HomeMy WebLinkAboutBates 14739-14788 Appendix B - Notice of Preparatiion APPENDIX B
Notice of Preparation and Comment Letters
Froom Ranch Specific Plan Project
Final EIR 14739
This Page Intentionally Left Blank.
14740
Notice of Preparation
To: EIR & Notice of Preparation Mailing List
SUBJECT: Notice of Preparation of a Draft Environmental Impact Report
Lead Agency: Consulting Firm: (if applicable)
Agency Name: City of San Luis Obispo EIR to be prepared by:
Department Name: Community Development Firm Name: To be determined
Street Address: 919 Palm Street Street Address:
City/State/Zip: San Luis Obispo, CA 93401 City/State/Zip:
Contact: Shawna Scott(781-7176; sscott(a�slocity.orq) Contact:
The Citv of San Luis Obispo will be the Lead Agency and will prepare an environmental impact report
(EIR) for the project identified below. We need to know the views of your agency as to the scope and
content of the environmental information, which is germane to your agency's statutory responsibilities
in connection with the proposed project. Your agency will need to use the EIR prepared by our agency
when considering your permit or other approval for this project. The project description, location, and
the potential environmental effects are summarized in the attached materials. A copy of the Initial
Study and additional background information is available here:
www.slocity.org/qovernment/department-directorv/community-development/documents-
online/environmental-review-documents/-folder-1911. Due to the time limits mandated by State law,
your response must be sent at the earliest possible date, but not later than 30 days after receipt of
this notice. Please send your response to the attention of Shawna Scott, Associate Planner for the
City of San Luis Obispo Community Development Department, at the address shown above. We will
need the name of a contact person in your agency.
Project Title: Froom Ranch Specific Plan Project
Project Location: The Froom Ranch Specific Plan Area consists of two parcels located at 12165 and
12393 Froom Ranch Way, totaling approximately 110 acres (ANP 067-241-030 and 067-241-031)
within unincorporated San Luis Obispo County, and adjacent to City of San Luis Obispo city limits. The
site is located immediately west of Los Osos Valley Road between U.S. 101 and the Irish Hills Plaza.
Project Description: The project includes a Specific Plan, General Plan Amendment, and related
actions that would allow for the development of the Froom Ranch Specific Plan Area, which is
identified as Specific Plan 3 (SP-3), Madonna on LOVR, in the City's General Plan. The Land Use
Element requires that a Specific Plan be adopted prior to annexation. The project will be primarily
residential with some commercial development in the northeast portion of the site closest to Los Osos
Valley Road and the adjacent Irish Hills Plaza. A major component of the planned residential uses is a
Life Plan Community (LPC) known as Villaggio. Villaggio would provide a variety of different unit types
for independent senior housing as well as access to higher levels of care such as Assisted Living,
Memory Care, and Skilled Nursing, when needed. Additional residential uses in the northern portion of
the site will be multiple-family. As required by the Land Use Element, a minimum of 50% of the project
site must be designated Open Space; the current Plan designates approximately 51% of the site as
Open Space. The Specific Plan also includes a Neighborhood Trailhead Park to connect to the Irish
Hills Natural Reserve, which may incorporate onsite historic structures. The treatment and potential
use of the historic structures is currently under evaluation by the applicant.
Date: Julv 10. 2017
Signature: �'`�"�~ ���
Title: Associate Planner, Citv of San Luis Obispo Communitv Development Deqartment
Reference:California Administrative Code,Title 14(CEQA Guidelines)Sections 15082(a), 15103, 15375(Revised October 1989)
14741
NOTICE OF PREPARATION ATTACHMENT
FROOM RANCH SPECIFIC PLAN PROJECT
The City of San Luis Obispo, as Lead Agency under the California Environmental Quality Act (CEQA),
is requesting comments on the scope and content of an environmental impact report (EIR) being
prepared for the Froom Ranch Specific Plan Project, as described in this Notice of Preparation.
Anticipated project entitlements are described below and issues anticipated being analyzed in the EIR
are listed below and described in the Initial Study. The Initial Study and additional background
information is available here: www.slocity.org/qovernment/department-directorv/communit rL-
development/documents-online/environmental-review-documents/-folder-1911. The City requests your
written comments on the NOP by August 14, 2017 and also invites you to attend a public scoping
meeting to be held on July 26, 2017, as detailed below. Please contact Shawna Scott, Associate
Planner at (805) 781-7176 or sscott .slocity.orq or Contract Planner and Project Manager Emily Creel
at (805) 543-7095 x6814 or ecreel _swca.com if you have any questions.
Proiect Location
���
The Froom Ranch Specific Plan Area consists of two �,c�'`�
parcels located at 12165 and 12393 Froom Ranch Way, ��
totaling approximately 110 acres (APN 067-241-030 and ..4
067-241-031) within unincorporated San Luis Obispo �'
County, and adjacent to City of San Luis Obispo city
limits. The site is located immediately west of Los Osos
Valley Road between U.S. 101 and the Irish Hills Plaza. so
Based on a preliminary review, the project site is not on sos
the list of hazardous materials sites compiled pursuant to kALLEY
Government Code Section 65962.5 and there are no
records of previous or existing sources of hazardous
materials onsite.
DiscretionarY Permits
In order to implement development on the site consistent with the proposed project, the following
entitlements will need to be processed:
1. General Plan Amendment/Pre-Zoning
2. Specific Plan
3. Development Plan/Tentative Tract Map(s)
4. Architectural Review
5. Annexation
1. General Plan Amendment and Pre-Zoning. The applicant envisions a Specific Plan that
differs somewhat from the performance standards identified in the Land Use Element;
therefore, the project would require a General Plan Amendment to accommodate some
aspects of future development under the Specific Plan. Because the site is currently
unincorporated, it will need to be pre-zoned before annexation to the City could be
approved.
2. Specific Plan. The City of San Luis Obispo Land Use and Circulation Elements (LUCE)
identifies Froom Ranch as a Specific Plan Area (SP-3, Madonna on LOVR) that requires
the adoption of a Specific Plan prior to any development. The applicant is preparing a
Specific Plan to accommodate the proposed development consistent with guidance for
development contained in Section 8.1.5 of the Land Use Element.
Page 2 14742
3. Development Plan/Tentative Tract Map(s). The applicant will submit tract maps to
implement the provisions of the Specific Plan. The Tract Map establishes the proposed
lot lines to allow individual ownership of properties and to layout the required
infrastructure and utilities.
4. Architectural Review — Ultimately final architectural review of housing, commercial
buildings, and some site facilities will be needed. The ARC will take an early look at design
guidance in the development plan and provide comments.
5. Annexation. If the project is approved, the City would initiate the annexation process with
the San Luis Obispo Local Agency Formation Commission (LAFCo). Annexation will
depend on the City's ability to address key issues to LAFCo, including the ability to provide
public services to the site (including water) and the nature of a tax-sharing arrangement
with San Luis Obispo County.
In addition, the project will need to be formally reviewed by the Airport Land Use Commission (ALUC)
for consistency with the Airport Land Use Plan. Other advisory bodies that will weigh in on aspects of
the project development include the Parks & Recreation Commission reviewing park proposals,
Cultural Heritage Committee regarding the proposed use/treatment of historic structures, and the
Bicycle Advisory Committee advising on the proposed bicycle trail network.
Probable Environmental Effects/Issues Scoped for EIR
The EIR will be a full-scope document, which covers all environmental issue areas as summarized in
the preliminary Initial Study and as required by State CEQA Guidelines Article 9, Contents of
Environmental Impact Reports. Issue areas identified in the Initial Study as requiring evaluation in the
EIR and that may be determined to be potentially significant include:
• Aesthetics
• Agricultural Resources
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use/Planning
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation and Traffic
• Tribal Cultural Resources
• Utilities and Service Systems
In addition, the following anticipated key issues are highlighted and summarized below.
Page 3 14743
Potential Impacts to Environmental Resources Due to Development Above the 150-foot Elevation
The applicant's request includes a General Plan Amendment to modify the current language
presented in City of San Luis Obispo Land Use Element (LUE) Policy 6.4.7.H to allow for hillside
development above the 150-foot elevation. The EIR will evaluate the potential impacts to visual,
biological, and hydrological resources, potential geologic and soils hazards, and consistency with
plans and policies specifically identified to protect these sensitive resources. Additional analysis
including photo simulations of the proposed development within the hillside context will be necessary
to determine if the project could be designed to protect hillside views, consistent with LUE hillside
development policies and LUE resource protection policies, Open Space Policies protecting scenic
vistas, and Circulation Element policies which call for the protection of views from roadways
designated as having scenic value.
