permits for Phase 3. The pamphlet and interpretive signage shall be reviewed by the CHC and approved by the Community Development Director. The Parks and Recreation Commission shall review any interpretive signage proposed to be located within the park. The City Community Development Department shall ensure park designs incorporate interpretive signage consistent with approved documentation. This measure would also apply to Alternative 1. 02192
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-44 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 heritage organizations, and at the trailhead park. After the initial distribution of printed brochures, digital copies shall be available. Throughout the park, interpretive signs that provide information on building history and function (extant and demolished) shall also be incorporated. MM CR-12. Salvage and Reuse of Historic Materials. The Applicant shall reuse original material to the greatest extent feasible in the proposed work on the contributing structures to be relocated and/or reconstructed within the proposed public park (main residence, dairy barn, creamery/house, and granary). The Applicant and historic architect shall work with the City to prepare a marketing plan to offer to the public any salvaged historic materials not used during rehabilitation and reconstruction of the primary contributors, and demolition of the secondary contributors. As appropriate, unused or unretained historic materials will be offered to local historical societies and museums, then offered to architectural recycling before being disposed. The Applicant shall prepare and submit draft documentation to the City for review and approval by the Community Development Director prior to the issuance of grading permits for Phase 3. The marketing plan shall be reviewed and approved by the Community Development Director. This measure would also apply to Alternative 1. MM CR-13. Protection of the Historic Integrity. The Applicant and historic architect shall prepare design guidelines and a review process for new construction proximate to the main residence. New construction shall be undertaken in such a manner that the essential form and integrity of the main residence and its setting would be unimpaired. The design guidelines and review by City Community Development Director shall ensure new construction is compatible with main residence in material, features, size, scale and proportion, and massing. The Applicant shall prepare and submit draft design guidelines to the City and CHC for review and approval prior to approval of entitlements and the issuance of grading permits for Phase 1. The design guidelines shall be reviewed by the CHC and approved by the Community Development Director. This measure would also apply to Alternative 1. MM CR-14. Preparation of a Historic Structure Preservation Plan. Prior to commencement of Phase 1 construction, a City-approved qualified structural engineer and historical architect shall survey the existing foundations and other structural aspects of the main residence, creamery, dairy barn, and granary, and develop a preservation plan to protect the historic buildings from potential damage during construction activities. The qualified structural engineer shall identify any necessary temporary structural bracing for the historic structures to avoid damage to these resources during the duration of construction. The qualified structural engineer shall prepare a temporary historic structure stabilization plan identifying these techniques as necessary. The Applicant shall submit the preservation plan and temporary historic structure stabilization plan to the City for review and approval prior to recordation of the final map and issuance of grading and building permits for Phase 1 of construction. Prior to the issuance of Phase 4 building and grading permits, the Applicant shall submit the final Historic Structures Plan and temporary historic structure stabilization The City engineer shall review and approve the preservation plan prior to recordation of the final map and issuance of grading permits for Phase 1. The City-approved structural engineer shall periodically monitor vibration during vibration-causing construction activities to ensure excessive vibration does not occur and that temporary historic structure stabilization plan strategies are effective at avoiding This measure would also apply to Alternative 1. 02193
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-45 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 plan, with incorporation of any additional recommendations for repair, to the City for review and approval. vibration damage. The structural engineer shall halt construction activity if he/she deems construction activity may harm historical resources and shall modify or augment the temporary historic structure stabilization plan strategies accordingly. Geological Resources MM GEO-1. Construction Worker Paleontological Resource Education Program. Prior to construction of each phase, workers shall receive education regarding the recognition of possible paleontological resources, during grading and excavation. Such training shall provide construction personnel with direction regarding the procedures to be followed in the unlikely event that previously unidentified paleontological materials are discovered during construction. Training shall also inform construction personnel that unauthorized collection or disturbance of paleontological resources is not allowed. The training shall be prepared by a City-approved paleontologist and shall provide a description of paleontological resources that may be encountered in the Project site, outline steps to follow in the event that a discovery is made, and provide contact information for the Project paleontologist and appropriate City personnel. The training shall be conducted concurrent with other environmental or safety awareness and education programs for the Project, provided that the program elements pertaining to paleontological resources is provided by a qualified instructor meeting applicable professional qualifications standards. In order to prevent inadvertent potential significant impacts to paleontological resources that may be encountered during ground disturbance or construction activities, in the event of any inadvertent discovery of paleontological resources during construction, all work within the vicinity of the resource established by the City-approved paleontologist shall temporarily cease. If a paleontological resource is discovered, the City-approved paleontologist shall be notified to assess the significance of the find and provide recommendations as necessary for its proper disposition. Prior to ground disturbance for each phase, construction workers shall participate in an educational program that will enable them to recognize and report possible paleontological resources. The conditions for treatment of discoveries shall be printed on all grading plans. The City shall be notified immediately after the unanticipated discovery of a paleontological resource. Paleontological reports shall be reviewed and approved prior to issuance of occupancy. In the event that any potentially significant paleontological resources are uncovered during ground disturbance or construction activities: a. Temporarily cease grading in the vicinity of the resource established by the City-approved paleontologist and redirect activity elsewhere to ensure the preservation of the resource in which the discovery was made; b. Immediately notify the City of San Luis Obispo Community Paleontological reports prepared for the Project site in response to an unanticipated discovery shall be maintained by the City of San Luis Obispo Community Development Department. This measure would also apply to Alternative 1. 02194