Potential Impacts as a Result of Froom Creek Realiqnment
The proposed project includes the realignment and restoration of Froom Creek within the property
boundaries, and construction of pathways. City creeks and wetlands management objectives
applicable to Froom Creek include:
A. Maintaining and restoring natural conditions and fish and wildlife habitat;
B. Preventing loss of life and minimizing property damage from flooding;
C. Providing recreational opportunities which are compatible with fish and wildlife habitat, flood
protection, and use of adjacent private properties.
D. Recognizing and distinguishing between those sections of creeks and Laguna Lake which
are in urbanized areas, such as the Downtown core, and sections which are in largely
natural areas. Those sections already heavily impacted by urban development and activity
may be appropriate for multiple use whereas creeks and lakeshore in a more natural state
shall be managed for maximized ecological value (LUE Section 6.6.1 Creek and Wetlands
Management Objectives).
City staff and the applicant have met with resource agencies including the U.S. Army Corps of
Engineers, National Oceanic and Atmospheric Administration (NOAA) Fisheries, Regional Water
Quality Control Board, and California Department of Fish and Wildlife to review conceptual plans and
determine preliminary information that will be required for the agencies to formally respond to the
project. Key considerations include review of hydrological modeling to determine the gradient and
width necessary to provide suitable conditions for steelhead migration from the upper pools of Froom
Creek, through the project site, and connecting with San Luis Creek. Additional project details and
technical information will be provided by the applicant. Additional analysis will be required to ensure
consistency with regulations specific to floodway and floodplain management.
Potential Impacts to Historic Resources
The Froom Ranch Historic Complex is located within the project site, approximately at and below the
150-foot elevation line. This complex is not currently accessible to the public, and is generally blocked
from public view. The applicant submitted an evaluation of prehistoric and historic resources present
on the project site (First Carbon Solutions 2015), which determined that the Froom Ranch complex
(seven structures) is historically significant under National Register of Historic Places, California
Register of Historical Resources, and City of San Luis Obispo Historic Resources criteria. The LUE
states that the proposed project design should be sensitive to environmental constraints, including
historic structures, and adjust accordingly through design. The City Conservation and Open Space
Element (COSE) provides additional specific policy direction including the following:
Page 4 14744
• Significant historic and architectural resources should be identified, preserved, and
rehabilitated.
• Historically or architecturally significant buildings shall not be demolished or substantially
changed in outward appearance, unless doing so is necessary to remove a threat to health
and safety and other means to eliminate or reduce the threat to acceptable levels are
infeasible.
• Buildings and other cultural features that are not historically significant but which have
historical or architectural value should be preserved or relocated where feasible. Where
preservation or relocation is not feasible, the resource shall be documented and the
information retained in a secure but publicly accessible location. An acknowledgement of the
resource should be incorporated within the site through historic signage and the reuse or
display of historic materials and artifacts.
• Changes or additions to historically or architecturally significant buildings should be consistent
with the original structure and follow the Secretary of Interior's Standards for the Treatment of
Historic Buildings. New buildings in historical districts, or on historically significant sites, should
reflect the form, spacing and materials of nearby historic structures. The street appearance of
buildings which contribute to a neighborhood's architectural character should be maintained"
(COSE Section 3.2 and 3.3, Historical and Architectural Resources and Policies).
Full analysis of historic resources in the EIR will be necessary. The EIR will include an evaluation of
the proposed project, in addition to feasible alternatives to mitigate potential impacts to historic
resources. The EIR will also provide a preliminary assessment of the project's consistency with the
General Plan and Historic Preservation Ordinance and Guidelines.
Development of a Reasonable Ranqe of Alternatives
Factors that will influence the formulation of alternative project configurations include considerations
of project objectives, site suitability, economic viability, availability of infrastructure, General Plan
consistency, and the proponenYs control over alternative sites. The EIR will discuss the rationale for
selection of alternatives that are feasible and therefore, merit in-depth consideration, and which are
infeasible (e.g., failed to meet Project objectives or would not avoid significant environmental effects)
and therefore rejected. As directed by the City Council, the EIR will include a project alternative that
locates all development below the 150-foot elevation line. The City has requested this design
alternative from the applicant for incorporation and analysis in the EIR. The Alternatives Analysis will
also include an Alternative that retains and restores Froom Creek in its current location. In order to
present actionable alternatives in the EIR, the alternatives chapter will be comprehensive, provide
clear descriptions and graphics, and clearly identify potential impacts, associated levels of
significance, and identification of the mitigation measures that would be required to reduce potential
impacts. Additional alternatives are likely, but are not identified at this time.
Public Scopinq Meetinq
A public scoping meeting has been scheduled to allow for any interested persons to provide input on
issues to be discussed in the EIR:
Date and Time: July 26, 2017 at 6:00 p.m.
Place: 990 Palm Street (City Council Chamber upstairs)
The meeting is an opportunity for City staff to gather information from the public regarding the
potential environmental impacts of the project that need to be evaluated in the EIR. It is not intended
to be a hearing on the merits of the project. Therefore, members of the public should keep their
comments focused on potential significant changes to the environment that may occur as a direct
result of project development.
Page 5 14745
APPENDIX B—NOP COMMENTS AND RESPONSES
INDEX TO NOP COMMENTS
Appendix B includes a copy of the Notice of Preparation (NOP) for the proposed Project,
transcripts from the Public Scoping Hearings conducted on the NOP, copies of all comment letters
received on the NOP during the public comment period, and an indication(Section or Sub-Section)
where each individual comment is addressed in the Draft EIR. Table B-1 lists all comments and
shows the comment set identification number for each letter or commenter. Table B-2, identifies
the location where each individual comment is addressed in the Draft EIR. Comment letters are
present chronologically followed by the transcripts from the Public Hearing.
Table B-1. NOP Commenters and Comment Set Numbers
� � � � �
Interested Party Kathleen Choal 7/19/2017 1
Sierra Club Andrew Chrisrie 7/25/2017 2
Interested Party Mila Vujovich-La Barre 7/26/2017 3
Native American Heritage Commission Gayle Totton 7/27/2017 4 �
Salinan Tribe Patti Dutton 7/31/2017 5
Bicycle Advisory Committee Lea Brooks(1) 8/1/2017 6
San Luis Obispo Local Agency Formation Commission David Church 8/1/2017 7
CAL FIRE San Luis Obispo County Fire Department Travis Craig 8/2/2017 8
County of San Luis Obispo Department of Agriculture Lynda L.Auchinachie 8/4/2017 9
Interested Party Lea Brooks(2) 8/4/2017 10
California Department of Transportation—District 5 Melissa Streder 8/10/2017 11
California Native Plant Society Neil Havlik 8/ll/2017 12 �
San Luis Obispo Council of Governments Jeff Brubaker 8/14/2017 13
United States Fish and Wildlife Service Stephen P. Henry 8/14/2017 14
Table B-2. Response to NOP Commenters
�
Kathleen Choal
1-1 Thank you far your comments.Please refer to Section 3.13, Ti^ansportation and Tra�c for
impacts concerning traffic.With regard to what sidewalk improvements are proposed,please refer
to Section 2.0,Project Description.
1-2 Section 3.14, Utilities and Energy Conservation,provides discussion and analysis of impacts
associated with water use and water supply.
1-3 Please refer to Section 3.8,Hydrology and Water Quality,which provides the analysis of flood
potential upon Project implementarion.
Sierra Club—Andrew Christie
2-1 Thank you for your comments. Please refer to Section 5.0,Alternatives,for descriprions and
analysis of multiple Project alternatives,including consideration for an alternative with all
development below the 150-foot elevation line.
Froom Ranch Specific Plan Project B-1
Draft EIR 14746
APPENDIX B—NOP COMMENTS AND RESPONSES
2-2 Please refer to Section 2.0,Project Description, for the list of Project objectives, and to Section
5.0,Alternatives, for the assessment of alternatives against Project objectives.