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-46 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Development Department regarding the resource and redirected grading activity; c. Obtain the services of a City-approved professional paleontologist who shall assess the significance of the find and provide recommendations as necessary for its proper disposition for review and approval by City of San Luis Obispo Community Development Department. d. Complete all significance assessment and mitigation of impacts to the paleontological resource and verification reviewed and approved by City of San Luis Obispo Community Development Department prior to resuming grading in the area of the find. Hazards and Hazardous Materials MM HAZ-1. Preparation of a Construction Impact Management Plan. The Applicant shall prepare and submit a Construction Impact Management Plan to the City of San Luis Obispo Fire Department (SLOFD) prior to the issuance of grading permits. The Plan shall list measures taken during construction to reduce the potential for brush or grass fires from use of heavy equipment, welding, vehicles with catalytic converters, and other potential activities. The Plan shall include SLOFD recommended measures including, but not limited to the following: All equipment with the potential to work off-road shall be equipped with appropriate mufflers and have extinguishers mounted on each vehicle; In coordination with SLOFD, personnel shall be briefed on the dangers of wildfire and be able to respond accordingly should the need arise; The Applicant shall prepare a Construction Impact Management Plan in coordination with SLOFD, the San Luis Obispo County Fire Department, and the City, and submit the Plan to the SLOFD for approval prior to the issuance of grading permits. Provisions for fire protection shall be restated on all grading and building plans. Fire protection measures shall be implemented throughout construction and draw upon the CALFIRE and San Luis Obispo County Fire Department Strategic Fire Plan. The name and telephone The SLOFD shall review the Construction Impact Management Plan and provide recommended measures as necessary. The City permit processing planner shall ensure measures are integrated into the final grading and building plans prior to permit approval. City monitoring staff shall spot check for compliance during construction for each phase of development. This measure would also apply to Alternative 1. 02195
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-47 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Onsite supervisor(s) shall have a cell phone or other means of initiating a 911 response time in a timely manner in the event of a medical emergency and/or fire; All dead and decadent vegetation immediately surrounding the development area shall be removed to a minimum perimeter of 30 feet; Smoking shall only occur in a designated area; A water tender will be available on each construction site during the entire phase of construction; and A water tender operator shall be available onsite during all construction and remain onsite a minimum of 30 minutes after all construction has finished for the day. number of an onsite supervisor shall be provided to SLOFD prior to commencement of construction or grading activities. MM HAZ-2. Preparation of a Community Fire Protection Plan. In accordance with PRC Section 4291, the Applicant shall hire a City-qualified team that consists of appropriate specialists (i.e., fire management professionals, biologists) to prepare a Community Fire Protection Plan to design the creation and maintenance of required fire buffers and fuel management zones around developable areas and detail methods for achieving fire safety around new buildings while preserving the integrity and function of affected native plant communities to the maximum extent feasible, and that ensures that consistent fire fuel management practices are applied throughout the City. The Plan shall incorporate management strategies in coordination with adjacent property owners, including Mountainbrook Church and the Irish Hills Natural Reserve. The Plan shall outline the removal and control of invasive, non-native vegetation, and conservation of sensitive habitats and rare species, while developing fire fuel management practices that will discourage or prevent non-native grasses and other non-native invasive species from dominating surrounding areas. Landscaping shall be maintained by the Applicant and periodically inspected by the SLOFD during fire inspections in each of the fuel management zones to avoid the buildup of deadwood and leaf litter, which, if left to accumulate, would reduce the mitigating effect of the Plan. Specifically, the Plan shall include, but not be limited to, the following elements: Vegetation coverage and type; Prior to approval of the final development plan, the Community Fire Protection Plan shall be prepared and submitted to the City Natural Resources Manager and SLOFD for review and approval, with coordination from the San Luis Obispo County Fire Department. The Plan shall be implemented consistent with the approved maintenance schedule. The City-qualified biologist shall submit a monitoring report to the City Natural Resources Manager and SLOFD at the end of the first year following Project occupancy documenting the fuel management activities that took place. Conformance with the Community Fire Protection Plan shall be demonstrated through the submittal of annual photo documentation by the Applicant or site visits as necessary at the discretion of the Compliance monitoring staff. This measure would also apply to Alternative 1. 02196
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-48 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Setbacks between structures, sensitive wildlife species, and access routes; Development plan landscaping and planting standards within the setback areas; Native trees and shrubs, such as coast live oak, coastal scrub, and grassland shall be thinned and limbed up but left in place; All allowable weed abatement techniques, qualifications, and requirements for weed abatement contractors, as well as measures and techniques that ensure the required fuel management and vegetation clearance, shall be designed and implemented to provide adequate structure protection and avoid degradation of sensitive biological habitat; and Invasive species shall be removed and controlled. MM HAZ-3. Prohibition of Smoking and Designation of Smoking Areas. The FRSP shall designate smoking areas, located away from onsite fire hazards areas and within acceptable locations consistent with Chapter 8.16, Smoking Prohibition and Secondhand Smoke Control, of the City Municipal Code. Otherwise, smoking shall be prohibited onsite. The Applicant shall amend the FRSP to include policies to requiring the allowed use of fire resistant landscaping and hardscaping in areas to reduce mulch/gorilla hair, which is the receptive embers, if determined appropriate by SLOFD. Prior to adoption of the Final FRSP, the Applicant shall amend the Final FRSP to include these policies. The Applicant shall coordinate with SLOFD to identify appropriate locations for designated smoking areas and appropriate fire resistant landscaping and hardscaping features within the Project site. The Final FRSP shall be reviewed by the SLOFD and City for inclusion of the above measure. This measure would also apply to Alternative 1. MM HAZ-4. Preparation of a Site Evacuation Plan. The Applicant shall prepare and implement an Evacuation Plan, which shall address both Villaggio and Madonna Froom Ranch areas. The Evacuation Plan shall be subject to review by the City and SLOFD, and shall include, but not be limited to: Accommodation for assisted living and special care individuals; Shelter-in-place accommodations; Specified quantity and capacity of vehicles required to accommodate residents and employees of Villaggio, and maintenance of those vehicles; Signage that clearly indicates evacuation routes and meeting areas; Specified egress points for transportation vehicles; A relocation plan from the Project site to a secondary facility, with associated transportation; The above Evacuation Plan shall be prepared in coordination with the SLOFD and the San Luis Obispo County Fire Department and submitted for approval to the City and SLOFD prior to adoption of the Final VTM. The Applicant shall resubmit the Plan to the City and SLOFD prior to the construction of each phase of development. Prior to occupancy of the first residential unit, the Applicant shall implement measures within the Evacuation Plan. The City and SLOFD shall review the Evacuation Plan and ensure all recommendations are incorporated. The City Fire Marshall shall inspect the Project site for compliance prior to the occupancy of the first residential unit for each phase. This measure would also apply to Alternative 1. 02197
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-49 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Contingency plans for changes to the construction schedule or phasing plan that would affect the primary evacuation plan and routes; Periodic updates that would consider potential redevelopment activities or other roadway alterations; and Regular practice drills (e.g., one per year) for implementation of the Evacuation Plan. MM HAZ-5. Irish Hills Natural Reserve Fire Access. The FRSP shall designate fire access routes in at least two locations from the Project site to the Irish Hills Natural Reserve on at least 12-foot wide paths, one extending from Villaggio and one from Madonna Froom Ranch. Fire access routes shall be designed to allow emergency response to wildland area in the Irish Hills to support direct access for firefighting personnel and equipment. Prior to adoption of the Final FRSP, the Applicant shall amend the Final FRSP to include the required accessway, in coordination with SLOFD to identify appropriate locations within the Project site. The Final FRSP shall be reviewed by the SLOFD and City for inclusion of the above measure. This measure would also apply to Alternative 1. Hydrology and Water Quality MM HYD-1. Submittal of a Notice of Intent. Prior to the issuance of any construction/grading permit and/or the commencement of any clearing, grading, or excavation, the Applicant shall submit a Notice of Intent (NOI) for discharge from the Project site to the California SWRCB Storm Water Permit Unit. The NOI shall be submitted for review and approval to the SWRCB. The City will verify that a Waste Discharge Identification (WDID) number is assigned by the Board prior to the issuance of grading permits for construction activities. The NOI shall address discharge during all phases of development of the site until all disturbed areas are permanently stabilized. The City will confirm WDID number assignment prior to approval of the grading permit(s). City monitoring staff will periodically inspect the site during construction to ensure compliance. This measure would also apply to Alternative 1. MM HYD-2. Preparation of a Storm Water Pollution Prevention Plan. For each phase of construction, the Applicant shall require the building contractor to prepare and submit a Storm Water Pollution Prevention Plan (SWPPP) to the City 45 days prior to the start of work for approval. The contractor is responsible for understanding the State General Permit and instituting the SWPPP during construction. A SWPPP for site construction shall be developed prior to the initiation of grading and implemented for all construction activity on the Project site in excess of 1 acre, or where the area of disturbance is less than 1 acre but is part of the Project’s plan of development that in total disturbs 1 or more acres. The The Applicant shall prepare a SWPPP that includes the above and any additional required BMPs addressing each phase of construction and timing. The SWPPP and notices shall be submitted to the SWRCB under their Stormwater Multi-Application, Reporting, and Tracking System (SMARTS). The SWPPP shall be designed to City monitoring staff shall periodically inspect the site for compliance with the SWPPP during grading to monitor runoff and after conclusion of grading activities. A Qualified SWPPP Practitioner (QSP) will be retained by the developer for overall management and reporting responsibility regarding the SWPPP and documentation This measure would also apply to Alternative 1. 02198
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-50 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 SWPPP shall identify potential pollutant sources that may affect the quality of discharges to stormwater and shall include specific BMPs to control the discharge of material from the site, including, but not limited to: Temporary detention basins, straw bales, sand bagging, mulching, erosion control blankets, silt fencing, and soil stabilizers shall be used. Sufficient physical protection and pollution prevention measures to prevent sedimentation, siltation, and/or debris from entering the Calle Joaquin wetlands. Soil stockpiles and graded slopes shall be covered after 14 days of inactivity and 24 hours prior to and during inclement weather conditions. Fiber rolls shall be placed along the top of exposed slopes and at the toes of graded areas to reduce surface soil movement, as necessary. A routine monitoring plan shall be implemented to ensure success of all onsite erosion and sedimentation control measures. Dust control measures shall be implemented to ensure success of all onsite activities to control fugitive dust. Streets surrounding the Project site shall be cleaned daily or as necessary. BMPs shall be strictly followed to prevent spills and discharges of pollutants onsite (material and container storage, proper trash disposal, construction entrances, etc.). Sandbags, or other equivalent techniques, shall be utilized along graded areas to prevent siltation transport to the surrounding areas. Additional BMPs shall be implemented for any fuel storage or fuel handling that could occur onsite during construction. The SWPPP must be prepared in accordance with the guidelines adopted by the SWRCB. The SWPPP shall be submitted to the City along with grading/development plans for review and approval. The Applicant shall file a Notice of Completion for construction of the development, identifying that pollution sources were controlled during the construction of the Project and implementing a closure SWPPP for the site. address erosion and sediment control during all phases of development of the site until all disturbed areas are permanently stabilized. The development plans submitted to the City shall include and reflect the erosion control plan and BMPs submitted to the State. under SMARTS in accordance with their permitting requirement. The Applicant will keep a copy of the SWPPP on the Project site during grading and construction activities. 02199
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-51 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 MM HYD-3. Timing of Installation of Stormwater Management Systems. Installation of the stormwater management system shall occur during the dry season (May through October), including realignment and restoration of Froom Creek, installation of hydrological connections for the stormwater detention basin, construction of onsite retention basins, and the installation of the Home Depot and LOVR ditches. Stormwater management system features shall be fully installed and restored to ensure soil stabilization and adequate stormwater conveyance capacity prior to the storm season (October through April). The Applicant shall demonstrate compliance within grading and construction phasing plans subject to City review and approval prior to issuance of grading permits for each Project phase. The City shall review grading and construction plans for all phases to ensure compliance. City grading monitors shall spot check for compliance. This measure would also apply to Alternative 1. MM HYD-4. Preparation of Refined Plans for Bio-Engineering of Froom Creek. The Applicant shall submit final Froom Creek Realignment plans and supporting technical studies that provide a refined bio-engineering approach to ensure creek bank and channel bottom stability and avoidance or reduction of further erosion. Final creek design plans and a supporting engineering study shall address appropriate boulder sizes and bank protection measures necessary to prevent dislodgement or remobilization of in-channel or toe-slope protection rock. Natural methods (e.g., additional rock) shall be employed as needed to maintain the proposed creek alignment and downslope bank location between the channel and LOVR and the Calle Joaquin wetlands, and to protect mid- to upper-bank areas and top-of-bank from erosion from flood flows and aid in maintenance of riparian vegetation. The Applicant shall submit revised plans and additional supporting technical studies to the City for review and approval prior to recordation of the final VTM. The final VTM shall depict all necessary revisions or improvements identified in the revised Froom Creek Realignment plans and supporting studies. City staff shall inspect Froom Creek realignment improvements and ensure compliance throughout all construction phases. Permit compliance monitoring staff shall perform periodic site inspections to verify compliance with planned improvements. This measure would also apply to Alternative 1. Noise MM NO-1. Limitation of Construction Work Hours. Except for emergency repair of public service utilities, or where an exception is issued by the Community Development Department, no operation of tools or equipment used in construction, drilling, repair, alteration, or demolition work shall occur between the hours of 7:00 PM and 7:00 AM, or any time on Sundays, holidays, or after sunset, such that the sound creates a noise disturbance that exceeds 75 dBA for single-family residential uses, 80 dBA for multi-family residential uses, and 85 dBA for mixed residential/commercial land uses, as shown in Table 3.10-9 and Table 3.10-10, across a residential or commercial property line. Plans submitted for grading and building permits shall clearly indicate construction hours and shall be submitted to the City for approval prior to grading and building permit issuance for each Project phase. To ensure response to and resolution of potential public noise nuisance complaints, plans submitted for grading and building permits shall clearly identify the Project’s construction manager (or similar) and 24-hour contact information. At the pre-The Applicant’s permit compliance monitoring staff shall perform periodic site inspections to verify compliance with activity schedules and respond to complaints. This measure would also apply to Alternative 1. 02200