2-3 Section 3.0.4, Cumulative Impact Analysis,describes the methodology and cumulative projects
list utilized for analysis within the EIR. Each resource section(Sections 3.1 through 3.15)also
contains cumulative analysis associated with each resource area.
Mila Vujovich-La Barre
3-1 Thank you for your comments.Please refer to Section 3.14, Utilities and Energy Conservation,
which provides discussion and analysis of impacts associated with water use and water supply.
3-2 Section 3.9,Land Use and Planning,provides consideration for design restrictions and site
constraints established by the LUCE, including the 150-foot height line,and Section 3.11,
Population and Housing,considers the proposed residential component associated effects.
3-3 Please refer to Secrion 3.13, Transportation and Traffic,for impacts concerning traffic,including
cumulative considerations.
3-4 Section 3.0.4, Cumulative Impact Analysis,describes the methodology and cumulative projects
list utilized for analysis within the EIR, including the Prado Road project.
3-5 Section 3.11,Population and Housing,considers the proposed residential component associated
effects,including the City's affordable housing requirement.
3-6 Please refer to Section 3.8,Noise,which provides analysis for potential noise from vehicular
traffic and potential mitigation.
3-7 Section 3.4,Biological Resources,discusses animal and vegetation protection within the site,and
Section 3.1,Aesthetics,addresses viewshed impacts in the vicinity.
3-8 Refer to Section 3.13, Transportation and Traffic for impacts concerning access, sidewalks,and
bike paths,and Section 3.12,Public Services and Recreation,for proximity and access to
recreational facilities and open spaces in the area.
3-9 With regard to the EIR process,please refer to Section 1.0,Introduction,for a summary of the
public outreach undertaken during EIR preparation.
3-10 Please refer to Section 32,Agricultural Resources,which addresses agricultural resources on-site
and potential impacts from the Project on agricultural activities.
Native American Heritage Commission—Gayle Totton
4-1 Thank you far your comments and guidance.Please refer to Section 1.0,Introduction,for a
summary of outreach undertaken during EIR preparation,and Secrion 3.5, Cultural and Tribal
Cultural Resources,for the implementation of CEQA updates associated with tribal cultural
resources,including adherence to AB 52, SB 18,and the NAHC's recommendations for
conducting cultural resources assessments.
Salinan Tribe—Patti Dutton
5-1 Thank you for your comment. '
Bicycle Advisory Committee—Lea Brooks(1)
6-1 Thank you for your comments. Regarding what street improvements are proposed,please refer to
Section 2.0,Project Description.Please refer to Section 3.13, Transportation and Traffic for
impacts concerning traffic,and potential mitigations that would affect proposed improvements
and existing connections.
6-2 Refer to Section 3.13, Transportation and Traffic for impacts concerning pedestrian and bicycle
access,and Section 3.12,Public Services and Recreation,for proximity and access to recreational
facilities and open spaces in the area, including the existing trail netwark.
San Luis Obispo Local Agency Formation Commission—David Church
7-1 Thank you for your comments.Please refer to Sections 3.12,Public Services and Recreation,and
3.14, Utilities and Energy Conservation,which address the majority of potential increases in
services that may be required to the Project site,though associated information is located
throughout the EIR.
7-2 Please refer to the prepared EIR,which contains all associated information,especially within
Sections 3.12,Public Services and Recreation,and 3.14, Utilities and Energy Conservation.
7-3 Section 2.0,Project Description,contains a list of required approvals,including annexation and
prezoning.
B-2 Froom Ranch Specific Plan P�je�
Dra�r�
APPENDIX B—NOP COMMENTS AND RESPONSES
7-4 Please refer to the regulatory setting descriptions within the EIR,which contain relevant LAFCo
policies for agricultural resources,public safety,water/wastewater, land use,and growth inducing
impacts.
7-5 Refer to Sections 3.2,Agricultural Resources, and 3.9,Land Use and Planning,for discussion of
agricultural conservation easement holdings and associated impacts of the Project,including
consideration for LAFCds Madonna-Gap annexation.
7-6 Please refer to the analysis within the EIR,which contain relevant LAFCo policies and mitigation
measures,notably within Sections 3.2,Agricultural Resources,33,Air Quality and Greenhouse
Gas Emissions,3.12,Public Services and Recreation,and 3.13, Transportation and Traffic.
7-7 Please refer to Secrion 5.0,Alternatives,for the descriprions and associated analyses for each
Project alternative.
CAL FIRE San Luis Obispo County Fire Department—Travis Craig
8-1 Thank you for your comments. With regard to discussion and impacts on emergency services and
CALFIRE/San Luis Obispo County Fire Department facilities pursuant to CEQA,please refer to
Section 3.12,Public Services and Recreation.
County of San Luis Obispo Department of Agriculture—Lynda L.Auchinachie
9-1 Thank you for your comments.Please refer to Section 3.2,Agricultural Resources,which
addresses agricultural resources on-site such as prime agricultural land,the agricultural easement,
and potential impacts from the Project on agricultural activities.
Lea Brooks(2)
10-1 Thank you for your comments.Please refer to Section 3.13, Transportation and Tra�c for
impacts concerning pedestrian and bicycle access and safety.
California Department of Transportation: District 5—Melissa Streder
ll-1 Thank you for your comments. Section 311,Population and Housing,provides discussion and
analysis of work force housing and consideration for the City's jobs-housing balance.Associated
Vehicle Miles Traveled and vehicle dependency is discussed within Section 3.13, Transportation
and Tra�c.
11-2 Section 3.13, Transportation and Ti^a�c,provides discussion and analysis of potential impacts of
the Project on surrounding roadways and intersections, in addition to consideration for cumulative
impacts.
11-3 Refer to Section 3.13, Transportation and Ti^affic,for discussion of multimodal transportarion
strategies alternate circularion patterns and connectiviry to the Project site.
11-4 Please refer to Secrion 3.8,Hydrology and Water Quality,which provides the analysis of flood
potential upon Project implementation,including modifications to creeks and culverts within the
Project site and vicinity,including culverts within Caltrans right-of-way near U.S.Highway 101.
California Native Plant Society—Neil Aavlik
12-1 Thank you for your comments. With regards to potential impacts above the 150-foot elevation
line associated with aesthetics,biological,hydrological, and noise,please refer to Sections 3.1,
Aesthetics,3.4,Biological Resources, 3.8,Hydrology and Water Quality,and 3.10,Noise.
I 12-2 Please refer to Section 3.1,Aesthetics,for aesthetics discussion and impacts associated with
implementation of the Project.
12-3 Please refer to Section 3.4,Biological Resources,for biological resource discussion and impacts
associated with implementation of the Project.
12-4 Please refer to Sections 3.4,Biological Resources,and 3.8,Hydrology and Water Quality,for
I discussion and impacts associated with implementation of the Project,including water flow and
biological resources.
12-5 Please refer to Section 3.4,Biological Resources,for discussion and impacts associated with
implementation of the Project,including protection of the federally-listed Chorro Creek bog
thistle.
12-6 Please refer to Secrions 3.8,Hydrology and Water Quality, and 3.4,Biological Resources,for
discussion and impacts associated with implementation of the Project,including realignment of
Froom Creek and the potential destruction of delineated wetland areas.
I 12-7 Section 3.8,Hydrology and Water Qualiry,addresses Froom Creek,subsurface flows,potential
effects of the creek's proposed realignment,and flooding.
Froom Ranch Specific Plan Project B-3
Draft EIR 14748
APPENDIX B—NOP COMMENTS AND RESPONSES
12-8 Refer to Section 3.5, Cultural and Ti-ibal Cultural Resources, for analysis of the Froom Ranch
historic buildings and measures to preserve their integrity.
12-9 Please refer to Sections 3.2,Agricultural Resources,and 3.9,Land Use and Planning,for
discussion of open space and agricultural conservation easement holdings, in addition to impacts
to these areas upon implementation of the Project.
12-10 Refer to Section 1.0,Introduction,which summarizes easements associated with the Project site
and that may be affected by the Project and/or alternatives,and Section 3.4,Biological Resources,
which discusses potential impacts to biological resources.
12-11 Please refer to Section 5.0,Alternatives,for the descriptions and associated analyses for each
Project alternative.