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-52 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 construction meeting required for all phases of grading and development, all construction workers shall be briefed on restricted construction hour limitations. A workday schedule shall be adhered to for the duration of construction for all phases. MM NO-2. Implementation of Noise Attenuation Measures. For all construction activity at the Project site, noise attenuation techniques shall be employed to ensure that noise levels are maintained within levels allowed by the City of San Luis Obispo Municipal Code, Title 9, Chapter 9.12 (Noise Control). Such techniques shall include: Sound blankets on noise-generating equipment. Stationary construction equipment that generates noise levels above 65 dBA at the Project boundaries shall be shielded with a barrier that meets a sound transmission class (a rating of how well noise barriers attenuate sound) of 25. All diesel equipment shall be operated with closed engine doors and shall be equipped with factory-recommended mufflers. Temporary sound barriers shall be constructed between construction sites and affected uses. The Applicant shall designate the proposed area of operation of stationary construction equipment and depict acoustic shielding around these areas on building and grading plans. Equipment and shielding shall be installed prior to construction and remain in the designated location throughout construction activities. Construction plans shall identify Best Management Practices (BMPs) to be implemented during construction. All construction workers shall be briefed at a pre-construction meeting on how, why, and where BMP measures are to be implemented. BMPs shall be identified and described for submittal to the City for review and approval prior to building or grading permit issuance. BMPs shall be adhered to for the duration of the Project. Construction plans shall include truck routes and shall be submitted to the City prior to grading and building permit issuance for each Project phase. City staff shall ensure compliance throughout all construction phases. The Applicant’s permit compliance monitoring staff shall perform periodic site inspections to verify compliance with activity schedules. This measure would also apply to Alternative 1. MM NO-3. Notification of Adjacent Properties Prior to Construction Work. The Applicant shall inform landowners and business operators at properties within 300 feet of the Project site The Applicant shall provide and post signs stating these restrictions and the Project’s construction City staff shall ensure compliance throughout all construction phases. The Applicant’s permit This measure would also apply to Alternative 1. 02201
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-53 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 of proposed construction timelines and noise complaint procedures to minimize potential annoyance or nuisance complaints related to construction noise no less than 10 days prior to initiation of any grading and construction activity for any Phase. The notice shall include the name and contact information of the Project’s construction manager and contact information for the City’s Community Development Department. manager’s name and contact information at construction site entries. Signs shall be posted prior to commencement of construction and maintained throughout construction of any Phase. The construction schedule and mailing list shall be submitted to the City Community Development Department 10 days prior to initiation of any earth movement. compliance monitoring staff shall perform periodic site inspections to verify compliance with activity schedules and respond to complaints. MM NO-4. Preparation of Project-Specific Noise Study. Prior to approval of park and residential development within the Madonna Froom Ranch area of the Specific Plan, the Applicant shall submit a project-specific noise study that evaluates the potential for noise exposure from adjacent commercial uses and identifies project-specific design measures to attenuate exterior and interior noise consistent with the City’s Noise Element and Noise Ordinance. If necessary to reduce noise within acceptable levels, noise reduction measures may include a planted earthen berm, sound wall, or similar noise attenuating feature along the site boundary with Irish Hills Plaza, consistent with Policy 1.8.2 of the Noise Element. The Applicant shall incorporate the above mitigation within the final FRSP prior to adoption. City staff shall ensure compliance with required site design and noise reduction measures within the final FRSP prior to adoption and shall confirm any required noise attenuation measures are shown on construction plans prior to issuance of building permits. This measure would also apply to Alternative 1. Public Services MM PS-1. Public Parkland Requirements for Villaggio. Mitigation shall be calculated based on actual buildout populations within Madonna Froom Ranch. At the discretion of the Community Development Department and City of San Luis Obispo Parks and Recreation Department, and to ensure that parkland would satisfy the needs of the proposed population of Villaggio, the Applicant shall either: a. Identify, purchase, and develop up to 7.32 acres of parkland, including 2.79 acres of neighborhood park (in addition to the 2.9 acres of public parkland proposed by the Project), within the City’s Sphere of Influence, consistent with City General Plan PRE Policies 3.13.1, 3.15.1, 5.0.1, and 5.0.2. If feasible, land for development of neighborhood park space should be identified within interior areas of the City Sphere of Influence to maximize use and access; or The development of parkland and/or dedication of fees shall be completed by the Applicant prior to issuance of building permits. While coordinating with the City Parks and Recreation Department, the Applicant shall modify the FRSP to demonstrate the provision of recreational facilities to meet the demand of Villaggio residents if an onsite option is selected. The City shall ensure compliance with General Plan PRE Policies 3.13.1, 3.15.1, 5.0.1, and 5.0.2, and shall ensure the above measure is implemented prior issuance of building permits. This measure would also apply to Alternative 1. 02202
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-54 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 b. Provide a contribution of fees in-lieu of dedication of parkland, restricted solely for parkland acquisition and improvement. MM PS-2. Public Parkland Requirements for Madonna Froom Ranch. The Applicant shall identify, designate, dedicate, and/or develop up to 1.16 acres of public parkland into the Froom Ranch Specific Plan to be operational at the time of buildout of the Project, in addition to parkland provided under MM PS-1. Mitigation shall be calculated based on actual buildout populations within Madonna Froom Ranch and may be implemented using one of the following options, at the discretion of the Community Development Department and City Parks and Recreation Department: a. The Applicant shall designate an additional area of up to 1.16 acres of public facilities land use with the intention of providing parkland, within the Specific Plan area, consistent with City General Plan PRE Policies 3.13.1, 3.15.1, 5.0.1, and 5.0.2, or b. The Applicant shall identify and purchase or dedicate up to 1.16 acres of parkland within the City’s Sphere of Influence, or c. The Applicant shall provide a contribution of fees in-lieu of dedication of up to 1.16 acres of parkland, restricted solely for parkland acquisition and improvement. The development of parkland and/or dedication of fees shall be completed by the Applicant prior to issuance of building permits. While coordinating with the City Parks and Recreation Department, the Applicant shall modify the FRSP to demonstrate the provision of recreational facilities to meet the demand of Madonna Froom Ranch residents if an onsite option is selected. The City shall ensure compliance with General Plan PRE Policies 3.13.1, 3.13.1, 5.0.1, and 5.0.2, and shall ensure the above measure is implemented prior to issuance of building permits. This measure would also apply to Alternative 1. Transportation and Traffic MM TRANS-1. Construction Transportation Management Plan. The Applicant shall prepare a Construction Transportation Management Plan for all phases of the Project for review and approval by the City prior to issuance of grading or building permits to address and manage traffic during construction. The Applicant shall coordinate with SLO Regional Rideshare for the development of the Plan. The Plan shall be designed to: Prevent traffic impacts on the surrounding roadway network; Restrict construction staging to within the Project site; Minimize parking impacts both to public parking and access to private parking to the greatest extent practicable; Ensure safety for both those construction vehicles and works and the surrounding community; Prevent substantial truck traffic through residential neighborhoods; and Provide strategies to reduce single-occupancy vehicle trips made by resident and employees. The Applicant shall submit the Construction Transportation Management Plan to the City for review and approval prior to issuance of grading or building permits. The Construction Transportation Management Plan shall be updated as needed to reflect changing conditions over the Project’s five-year construction schedule. The Applicant shall conduct necessary construction employee training prior to the commencement of construction. The City Public Works Department, Community Development Department, Police Department, and Fire Department, The City shall ensure compliance with the Construction Transportation Management Plan with periodic inspections of the Project site during construction. Complaints related to construction traffic at the site shall be directed to the City Public Works Department. This measure would also apply to Alternative 1. 02203