San Luis Obispo Council of Governments—Jeff Brubaker
13-1 Thank you for your comments. For discussion and consideration for SLOCOG's 2014 Regional
Transportation Plan and Sustainable Communiries Strategy,please refer to Section 3.9,Land Use
and Planning,and Section 3.13, Transportation and Traffic.
13-2 Please refer to Section 3.11,Population and Housing,which provides discussion and analysis of
affordable housing,including consideration for SLOCOG's 2050 Regional Growth Forecast,and
very low-, low-,and moderate-income households.Associated impacts to transportation and
traffic are addressed within Section 3.13, Transportation and Tra�c,and associated greenhouse
gas emissions addressed within Section 33,Air Quality and Greenhouse Gas Emissions.
13-3 Section 3.13, Transportation and Traffic,provides discussion and analysis of potential impacts of
the Project on surrounding roadways and intersections, in addition to consideration for cumulative
projects and transportation demand management.
13-4 Refer to Section 3.13, Transportation and Ti^affzc for impacts concerning pedestrian and bicycle
access,and Section 3.12,Public Services and Recreation,for proximiry and access to recreational
facilities and open spaces in the area,including the existing trail network.
United States Fish and Wildlife Service—Stephen P.Henry
14-1 Thank you for your comments.Please refer to Section 3.4,Biological Resources,which discusses
animal and vegetarion protection within the site,including consideration for federally-listed
threatened animal species,the Endangered Species Act,and associated mitigarions. Secrion 4.0,
Alternatives,provides descriptions and analysis of alternarives and their potenrial impacts to
biologicalresources.
B-4 Froom Ranch Specific Plan P�je�
Dra�r�
REC�IVE❑
CtTY�F SAi�L�!!5 OBI5P0
J�ly �g, �a�� JU� 2 5 2011
City of San L�is dbispa Go�n�nu�vi7��o�v��o�MEt�r
clo Commurtity Develapment
919 Palrri Stree#
San Luis Qbispo, CA 934��
Re: Froom Ranch Spe�ific Ptan PrQ��ct
Ta 1Nham I�May Can�ern:
I am writing regarding the EIR far the Froom Ran�h Specific Plan PrajeGt. As a busaz3ess
owner in the area, I ha�e 3 majar conce�-ns that I would like ta ha�e in�luded in the EIR;
• Ti-affic congestiorilRoadway Iinp�-o�ements
■ VVater Use
■ Floading
T�e traf�c on Las Osos Valley Raad has �-nwr� tre�nendously a�er tlie tast few years as
x�are retail has mo�ed �nto the area. T�e rr�adway impro�ements caanpleted Iast sumFner
�a�e helped l�ut traffi�still ba�ks up at the majnr intersectians and tl�e entran�es to retail
areas by Cnstca and Tar�et. I would liice tr� see what kind of impact this proje�t wvuld
ha�e an the traffic in the area and what kind af raadway i�npro�etnents would he r�ee�ed
to handle the increased congestion. �f note, would a sidewalk he in�iuded on thc
sauthsic�e of LDVR?
Althaugh we t�a�e left tt�e drought behind for��aw, I would like to knaw if water use will
�e an issue for this praje�t.
T�e in#ersection�f LDVR&Calic]oaquin �looded se�eral times during our rainy season.
SecEians af raadway alang L�VR were also reduced to �ne lane due to water o�erflow.
As part af the EIR, I would like ta see hc�w the potential for flooding alo�g the raadway
and any sidewatk would be addressed,
Thank you.
Sincerely,
Kathle�n Gl�aai
KSBY-TV, Presic�ent &General Ma�ager
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14751
Scott, Shawna
From: Santa Lucia Chapter of the Sierra Club <sierraclub8@gmail.com>
Sent: Tuesday, July 25, 2017 3:33 PM
To: Scott, Shawna
Subject: Comments on Froom Ranch NOP
� 1� � ��
I�� � � �� �
SA�IT� LUCI�
� C:[--iAPTEI�
July 25, 2017
Shawna Scott, Associate Planner
City of San Luis Obispo
Community Development
919 Palm St., San Luis Obispo CA 93401
Dear Ms. Scott,
We are in receipt of your July 10 letter requesting comment on the Notice of Preparation of an Environmental
Impact Report for the Froom Ranch Specific Plan Project.
The Sierra Club has three primary concerns with this project: Its proposed development beyond the Urban
Reserve Line, the definition of Project objectives, and the inclusion of a full analysis of the Project's potential
cumulative impacts in the EIR.
We appreciate that the City has shown awareness of the first concern in the NOP's discussion of the potential
impacts of the request by the applicant for a General Plan Amendment to allow for hillside development above
the 150-foot level, and the City's stated intent to include a project alternative that locates all development below
the 150-foot elevation line.
Second, as we pointed out in our comments on the San Luis Ranch Project, when a Specific Plan/General Plan
amendment is proposed, the Project objectives should be stated in terms of development options within the
range of intensity of the residential and commercial development called out in the Land Use Element, not just
the high end of that range. The California Environmental Quality Act does not require analysis of only the
project design that will assure the maximum level of residential and commercial development allowed in the
General Plan and dismissal of any alternative of reduced scale as infeasible solely because the scale is reduced.
We urge the City not to take the position that Project objectives serve as a bar to the analysis of scaled-back
alternatives, nor maintain that a Project alternative may not be considered unless it meets all of the Project
objectives.
Third,per CEQA Guidelines, the EIR must evaluate "past,present, and reasonably foreseeable future projects,"
which "when considered together, are considerable or which compound or increase other environmental
impacts."
1 14752
As of July 20, the City's website listed the following reasonably foreseeable future projects:
Projects Currently Posted on SLO City Web Site
Residential Sq. Feet of Open
Name Units Commercial/Office Hotel Space Other
San Luis Ranch 500 350,000 200 5.8
Avila Ranch 720 20,000
Froom Ranch 130 30,000 120 2.9 398 Senior Units
1101 Monterey 27,079
Marsh&Carmel 8 1,100
Madonna Plaza 56,257
San Luis Square 62 19,792 36
Monterey Place 29 12,255 3
Vesper Hotel at the Creamery 6,698 47
Twin Creeks 102 6,566
Broad St. Collection 10 6
1185 Monterey 13 2,464
Bridge Street 21,000
71 Palomar Av 33
Wes Creek Development 172
Ferrini Apartments 5
22 North Chorro 27 2,000
Imel Ranch Subdivision 18
Olive Mixed Use 17 3,500
Wingate Homes 142 5,000
Righetti Ranch Subdivision 304
Digital West 775,000
Towne Place Suites 114
French Hospital Expansion
Motel Inn 55 13 RV spaces and 10 Airstream spaces
The Junction 69 3,000
Long Bonetti Public Market 47,000
Jones Subdivision 65 15,000
Granada Hotel Expansion 22
Ellsworth Tract 35 Commercial Lots
Aerovista Place 37,000
South Town 18 18 70
Discovery SLO Bowling 245,000 Reusing existing space
McCarthy Steel 9,840
The Yard 43
Z 4753
Bishop Street Studios 34
Caudill Mixed Use 36 5,500
Perry Ford 7,895
Laurel Lane Mixed Use 18 2,500
Poly Performance 30,000
Tank Farm Commerce Park 29,000
Broad Street Mixed Use 11 3,000
Shell Station Development 10,000
Higuera Brew 15,500 Reusing existing space
Iron Works 46 4,400
Monterey Hotel 102
Homeless Service Center 20,000
Toscano Moresco 161
BMW Dealership 23,945
625 Toro 14
Serra Meadows 247
Aerovista Office 37,000
Hotel Serra 8 25,000 64
Brownstones 8
Chinatown Hotel 30 25,000 78
Direct Injectors 6,200
Airport Business Center 75,000
SLO Brew Production 31,290
Avinvo Townhomes 161
Pacific Courtyards 9 8,000
Fxlini Tract 13
Bridge Street 26
Boysen Apartments 6
Total 3315 2,054,851 847 8.7
Compiled by David Blakely
We urge the City to insure that in addition to analyzing and considering mitigations for potential impacts on traffic,
greenhouse gas emissions, air quality,biological resources, land use/planning and all other areas identified in the Initial
Study as requiring evaluation,the EIR fully analyzes and mitigates the cumulative impacts likely to arise in those
categories from all of the above projects and any others that are likely to be developed within the approximate timeframe
of the Froom Ranch Specific Plan.
Thank you for inviting us to comment,
��
3 14754
Andrew Christie, Director
Santa Lucia Chapter of the Sierra Club
P.O. Box 15755
San Luis Obispo, CA 93406
(805) 543-8717
4 14755
�rom: Miia Vujo�i�h-LaBarr�
5ent: Wedncsday,July 2Ci,2fl I 7 i 2:2fi PEV1
To: Ad�isot'y Bc�dics;E-mail Councit We�sitc; Lic�itig,Katie
Cc: Hartnan,Heidi; �ease,Andy;Gomea,Aaron; Ri�oire, Dar�;Christianso�i,�ar�yn
5uhjecE: Froom Ranch 5cnping Meeting Con�erns
f�ECEIVE�
To: P�anning Cvmmissivn - Cify of San Luis Qbispa CI7YflF 5AN LL115 p815PU
Cc: 5an Luis �bispo City Cauncil Memhers ��� � � ��1�
Katie �ichtig - City Manager
Re: Froom Ranch De►►elopment
F�om: AAila Vujor►ich-La Barre can�M���rv��vE�ap�n€�vr
E3ate: July 2G, 2U17
Dear Plar�ning Cammission Members -
T�ank yau for the opportunity ta voi�e apinEons abo�t the Frvvm Ranch ❑e�el+opment. Many v�my
concems were expressed auring the Land Use Circulation Element tLUCE} meetin�s a few years ag❑ a�d
at some recent meetings, d�e to the r�sh af de�elopm�n# in the sou�he�n part af our city.
1 wanted to express my cvncerr�s for y�ur consideration and the public recflrd.
��om the publicity, i# is my unders#ar�ding #hat "Johr� Madanna planS to trartsform ���-acres in Sat� Luis
Obispa into a $50� millivr� mixed-use project that cafiers to the ci#y's aging papufation. The pra�ased Froom
F2ar�c� proje�t in�Eudes a �antin�ing care retirement community �CCRC} that ofFers 350 res�e�er�tial units for
seniors, 15�,D00-35�,DOQ SC{Ual'� ��E� af COR1R]ECCtaI CB��II21'S ��� ft5 ��S1C�EC]�S, 2D4 a�artrnents and around
�0-��D sir�gle-famify detach�e� units."
This particufar de�e[vper�ras {ong and hanarab[e #ies tv atar communi�y. it is my hope that he wiI� reafisticalfy
ad�ust his de�efapment plans after this sca�ing meetir�g.
A deve�vpme�� of tk�is magnitude wilf drastical[y aEter the tra�#ic and the �isuaf aftracti�er�ess of t��s part af
town.
As you aif knaw, the La�d Llse Circula�io� Efemer�t �LUCE} was funded by a state grar�t that maximized
devefapment in San Luis a�ispa. It may have beer� gvvd Er� thevry far the ma�vrity of the LLI�E members
wh❑ had a backgra�nd or persona! financial interest in �evelopment. Howe�er, the LUCE dacument- which
i�as �ecame #he blueprint for future develapment - did not talce into cvr�sideratian many realities. The
minvrity report from the �UCE h�ghfights this and the fact that the LL�CE pro�ess d�d nv# pravide #or
subs#antial �ublic input_
My cancerns abot�t the Froom RancF� ❑evefapmenE are pr�marily the fv[lvwing:
9.V4fater.
Where is the water fvr this develvpment? City and County residen�s ha�e been asked #o conserve fvr
mo�ths and 1 dv nvt sae water le�els increasing at t�e sa�rces �f o�r water far a de�eiopment �f this
magnitu�e. ,1ohn Madanna has stated #F�at, "The praject woufd �ase some exis�ing wells on the prQperty and
draw fram tt�e ci#y's reser�oirs to satisfy i�s water neec�s."
2. Design
14756
:
The continuing care retirement community (CCRC) that offers 350 residential units for seniors, will be an
asset. However, the proposed 200 apartments and 60-100 single-family detached units and commercial
space are not necessary. By changing this configuration, and just building the CCRC there will be no
need to encroach over the 150 foot height line established in the LUCE document.
3. Traffic
This upcoming generation may focus on walking, biking and bus travel out of respect for climate change,
however most people will still utilize a car. People in the surrounding neighborhoods and businesses of
Laguna Lake deserve an authentic study of what traffic will look like with this proposed development,
including the cumulative impacts of the traffic from San Luis Ranch and the traffic from the Avila
Ranch development.
They also deserve an authentic appraisal of parking for the Froom Ranch development.
Traffic flow from the existing proposed business development should also be part of that same study. If
John Madonna wants to include commercial development in the Froom Ranch development, that increased
traffic also needs to be factored in.
4. Prado Road.
As I wrote previously, the proverbial "elephant in the room" is Prado Road. For years now, people have
been asking whether Prado Road is going to be an interchange or an overpass. They have been asking
whether or not it a four-lane truck highway as it appears on the adopted LUCE plan.
Prado Road was indeed part of the updated Land Use Circulation Element (LUCE) Plan. Also, the LUCE
plan is cited in meetings as the rationale for immense and dense developments. Prado Road is also part of
the traffic circulation plan for San Luis Ranch and Avila Ranch. The public deserves to see the entire plan
and the inclusion of the Prado Road overpass or interchange. One cannot "cherry pick" the LUCE plan
and provide for just the parts that are "easy" and/or profitable. All of the support system should be
in place.
Since the developers are to date solely responsible for traffic/road improvements - their "fair share" - this
overpass or interchange, will substantially impact the cost of the projects being proposed.
City staff continues to entertain and even approve development without getting a clear answer on whether
or not the overpass or interchange is even viable. This is unconscionable.
A transparent, public discussion should occur with CALTRANS about the Prado Road interchange
and/or overpass with both the Planning Commission and City Council present as soon as possible.
Real financial figures and real measurements should be included at that meeting.
I have personally been on the course of the planned Prado Road with an old-fashioned tape
measure and elected officials, and made the point very clear that at certain points along the route -
Prado Road - as a "four lane truck highway" simply does not fit.
After a public meeting City staff and elected officials should insist that the traffic infrastructure - out of the
pocket of the developer- be completed either at the same time the development is being constructed or
prior to it.
The developer of San Luis Ranch has already received approval to build homes in the first phase in back of
Target and funnel all of the resulting traffic onto Froom Ranch Road and then onto Los Osos Valley Road.
This was not what was guaranteed in the LUCE and in public meetings.
14757
a
The San �uis Rancf� de�eloper's represen�ative has publicly qu�pp�d, "Who knvws when tF�e Pra�fo Raad
overpass wifl e�er be huilt?" For those o� t�s t�a� care a�ou#"smart growth" an� keeping vne's word, that
statement is nvt comfvrtir�g.
The construction vf Prado Road cannvt be an aft�rthought. According tv CEQA, when "a larger
project is identified" -as in Prado Road fram Madonna Road to Broad Street tha# has been an the
Ci#y Master Plan since 19fi�- it needs �o ha�e a camprehensE�e En►►ironmental Impact Report [EIR3
and he e�aluated ❑n the meri#s ❑f that study. CurrQntly, city s#aff is af[owi�g Prado Road to be
"illegalfy segmented" or "piecemea}ed" which is in �ioiatian af CEQA.
As was mentioned En the pre�ivus Plan�ing Commission meeting vn San Luis Ranc�, what f�apperss when
people transit in �ars over Highway 't0'� eastbo�and towards Broad S�reet. The "four-lar�e truck highway" -
Prado Road - wil[ then cross Sauth Higuera...and then what? Wilf traffic be funneled to two lanes through
Serra Meadows? Turn Narth or South anto Soutf� Higuera? Vlle deserve ta have these answers now.
5. AfFordab[e housing and Workforce Hvusing
AffvrdabEe hausing is �ra�ased and the quest�on is, "At wl�at �r�ce?" The �ost of road impra�ernents needs
ta �e factored into the purchase prEce sa that the de�elaper can make a prvfiit.
I�wvuld be gvod business sense tv knaw where the workers €ar this CCRC wiil be li�ing. Wi[1 they
be making a "lEv�ng wage?" Most emplvyees in these types of de�elopments are making $12-$18 per hour.