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-55 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 The Construction Transportation Management Plan shall be subject to review and approval by the Public Works Director to ensure that the Plan has been designed in accordance with this mitigation measure. The Applicant shall identify a point of contact to coordinate Plan implementation. This review shall occur prior to issuance of grading or building permits. It shall, at a minimum, include the following: Ongoing Requirements throughout the Duration of Construction: A detailed Construction Transportation Management Plan for work zones shall be maintained. At a minimum, this shall include parking and travel lane configurations; warning, regulatory, guide, and directional signage; and area sidewalks, bicycle lanes, and parking lanes. The Plan shall include specific information regarding the Project’s construction activities that may disrupt normal pedestrian and traffic flow and the measures to address these disruptions. Such Plan shall be reviewed and approved by the Community Development Department and implemented in accordance with this approval. Heavy haul construction vehicles and cement trucks shall not pass through Villaggio’s Lower Area access roads once any of the Lower Area residences become occupied, and must utilize access from Calle Joaquin to access the Upper Terrace after that time. Work within the public right-of-way shall be reviewed and approved by the City on a case-by-case basis based on the magnitude and type of construction activity. Work shall generally be performed between 8:30 AM and 4:00 PM. This work includes dirt hauling and construction material delivery. Work within the public right-of-way outside of these hours shall only be allowed after the issuance of an after-hours construction permit administered by the Building and Safety Division. Additional restrictions may be put in place by Public Works Department depending on particular construction activities and conditions. Streets and equipment shall be cleaned in accordance with established Public Works requirements. and nearby residences and businesses shall be notified of the construction schedule prior to initiation of construction. The Applicant shall submit individual traffic control plans and part of encroachment permits for work within the public right-of-way. 02204
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-56 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Trucks shall only travel on a City-approved construction route. Limited queuing may occur on the construction site itself. Materials and equipment shall be minimally visible to the public; the preferred location for materials is to be onsite, with a minimum amount of materials within a work area in the public right-of-way, subject to a current Use of Public Property Permit. Provision of off-street parking for construction workers, which may include the use of a remote location with shuttle transport to the site, if determined necessary by the City. Where construction activities require closure of bike lanes or sidewalks along LOVR, temporary bicycle and pedestrian pathways shall be provided where feasible with physical separation provided between users and adjacent vehicle traffic consistent with Public Works requirements. Project Coordination Elements That Shall Be Implemented Prior to Commencement of Construction: The traveling public shall be advised of impending construction activities that may substantially affect key roadways or other facilities (e.g., information signs, portable message signs, media listing/notification, and implementation of an approved Construction Impact Mitigation Plan). A Use of Public Property Permit, Excavation Permit, Sewer Permit, or Oversize Load Permit, as well as any Caltrans permits required for any construction work requiring encroachment into public rights-of-way, detours, or any other work within the public right-of-way shall be obtained. Timely notification of construction schedules shall be provided to all affected agencies (e.g., Police Department, Fire Department, Public Works Department, and Community Development Department) and to all owners and residential and commercial tenants of property within a radius of 0.25 mile. Construction work shall be coordinated with affected agencies in advance of start of work. Approvals may take up to two weeks per each submittal. 02205
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-57 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Public Works Department approval of any haul routes for construction materials and equipment deliveries shall be obtained. Construction traffic plans, routes, and schedules shall be shared with the City Active Transportation Committee, County Public Works Department (for distribution to the County Bicycle Advisory Committee), the Los Verdes Park 1 and 2 Homeowners Associations, and local bicycle advocacy groups, such as Bike SLO County and the SLO Bicycle Club. MM TRANS-2. LOVR/U.S. 101 Ramp Improvements. The Project Applicant shall design and construct the extension of the southbound right-turn pocket at the LOVR/U.S. 101 southbound ramps intersection to provide a storage length of at least 150 feet. In coordination with the Applicant, the City and Caltrans shall also implement traffic signal coordination between the LOVR/Calle Joaquin intersection and adjacent U.S. 101 northbound and southbound ramps and optimize traffic signal timings at these three intersections. In addition, the Applicant shall also pay a fair share mitigation fee towards the improvements that are required to be constructed by the San Luis Ranch development at this intersection, which include extension of the southbound off-ramp through/left-turn pocket to provide a storage length of at least 320 feet. This mitigation measure requires Caltrans approval and coordination. Prior to recordation of the final VTM for subdivision of the Madonna Froom Ranch development phase, the Applicant shall submit a Public Street Improvement Plan for roadway improvements at the southbound right-turn pocket and a Traffic Engineering Study with signal timing recommendations for review and implementation by the City and Caltrans. Payment of fair share mitigation fees shall be provided prior to first building permit issuance for Madonna Froom Ranch development, while construction of applicable improvements shall be completed prior to the issuance of first certificate of occupancy for Madonna Froom Ranch development. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans or contributes an appropriate fair share as approved by the City. This measure would also apply to Alternative 1. MM TRANS-3. South Higuera Street/Vachell Lane Fair Share Mitigation Fees. The Project Applicant pay a fair share mitigation fee towards the improvements to be constructed by the Avila Ranch development project, which include the following: left turn at the South Higuera Street/Vachell Lane intersection, extension of Buckley Road from Vachell Lane to South Higuera Street, and installation of a traffic signal at Buckley Road/South Higuera Street intersection. Prior to issuance of building permits for each development phase, the Applicant shall provide a prorated fair share contribution towards the South Higuera/Vachell and Buckley Road improvements per the terms established in the Avila Ranch The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans or contributes an appropriate fair share as approved by the City. This measure would also apply to Alternative 1. 02206