There are or�ly a handful of tzighly-paid dact�rs and t�era�ists �hat wifl be employed. Let's analyze this ratio
ahead vf time and discuss where the ho�asing exists for these modestfy paid workers.
fi. Affordabte hvusing �s. Student renta�s.
LJnfess ther� is an appartunity for deed restrictions a�dlor strict "Conditians, CQvenan�s and Restraints"
�CC and R's� on the proposed homes and apartmet�#s, who is to say that�h�e residential units wil[ rtvt be
turned i��a a mass of student renta[s.
7. Nvise
The noise#rom this develo�mer�t wi3f need tv be mitigated. The no�se w�ll be frvm the people and the
�ehicular traffic. Currently that area has a �ural atmasphere.
8. Trees and animal protection
Ha�ing �iewed the preliminary p�an, my aftentivn �s afsv vn the fact that constructi�n is on en�ironme�rta�[y
sensiti�e areas. If is my hope that any de�elapment wilf be beivw the 1�0-�oot line to preserve the �iew as
established �n fhe LL1GE. E�en with that, i� is my hape that any deve[opment wi[I inci�de as many trees arad
preservativn of the pu�fic�iewshed v�t�e fvvthills.
9. Access to existing commercia� de�elopment and recreatian
Since this is a scoping meeting, I wvtafd also like to see access to waE�cing ar�d biEcing trails be a�paren�. �
vvauld also IiKe t� see a�cess to public transportatian far t[�ese seniors an� future residents_ Ac�ess ta the
Laguna La�Ce recreatEana� area has �vt beer� giver� the atter�tion that it deserves.
Having lvvked a� tF�e pre[im�nary plan, I would afsa fike ta see as many Class '[ bi�Ce pat�s in the
de�elopment�a er�sure the safety of residents and workers.
1�.Pubfic Inpu#
As I mentioned at the LUCE meetings, it wauld serve the deve[oper we[l to send a notice #o t#�e
neighbarhoads that wifl be impacted an� rece�ve �u��i�feedhack on the de�elapmer�t.
'�7. Agric��tura� Land
14758
3
I wish that John Madanna caufd use a govd partior� vf tf�is fand for grazing ar crops. I mourn tF�e demise af
Iocai agricultural land in the name of 3nfilf. I believe tf�at +t is myopic fiar the sake af the next generation.
Ir� closing, thank yo� for the op�vrtunity to enc�merate cancerns now so that they car� be addressed in the
near future,
5incerefy,
�fila tlujo�rch-La Ba�rre
Mi[a Vujovich-La Barre
650 Skyfine ❑rive
San �uis Qbispo, CA 934d5
14759
4
STATE.flF CALIFQRN.IA. Edmund C..Brvwn.�r....Governor
NATIVE AMERICAN HERITAGE COMMISSION �"`�` '• :
�� .;_�;�.,
Environmental and Cultural Department ''�r��.,-��
�-:S;�PkC;�:�:}'
1550 Harbor Blvd.,Suite 700 •�p�,`:_,�:�-
West Sacremento,CA 95691 ���;��'
Phone(916)373-3710 �
July 27, 2017
Shawna Scott
City of San Luis Obispo
919 Palm Street
San Luis Obispo, CA 93401
Sent via e-mail: sscott@slocity.org
RE: SCH#2017071033; Froom Ranch Specific Plan Project, City of San Luis Obispo; San Luis Obispo County,
California
Dear Ms. Scott:
The Native American Heritage Commission has received the Notice of Preparation (NOP)for Draft Environmental
Impact Report for the project referenced above. The California Environmental Quality Act(CEQA) (Pub. Resources
Code §21000 et seq.), specifically Public Resources Code section 21084.1, states that a project that may cause a
substantial adverse change in the significance of an historical resource is a project that may have a significant
efFect on the environment. (Pub. Resources Code § 21084.1; Cal. Code Regs., tit.14, § 15064.5 (b) (CEQA •
Guidelines Section 15064.5 (b)). If there is substantial evidence, in light of the whole record before a lead agency,
that a project may have a significant effect on the environment, an environmental impact report(EIR)shall be
prepared. (Pub. Resources Code§ 21080 (d); Cal. Code Regs., tit. 14, § 15064 subd. (a)(1) (CEQA Guidelines §
15064 (a)(1)). In order to determine whether a project will cause a substantial adverse change in the significance
of a historical resource, a lead agency will need to determine whether there are historical resources with the area of
project effect(APE).
CEQA was amended significantly in 2014. Assembly Bill 52 (Gatto, Chapter 532, Statutes of 2014) (AB 52)
amended CEQA to create a se arate cate a of culturai resources, "tribal cultural resources" (Pub. Resources
Code §21074) and provides that a project with an effect that may cause a substantial adverse change in the
significance of a tribal cultural resource is a project that may have a significant effect on the environment (Pub.
Resources Code § 21084.2). Please reference California Natural Resources Agency (2016) "Final Text for tribal
cultural resources update to Appendix G: Environmental Checklist Form,"
ht# :Ilr�sources.ca. ovlce altl�cs1�b521Clean-finai-AB-52-/� -G-text-5uhrnitfed. df. Public agencies shall, when
feasible, avoid damaging effects to any tribal cultural resource. (Pub. Resources Code § 21084.3 (a)). AB 52
applies to any project for which a notice of preparation or a notice of negative declaration or mitigated
negative declaration is filed on or after July 1, 2015. If your project involves the adoption of or amendment to a
general plan or a specific plan, or the designatibn or proposed designation of open space, on or after March 1,
2005, it may also be subject to Senate Bill 18 (Burton, Chapter 905, Statutes of 2004) (SB 18). Both SB 18 and
AB 52 have tribal consultation requirements. If your project is also subject to the federal National
Environmental Policy Act(42 U.S.C. §4321 et seq.) (NEPA), the tribal consultation requirements of Section 106 of
the National Historic Preservation Act of 1966 (154 U.S.C. 300101, 36 C.F.R. § 800 et seq.) may also apply.
The NAHC recommends lead agencies consult with all California Native American tribes that are traditionally
and culturally affiliated with the geographic area of your proposed project as early as possible in order to avoid
inadvertent discoveries of Native American human remains and best protect tribal cultural resources. Below is a
brief summary of artions of AB 52 and SB 18 as well as the NAHC's recommendations for conducting cultural
resources assessments. Consult your legal counsel about compliance with AB 52 and SB 18 as well as
compliance with any other applicable laws.
14760
AB 52
AB 52 has added to CEQA the additional requirements listed below, along with many other requirements:
1. Fourteen Da Period ta Pr��ide Notice of Com letion of an A licati�nl�ecisipn to Undertake a Pro'ect: Within
fourteen (14)days of determining that an application for a project is complete or of a decision by a public
agency to undertake a project, a lead agency shall provide formal notification to a designated contact of, or
tribal representative of, traditionally and culturally affiliated California Native American tribes that have
requested notice, to be accomplished by at least one written notice that includes:
a. A brief description of the project.
b. The lead agency contact information.
c. Notification that the California Native American tribe has 30 days to request consultation. (Pub.
Resources Code § 21080.3.1 (d)).
d. A"California Native American tribe" is defined as a Native American tribe located in California that is on
the contact list maintained by the NAHC for the purposes of Chapter 905 of Statutes of 2004 (SB 18).
(Pub. Resources Code §21073).
2. Be in Co�sultatian Within 3a �]a s of Recp€v:n a Tribe's Re uest for Cnnsult�tion and Before Releasin �
Ne ative ❑eelaraiion Miti ated Ne ative Declaration, or En�irnnmental Impact Report: A lead agency shall
begin the consultation process within 30 days of receiving a request for consultation from a California Native
American tribe that is traditionally and culturally affiliated with the geographic area of the proposed project.
(Pub. Resources Code §21080.3.1, subds. (d)and (e))and prior to the release of a negative declaration,
mitigated negative declaration or environmental impact report. (Pub. Resources Code§ 21080.3.1(b)).
a. For purposes of AB 52, "consultation shall have the same meaning as provided in Gov. Code §
65352.4 (SB 18). (Pub. Resources Code §21080.3.1 (b)).
3. Mandatory 7opics of Consultation lf Requested hv a Tribe: The following topics of consultation, if a tribe
requests to discuss them, are mandatory topics of consultation:
a. Alternatives to the project.
b. Recommended mitigation measures.
c. Significant effects. (Pub. Resources Code§ 21080.3.2 (a)).
4. ❑iscretionary T�pics Qf Consultation: The following topics are discretionary topics of consultation:
a. Type of environmental review necessary.
b. Significance of the tribal cultural resources.
c. Significance of the project's impacts on tribal cultural resources.
d. If necessary, project alternatives or appropriate measures for preservation or mitigation that the tribe
may recommend to the lead agency. (Pub. Resources Code §21080.3.2 (a)).
5. Confidentialit of Inf�rmation Submitted b a Tribe Durin the Environmental Review Process: With some
exceptions, any information, including but not limited to, the location, description, and use of tribal cultural
resources submitted by a California Native American tribe during the environmental review process shall not be
included in the environmental document or otherwise disclosed by the lead agency or any other public agency
to the public, consistent with Government Code sections 6254 (r)and 6254.10. Any information submitted by a
California Native American tribe during the consultation or environmental review process shall be published in a
confidential appendix to the environmental document unless the tribe that provided the information consents, in
writing, to the disclosure of some or all of the information to the public. (Pub. Resources Code §21082.3
(c)(1)).
6. Discussion of Im acts to Tribal Cultural Resources in the Environmental Document: If a project may have a
significant impact on a tribal cultural resource, the lead agency's environmental document shall discuss both of
the following:
a. Whether the proposed project has a significant impact on an identified tribal cultural resource.
b. Whether feasible alternatives or mitigation measures, including those measures that may be agreed to
pursuant to Public Resources Code section 21082.3, subdivision (a), avoid or substantially lessen the
impact on the identified tribal cultural resource. (Pub. Resources Code § 21082.3 (b)).
2 14761
7. Conclusion of Consultation: Consultation with a tribe shall be considered concluded when either of the
following occurs:
a. The parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on a
tribal cultural resource; or
b. A party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be
reached. (Pub. Resources Code §21080.3.2 (b)).
8. Recommendin Miti ation Measures A reed U on in Consultation in the Environmental Document: Any
mitigation measures agreed upon in the consultation conducted pursuant to Public Resources Code section
21080.3.2 shall be recommended for inclusion in the environmental document and in an adopted mitigation
monitoring and reporting program, if determined to avoid or lessen the impact pursuant to Public Resources
Code section 21082.3, subdivision (b), paragraph 2, and shall be fully enforceable. (Pub. Resources Code §
21082.3 (a)). ,
9. Required Consideration of Feasible Mitiqafian: If mitigation measures recommended by the staff of the lead
agency as a result of the consultation process are not included in the environmental document or if there are no
agreed upon mitigation measures at the conclusion of consultation, or if consultation does not occur, and if
substantial evidence demonstrates that a project will cause a significant effect to a tribal cultural resource, the
lead agency shall consider feasible mitigation pursuant to Public Resources Code section 21084.3 (b). (Pub.
Resources Code §21082.3 (e)).
10. Exam les of Miti ation Measures That lf Feasible Ma Be Considered to Avoid or Minimize Si nificant
Ad�erse Impacts to Tribal Cultural Resources:
a. Avoidance and preservation of the resources in place, including, but not limited to:
i. Planning and construction to avoid the resources and protect the cultural and natural context.
ii. Planning greenspace, parks, or other open space, to incorporate the resources with culturally
appropriate protection and management criteria.
b. Treating the resource with culturally appropriate dignity, taking into accourlt the tribal cultural values
and meaning of the resource, including, but not limited to, the following:
i. Protecting the cultural character and integrity of the resource.
ii. Protecting the traditional use of the resource.
iii. Protecting the confidentiality of the resource.
c. Permanent conservation easements or other interests in real property, with culturally appropriate
management criteria for the purposes of preserving or utilizing the resources or places.
d. Protecting the resource. (Pub. Resource Code §21084.3 (b)).
e. Please note that a federally recognized California Native American tribe or a nonfederally recognized
California Native American tribe that is on the contact list maintained by the NAHC to protect a
California prehistoric, archaeological, cultural, spiritual, or ceremonial place may acquire and hold
conservation easements if the conservation easement is voluntarily conveyed. (Civ. Code§815.3 (c)).
f. Please note that it is the policy of the state that Native American remains and associated grave artifacts
shall be repatriated. (Pub. Resources Code§ 5097.991).
11. Prerequisites for Certifyinq an Enviranmental Impact Repo�t or Adopting a Mitigated Neqative Declaration or
Ne ative Declaration with a Si nificant Im act on an Identified Tribal Cultural Resource: An environmental
impact report may not be certified, nor may a mitigated negative declaration or a negative declaration be
adopted unless one of the following occurs:
a. The consultation process between the tribes and the lead agency has occurred as provided in Public
Resources Code sections 21080.3.1 and 21080.3.2 and concluded pursuant to Public Resources Code
section 21080.3.2.
b. The tribe that requested consultation failed to provide comments to the lead agency or otherwise failed
to engage in the consultation process.
c. The lead agency provided notice of the project to the tribe in compliance with Public Resources Code
section 21080.3.1 (d)and the tribe failed to request consultation within 30 days. (Pub. Resources
Code § 21082.3 (d)).
This process should be documented in the Cultural Resources section of your environmental document.
The NAHC's PowerPoint presentation titled, "Tribal Consultation Under AB 52: Requirements and Best Practices"
may be found online at: http://nahc.ca.gov/wp-contenUuploads/2015/10/A652TribalConsultation_CaIEPAPDF.pdf
3 14762
SB 18
SB 18 applies to local governments and requires local governments to contact, provide notice to, refer plans to,
and consult with tribes prior to the adoption or amendment of a general plan or a specific plan, or the designation of
open space. (Gov. Code § 65352.3). Local governments should consult the Governor's Office of Planning and
Research's "Tribal Consultation Guidelines,"which can be found online at:
https://www.opr.ca.gov/docs/09_14_05_Updated_Guidelines_922.pdf
Some of SB 18's provisions include:
1. Tribal Cansu�tatian: If a local government considers a proposal to adopt or amend a general plan or a specific
plan, or to designate open space it is required to contact the appropriate tribes identified by the NAHC by
requesting a "Tribal Consultation List." If a tribe, once contacted, requests consultation the local government
must consult with the tribe on the plan proposal. A tribe has 90 days from the date of receipt of notification
to request consultation unless a shorter timeframe has been agreed to by the tribe. (Gov. Code §
65352.3 (a)(2)).
2. No Statuto Time Limit on SB 18 Tribal Consultation. There is no statutory time limit on SB 18 tribal
consultation.
3. Con_fidentialify: Consistent with the guidelines developed and adopted by the Office of Planning and Research
pursuant to Gov. Code section 65040.2, the city or county shall protect the confidentiality of the information
concerning the specific identity, location, character, and use of places, features and objects described in Public
Resources Code sections 5097.9 and 5097.993 that are within the city's or county's jurisdiction. (Gov. Code
§65352.3 (b)).
4. Conclusion of SB 18 Tribal Consultation: Consultation should be concluded at the point in which:
a. The parties to the consultation come to a mutual agreement concerning the appropriate measures for
preservation or mitigation; or
b. Either the local government or the tribe, acting in good faith and after reasonable effort, concludes that
mutual agreement cannot be reached concerning the appropriate measures of preservation or
mitigation. (Tribal Consultation Guidelines, Governor's Office of Planning and Research (2005) at p.
18).
Agencies should be aware that neither AB 52 nor SB 18 precludes agencies from initiating tribal consultation with
tribes that are traditionally and culturally affiliated with their jurisdictions before the timeframes provided in AB 52
and SB 18. For that reason, we urge you to continue to request Native American Tribal Contact Lists and "Sacred
Lands File"searches from the NAHC. The request forms can be found online at:
http://nahc.ca.gov/resources/forms/
NAHC Recommendations for Cultural Resources Assessments
To adequately assess the existence and significance of tribal cultural resources and plan for avoidance,
preservation in place, or barring both, mitigation of project-related impacts to tribal cultural resources, the NAHC
recommends the following actions:
1. Contact the appropriate regional California Historical Research Information System (CHRIS) Center
(http://ohp.parks.ca.gov/?page_id=1068)for an archaeological records search. The records search will
determine:
a. If part or all of the APE has been previously surveyed for cultural resources.
b. If any known cultural resources have been already been recorded on or adjacent to the APE.
c. If the probability is low, moderate, or high that cultural resources are located in the APE.
d. If a survey is required to determine whether previously unrecorded cultural resources are present.