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-58 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 If the Buckley Road Extension has not been completed prior to the Madonna Froom Ranch development phase, the Applicant shall be responsible for design and installation of alternate measures to mitigate the Project’s proportional share of intersection impacts to the satisfaction of the Public Works Director. Alternative measures may include installation of a center refuge on S. Higuera to allow two-stage left turns from Vachell, installation of left-turn restrictions at South Higuera/Vachell if the planned Earthwood Lane street connection between Vachell and Suburban has been completed, or signalization of the S. Higuera/Vachell intersection. Mitigation may require County coordination. If the Buckley Road Extension has not been completed prior to the Madonna Froom Ranch development phase, the Applicant shall be responsible for design and installation of alternate measures to mitigate the Project’s proportional share of intersection impacts to the satisfaction of the Public Works Director. Alternative measures may include installation of a center refuge on S. Higuera to allow two-stage left turns from Vachell, installation of left-turn restrictions at South Higuera/Vachell if the planned Earthwood Lane street connection between Vachell and Suburban has been completed, or signalization of the S. Higuera/Vachell intersection. Mitigation may require County coordination. Private Reimbursement Agreement. If the Buckley Road Extension has not been completed by others prior to issuance of first building permits for the Madonna Froom Ranch development phase, the Applicant shall design and construct alternate mitigation measures to the satisfaction of the Public Works Director prior to issuance of first certificate of occupancy for Madonna Froom Ranch. MM TRANS-4. South Higuera Street/Suburban Road Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee towards improvements to be constructed by the Avila Ranch development, which include restriping of the westbound approach of the South Higuera Street/Suburban Road intersection to extend the left- and right-turn pocket storage to 250 feet. If planned improvements have not yet been completed prior to issuance of building permits for the Madonna Froom Ranch development, the Applicant shall be responsible for installation of the striping improvements. Prior to the issuance of building permits for Madonna Froom Ranch development, the Applicant shall provide a fair share contribution towards the intersection striping improvements. If the planned improvements have not yet been completed by others prior to issuance of building permits for Madonna Froom Ranch development, the applicant shall be responsible for installation of the intersection striping improvements prior to issuance of first certificates of occupancy for The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans or contributes an appropriate fair share as approved by the City. This measure would also apply to Alternative 1. 02207
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-59 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 the Madonna Froom Ranch development. MM TRANS-5. South Higuera Street/Tank Farm Bike Lane Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee towards bicycle improvements at South Higuera/Tank Farm to be constructed by the Avila Ranch development, which include extending the westbound bike lane on Tank Farm Road to the South Higuera Street/Tank Farm Road intersection and installation of a bike box (with loop detection) to facilitate bicycle left-turn movements. Fair share contribution is satisfied through participation in the Citywide Transportation Impact Fee program. If the planned bicycle improvements have not yet been completed prior to development of the Villaggio Lower Area, the Applicant shall be responsible for design and installation of the bicycle improvements. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees. If the planned improvements have not yet been completed by others prior to issuance of first building permits for Villaggio’s Lower Area development, the Applicant shall be responsible for design and installation of the bicycle improvements prior to first occupancy permits for the Villaggio Lower Area development. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans or contributes an appropriate fair share as approved by the City. This measure would also apply to Alternative 1. MM TRANS-6a. South Higuera Street/Tank Farm Road Southbound Left-Turn Lane Fair Share Mitigation Fees. The Project Applicant shall pay fair share mitigation fees towards intersection improvements to be constructed by the Avila Ranch development, which include installation of a second southbound left-turn lane at the South Higuera Street/Tank Farm Road intersection. Fair share contributions are satisfied through participation in the Citywide Transportation Impact Fee program. If installation of dual southbound left-turn lanes has not been completed prior to Madonna Froom Ranch development phase, the Applicant shall coordinate with the City to retime the traffic signal at South Higuera/Tank Farm to mitigate the Project’s proportional contribution to queueing impacts. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees. If the planned South Higuera/Tank Farm intersection improvements have not yet been completed by others prior to issuance of first building permits for Madonna Froom Ranch development, the Applicant shall submit a Traffic Engineering Study with signal timing recommendations for review and implementation by the City prior to issuance of first certificates of The City shall verify that the Applicant pays fair share costs in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. 02208
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-60 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 occupancy for Madonna Froom Ranch development. MM TRANS-6b. Prado Road Overpass/Interchange Project Fair Share Mitigation Fees. The Project Applicant shall pay fair share costs for construction of the Prado Road Overpass/Interchange project. Fair share contributions are satisfied through participation in the Citywide Transportation Impact Fee program. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees The City shall verify that the Applicant pays fair share costs in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. MM TRANS-7. South Higuera Street/Prado Road Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee towards the intersection improvements to be constructed by the City at the South Higuera/Prado intersection, which includes installation of a second northbound left-turn lane, a second southbound left-turn lane, a second eastbound through lane, bicycle protected intersection features, traffic signal modifications, and widening of the adjacent Prado Road Creek Bridge west of South Higuera. Fair share contributions for both improvements are satisfied through participation in the Citywide Transportation Impact Fee program. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees. The City shall verify that the Applicant pays fair share costs in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. MM TRANS-8. LOVR Bike Lane Improvements. The Project Applicant shall design and install Class IV bikeways (protected bike lanes) along LOVR to provide a physical buffer between the sidewalk and vehicular traffic lanes. Improvement extents shall occur in the northbound direction between Laguna Lane and Diablo Drive, and in the southbound direction between Diablo Drive and Madonna Road. Some gaps in physical separation may remain due to right-of-way limitations or other design constraints. Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a Public Street Improvement Plan for review and approval by the City. Implementation shall be completed prior to the issuance of first certificates of occupancy for Villaggio’s Lower Area development. Improvement costs exceeding the Project’s proportional share may be eligible for private reimbursement. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. MM TRANS-9. LOVR Sidewalk Improvements. The Project Applicant shall design and install ADA-compliant curb, gutter and sidewalk along the west side of LOVR to complete the sidewalk connection between the Irish Hills Plaza and Calle Joaquin. The Project Applicant shall also design and install Class IV bikeways Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a Public Street Improvement Plan for The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plan. This measure would also apply to Alternative 1. 02209
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-61 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 (protected bike lanes) along LOVR to provide a physical buffer between the sidewalk and vehicular traffic lanes in the northbound and southbound directions between Madonna Road and South Higuera Street. This mitigation measure requires Caltrans approval and coordination for improvements near the LOVR/U.S. 101 interchange. If Class IV bikeways are not approved for segments within Caltrans right-of-way, or are deemed infeasible for short segments due to other geometric constraints, alternative treatments to improve pedestrian levels of service may be approved to the satisfaction of the Public Works Director. Potential alternative treatments include installation of striped bike lane buffers, street trees or other features that further buffer pedestrians from street traffic. review and approval by the City. Implementation shall be completed prior to the issuance of first certificates of occupancy for Villaggio’s Lower Area development. Applicable construction costs for improvements along LOVR between Calle Joaquin and Froom Ranch Way consistent with the planned Bob Jones Trail (Calle Joaquin to Oceanaire) Connection Project may be eligible for credits or reimbursement through the City’s Transportation Impact Fee program. Costs exceeding the Project’s proportional share for improvements along other segments may be eligible for private reimbursement only. MM TRANS-10. Madonna Road Multi-Use Path Fair Share Mitigation Fees. The Project Applicant shall pay fair share mitigation fees towards Madonna Road improvements to be constructed by the San Luis Ranch development, which include installation of a Class I Multi-Use Path parallel to Madonna Road between Oceanaire Drive and the U.S. 101 southbound ramps intersection. This project is in construction currently. Fair share contributions are satisfied through participation in the Citywide Transportation Impact Fee program. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees. The City shall verify that the Applicant pays fair share costs in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. MM TRANS-11. Internal Road Network Traffic Calming Measures. The Project is responsible for incorporating traffic calming measures (e.g., speed humps, bulb-outs, chicanes, etc.) into the design of Local Road “A” prior to development of Villaggio’s Lower Area. Traffic calming measures shall be designed to the satisfaction of the City Public Works and Fire Departments. Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a Public Street Improvement Plan for review and approval by the City. Implementation shall be completed prior to the issuance of first certificates of occupancy for The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. 02210
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-62 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 development of Villaggio’s Lower Area. MM TRANS-12. LOVR/Foothill Boulevard Fair Share Mitigation Fees. In coordination with the County, the Project Applicant shall pay a fair share mitigation fee for costs to construct the following future improvements at the LOVR/Foothill Boulevard intersection: widen northbound approach to provide one left-turn, two through, and one right-turn lane; widen westbound approach to provide one left-turn lane, one shared through/right-turn lane, and one right-turn lane. Additional improvements include roadway striping and traffic signal modifications needed to accommodate new lane configurations. This mitigation measure requires County approval and coordination. Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit preliminary intersection improvement plans for review and approval by the County, with plans developed to a level of detail sufficient to provide an engineer’s estimate of probable construction costs, including right-of-way acquisition (if needed). Fair share mitigation fees for these improvements shall be paid to the County prior to issuance of first certificates of occupancy development of Villaggio’s Lower Area. The City shall verify that the Applicant has provided applicable design plans and contributes an appropriate fair share mitigation fee to the satisfaction of the County. This measure would also apply to Alternative 1. MM TRANS-13. LOVR/Madonna Road Intersection Timing Improvements. In coordination with the Applicant, the City shall retime the traffic signal at LOVR/Madonna to implement Lead Pedestrian Intervals for each pedestrian crossing phase. Prior to the issuance of first building permits for the Villaggio Lower Area development phase, the City shall implement the signal timing modifications. The City shall verify that the signal timing modifications are implemented in accordance to the approved project phase. This measure would also apply to Alternative 1. MM TRANS-14. South Higuera Street/Tank Farm Road Lead Pedestrian Interval Improvements. In coordination with the City, the Project Applicant shall fund any costs required to implement Lead Pedestrian Intervals for each pedestrian crossing phase at the South Higuera Street/Tank Farm Road intersection. Prior to grading and recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a Traffic Engineering Study identifying recommended signal timing modifications for review and approval by the City. The proposed Lead Pedestrian Intervals shall be installed prior to the issuance of an occupancy or building permit for Villaggio’s Lower Area development. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans or contributes an appropriate fair share as approved by the City. This measure would also apply to Alternative 1. 02211
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-63 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 MM TRANS-15. South Higuera Street/Tank Farm Road Northbound Right-Turn Pocket Fair Share Mitigation Fees. The Project Applicant shall pay fair share mitigation fees towards extension of the northbound right-turn pocket storage at the South Higuera/Tank Farm Road intersection to 230 feet. Improvements are to be constructed by the San Luis Ranch Development or as a City-led capital improvement project. Fair share contributions are satisfied through participation in the Citywide Transportation Impact Fee program. Prior to the issuance of building permits for each development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements through payment of Citywide Transportation Impact Fees. The City shall verify that the Applicant pays its fair share fees. This measure would also apply to Alternative 1. MM TRANS-16. LOVR Corridor Intersection Timing Improvements. In coordination with the City and Caltrans, the Project Applicant shall fund costs required to optimize traffic signal timings along the LOVR corridor between Descanso Street and the South Higuera to improve traffic coordination and operations along this roadway segment. These intersections include LOVR/Descanso, LOVR/Royal, LOVR/Laguna, LOVR/Madonna, LOVR/Froom Ranch, LOVR/Auto Park, LOVR/Calle Joaquin, LOVR/U.S. 101 southbound ramps, LOVR/U.S. 101 northbound ramps and LOVR/S. Higuera. This requires coordination with Caltrans. Prior to issuance of first building permits for development of Villaggio Lower Area, the Applicant shall submit a Traffic Engineering Study identifying recommended signal timing modifications for review and approval by the City and Caltrans. Signal timing implementation shall be completed by the City and Caltrans. The City shall verify that the Applicant submits the required Traffic Engineering Study. This measure would also apply to Alternative 1. MM TRANS-17. LOVR/Madonna Road Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee to fund restriping modifications at the LOVR/Madonna Road intersection to increase southbound turn pocket storage to 365 feet. Prior to the issuance of first building permits for the Villaggio Lower Area development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements. Improvements to be installed by the City as part of regular signing and striping improvements. The City shall verify that the Applicant pays its fair share fees and that adequate funding is collected to implement these improvements. This measure would also apply to Alternative 1. MM TRANS-18. Madonna Road/Dalidio Drive Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee to fund modifications to the traffic signal at the Madonna Road/Dalidio Drive intersection to provide an eastbound right-turn overlap phase concurrent with the northbound left-turn phase. Prior to the issuance of first building permits for the Madonna Froom Ranch development phase, the Applicant shall provide a fair share contribution towards the mitigation improvements. Improvements to be implemented by the City as part of its ongoing traffic operations improvement program or installed in The City shall verify that the Applicant pays its fair share fees and that adequate funding is collected to implement these improvements. This measure would also apply to Alternative 1. 02212
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-64 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 conjunction with other intersection modifications to be constructed by the San Luis Ranch development project. MM TRANS-19. Installation of LOVR Landscaped Median. The Project shall design and install a landscaped median along LOVR from the terminus of the existing median at northern Project frontage to Calle Joaquin. The final FRSP shall be amended to incorporate the above median improvement prior to adoption and submitted to the City for review and approval. Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a public improvement plan for review and approval by the City. Implementation shall be completed prior to the issuance first certificates of occupancy for development of Villaggio’s Lower Area. The City shall ensure the above measure is incorporated into the final FRSP prior to Project approval. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. MM TRANS-20. Irish Hills Natural Reserve Emergency Access. The Project shall include an emergency access point from Villaggio’s Lower Area to the Irish Hills Natural Reserve to provide access to the existing dirt road network to fight fires in Irish Hills, specifically to Neil Havlik Way which connects to the four utility power line structures at the top of the ridgeline. This access point may be gated to ensure site security in consultation with SLOFD. The final FRSP shall be amended to incorporate the above emergency access connection prior to adoption and submitted to the City and SLOFD for review and approval. The above access road shall be integrated to the final VTM prior to approval of development plans. The City shall ensure the above measure is incorporated into the final FRSP prior to Project approval. This measure would also apply to Alternative 1. MM TRANS-21. Project Site Perimeter Emergency Access Points. The Project shall integrate access to the Project site perimeters for defending the Project site development. Specifically, these measures should address access to the wildland area immediately abutting the western boundary of Villaggio’s Lower Area. This measure shall include access from the proposed Local Road “C” to the Irish Hills, which may include use of space between proposed buildings for firefighting vehicle access, ramps up proposed retaining walls, and similar vehicle infrastructure to maintain access to the base of the Irish Hills. The final FRSP shall be amended to incorporate the above emergency access connection along the Irish Hills prior to adoption, and submitted to the City and SLOFD for review and approval. The above access road shall be integrated to the final VTM prior to approval of development plans. The City shall ensure the above measure is incorporated into the final FRSP prior to Project approval. This measure would also apply to Alternative 1. 02213
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-65 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 MM TRANS-22. Pedestrian and Bicycle Circulation Improvements. To address pedestrian and bicycle circulation safety issues, the Project Applicant shall incorporate the following elements into public improvements plans based on design guidance published by National Association of City Transportation Officials and the Federal Highway Administration: Install pedestrian refuges within center medians at north and south legs of the LOVR/Auto Park Way intersection; Install a single northbound left-turn lane at the LOVR/Auto Park Way intersection in lieu of dual left-turn lanes, as currently proposed, to shorten pedestrian crossing distance at the south leg of the intersection. Minimize the amount of roadway widening required along LOVR to the extent practicable by reducing turn pocket lengths at the LOVR/Auto Park intersection to the minimum extent required per applicable traffic engineering standards; Install a bulb-out at the southwest corner of the intersection to shorten pedestrian crossing distance at the south leg of the LOVR/Auto Park Way intersection; Install Lead Pedestrian Intervals at all pedestrian crossings at the LOVR/Auto Park Way intersection; Install protected bicycle intersection features as part of signalization and intersection improvements at the LOVR/Auto Park Way intersection, conceptually consistent with planned improvements at the nearby LOVR/Froom Ranch Way and Madonna Road/Dalidio Drive intersections, and as illustrated in the Bob Jones Trail (Calle Joaquin to Oceanaire) Project Study Report; Provide physically protected bicycle lanes (Class IV bikeway) along LOVR approaching/departing the Auto Park Way intersection and along Commercial Collector “A”. The Class IV bikeways shall be installed on-street with a physical barrier between cyclists and vehicular traffic or by constructing raised bicycle facilities at the sidewalk level adjacent to pedestrian sidewalks; The final FRSP shall be amended to incorporate the above improvements prior to adoption and submitted to the City and SLOFD for review and approval. Prior to recordation of the final VTM for development of Villaggio’s Lower Area, the Applicant shall submit a public improvement plan for review and approval by the City. Implementation shall be completed prior issuance of first certificates of occupancy for development of Villaggio’s Lower Area. The City shall ensure the above measure is incorporated into the final FRSP prior to Project approval. The City shall verify that the Applicant installs the improvements in accordance to the approved phase and design plans. This measure would also apply to Alternative 1. 02214
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) 9-66 Froom Ranch Specific Plan Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 Sidewalks shall be provided within the Madonna Froom Ranch development area of the Project site as per City standards; and Sidewalk design shall meet ADA requirements for a comfortable walking environment. MM TRANS-23. LOVR/Royal Way Fair Share Mitigation Fees. The Project Applicant shall pay a fair share mitigation fee to fund striping modifications to extend the northbound left-turn pocket at the LOVR/Royal Way intersection to 150 feet. This mitigation measure requires Caltrans approval and coordination. Prior to issuance of first building permits for Madonna Froom Ranch, the Applicant shall pay its fair share fees to the City. The City shall verify that the Applicant contributes an appropriate fair share as approved by the City and that adequate funding is collected to implement these improvements. This measure would also apply to Alternative 1. MM TRANS-24. LOVR/Calle Joaquin Lead Pedestrian Interval Improvements. In coordination with the Applicant, the City shall retime the traffic signal at LOVR/Calle Joaquin to implement Lead Pedestrian Intervals for each pedestrian crossing phase. Requires Caltrans coordination. Prior to the issuance of first building permits for the Villaggio Lower Area development phase, the City shall implement the signal timing modifications. The City shall verify that the signal timing modifications are implemented in accordance to the approved project phase. This measure would also apply to Alternative 1. MM TRANS-25. South Higuera Street/Tank Farm Road Southbound Left-Turn Pocket Fair Share Mitigation Fees. The Project Applicant shall pay its fair share mitigation fees to fund intersection striping improvements to extend the southbound left-turn pocket storage at the South Higuera Street/Tank Farm Road intersection to 300 feet. Prior to issuance of first building permits for Madonna Froom Ranch, the Applicant shall pay its fair share fees to the City. The City shall verify that the Applicant contributes an appropriate fair share as approved by the City and that adequate funding is collected to implement these improvements. This measure would also apply to Alternative 1. Utilities and Energy Conservation MM UT-1. On- and Offsite Infrastructure Improvement Review and Approval. The Applicant shall amend the FRSP to require that the size, location, and alignment of all on- and offsite water supply, recycled water, wastewater, and energy infrastructure shall be subject to review and approval by the City’s Public Works and Utilities Departments. The Applicant shall be responsible for constructing all required onsite and offsite utility improvements, as well as for repaving of damaged roadways. The Applicant is required to implement the above standard mitigation measures prior to approval of grading and the final VTM. City staff shall ensure the above measures are incorporated into the Final FRSP and building plans prior grading and recordation of the final VTM. City staff shall ensure measures are on all Project plans. City staff shall work with the Applicant to ensure that these requirements are implemented. This measure would also apply to Alternative 1. MM UT-2. Laguna Lift Station Replacement Fair Share Mitigation Fees. The Applicant shall pay fair share costs for replacement of the Laguna lift station or construction of capacity improvements through negotiation of a private reimbursement agreement with the City. Negotiation of a private reimbursement agreement with the City will fulfil the Project’s fair share financial obligation towards construction of necessary capacity improvements or replacement of The City shall approve the private reimbursement agreement and verify that the Applicant contributes appropriate fair share fees as approved by the City. This measure would also apply to Alternative 1. 02215
9.0 MITIGATION MONITORING AND REPORTING PROGRAM Table 9-1. Mitigation Monitoring and Reporting Program (Continued) Froom Ranch Specific Plan 9-67 Final EIR Mitigation Measure Plan Requirements & Timing Monitoring Applicability to Alternative 1 the Laguna lift station. Appropriate fees shall be negotiated with the City. Payment of fees shall be required prior to issuance of building permits for each development phase. 02216
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www.woodplc.com
Wood Environment &
Infrastructure Solutions, Inc.
104 West Anapamu Street, Suite 204A
San Luis Obispo, California 93101
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