2. If an archaeological inventory survey is required, the final stage is the preparation of a professional report
detailing the findings and recommendations of the records search and field survey.
a. The final report containing site forms, site significance, and mitigation measures should be submitted
immediately to the planning department. All information regarding site locations, Native American
human remains, and associated funerary objects should be in a separate confidential addendum and
not be made available for public disclosure.
4 14763
b. The final written report should be submitted within 3 months after work has been completed to the
appropriate regional CHRIS center.
3. Contact the NAHC for:
a. A Sacred Lands File search. Remember that tribes do not always record their sacred sites in the
Sacred Lands File, nor are they required to do so. A Sacred Lands File search is not a substitute for
consultation with tribes that are traditionally and culturally affiliated with the geographic area of the
projecYs APE.
b. A Native American Tribal Consultation List of appropriate tribes for consultation concerning the project
site and to assist in planning for avoidance, preservation in place, or, failing both, mitigation measures.
4. Remember that the lack of surface evidence of archaeological resources (including tribal cultural resources)
does not preclude their subsurface existence.
a. Lead agencies should include in their mitigation and monitoring reporting program plan provisions for
the identification and evaluation of inadvertently discovered archaeological resources per Cal. Code
Regs., tit. 14, section 15064.5(f) (CEQA Guidelines section 15064.5(f)). In areas of identified
archaeological sensitivity, a certified archaeologist and a culturally affiliated Native American with
knowledge of cultural resources should monitor all ground-disturbing activities.
b. Lead agencies should include in their mitigation and monitoring reporting program plans provisions for
the disposition of recovered cultural items that are not burial associated in consultation with culturally
affiliated Native Americans.
c. Lead agencies should include in their mitigation and monitoring reporting program plans provisions for
the treatment and disposition of inadvertently discovered Native American human remains. Health and
Safety Code section 7050.5, Public Resources Code section 5097.98, and Cal. Code Regs., tit. 14,
section 15064.5, subdivisions (d) and (e) (CEQA Guidelines section 15064.5, subds. (d)and (e))
address the processes to be followed in the event of an inadvertent discovery of any Native American
human remains and associated grave goods in a location other than a dedicated cemetery.
Please contact me if you need any additional information at gayle.totton@nahc.ca.gov.
Sincerely,
��
� Totton, M.A., PhD.
ss cia#e Governmental Program Analyst
cc: State Clearinghouse
5 14764
Scott, Shawna
From: Salinantribe <salinantribe@aol.com>
Sent: Monday,July 31, 2017 8:22 PM
To: Scott, Shawna
Subject: Froom Ranch Specific Plan Project
Greetings Scott, I have reviewed the proposed project and have no concerns at this time. Thanks, Patti Dunton,Tribal
Administrator
Sent from my iPhone
1 14765
Bicycle Advisory Committee
July 30, 2017
Draft
-Safe, convenient and consistent bicycle-pedestrian access through Irish Hills Plaza to
Froom Ranch Road, preferably a multi-use trail along the western edge of the plaza so
bicyclists and pedestrians can avoid maneuvering through the parking lots. This trail
would enable pedestrians and people on bikes to shop at Irish Hills Plaza without
having to travel on Los Osos Valley Road; and to cross Los Osos Valley Road to
access bike/pedestrian improvements being constructed as part of the San Luis Ranch
development.
-Safe and convenient bicycle/pedestrian access to C.L. Smith Elementary School and
Laguna Middle School for students and employees who live in the planned multi-family
units.
-Protected intersections on Los Osos Valley Road at Froom Ranch and Auto Park Way.
-Auto Park Way should be a complete street.
-Froom Ranch Road from Los Osos Valley Road to its terminus at the Irish Hills Open
Space should be a complete street.
-Fair share contribution to construct and connect these Bob Jones Trail segments to the
existing segment from Prado Road to Los Osos Valley Road: Los Osos Valley Road to
the Octagon Barn, a grade-separated crossing of Los Osos Valley Road under Highway
101 and the Prefumo segment from Oceanaire Drive to Calle Joaquin.
14766
S
.r `�FdAMA�'IpN�
�`� `� °�� LAFCO - San Luis Obispo - Local Agency Formation Commission
� � _� N SLO LAFCO- Serving the Area of San Luis Obispo County
�
z
,!`9�. Le.v
C��5�8f���� August 1, 2017
COMMISSIONERS Ms. Shawna Scott, Associate Planner
Community Development Department
Chairman City of San Luis Obispo
MARSHALLOCHYLSKI g19 Palm Street
Special District Member San Luis Obispo, CA 93401
Vice-Chairman
EDWAAGE Subject: Notice of Preparation of an Environmental Impact Report (EIR) —
City Member Froom Ranch Specific Plan and Annexation
DEBBIEARNOLD Dear Ms. Scott:
County Member
Thank you for the opportunity to provide comments regarding the scope and
LYNN COMPTON content of the draft EIR and Specific Plan for Froom Ranch. The Local Agency
County Member
Formation Commission (LAFCO) is a Responsible Agency that may use these
ROBERT ENNS documents for consideration of a future annexation to the City. LAFCO's
Special District Member comments are focused on the potential annexation of this area into the City and
the off-site mitigation for the Madonna-Gap annexation to protect prime
ROBERTAFONZI agricultural lands: The 110 acre area is within the City's Sphere of Influence.
City Member The Sphere of Influence for the City was updated in October 2016 and identifies
areas which may�be annexed into the City for �ervices over the next 20 years.
TOM MURRAY The Sphere of Influence Update and Municipal Service Review prepared and
Public Member
approved by LAFCO may be useful in preparing the draft EIR. Please consider
�� the following comments when completing the EIR:
ED EBY 9, Name of Contact Person. David Church, Executive Officer, San Luis
Special,District Member Obispo Local Agency Formation Commission, 1042 Pacific Street, Suite A,
San Luis Obispo, CA 93401. (805) 788-2096.
ADAM HILL
County Member 2 permit(s) or Approval(s)Authority. LAFCO is responsible for determining
JAMIEL.IRONS the Sphere of Influence for jurisdictions throughout the County, including
City Member the City of San Luis Obispo. LAFCO also considers any annexations or
changes of organization to a jurisdiction's service area. The proposed
HEATHERfENSEN annexation is subject to LAFCO's local policies and procedures which can
Public Member be found on our website at www.slolafco.com. These policies and
procedures should be reviewed as part of the CEQA process if LAFCO is to
$TAFF use the EIR as a Responsible Agency in considering the annexation. Of
DAVIDCHURCH particular note is the preparation of a Plan for Services by the City. A Plan
Executive Officer for Services identifies the services that the City would deliver and the City's
capability to provide such services. The specific government code section
RAYMONDA.BIERING that identifies the elements of:a plan for services is aS follows: �
Legal Counsel
M�KEP�TER GC.56653. (a) Whenever a local agency submits a resolution of�application
Senior Analyst for a change of organization or reorganization pursuant to this part,:the local
.agency shall submit with the resolution of application a plan for providing
DONNAJ.BLOYD services within the affected territory.
Commission Clerk
1042 Pacific Street, Suite A • San Luis Obispo, California 93401
Tel: 805.781.5795 Fax: 805.788.2072 www.slolafco.com 14767
Froom Ranch NOP-EIR Page 2 of 3
LAFCO Comments August 1, 2017
(b) The plan for providing services shall include all of the following information and any
additional information required by the commission or the executive officer:
(1) An enumeration and description of the services to be extended to the
affected territory.
(2) The level and range of those services.
(3) An indication of when those services can feasibly be extended to the
affected territory.
(4) An indication of any improvement or upgrading of structures, roads, sewer
or water facilities, or other conditions the local agency would impose or
require within the affected territory if the change of organization or
reorganization is completed.
(5) Information with respect to how those services will be financed.
3. Environmental Information. In order to consider the annexation of this area into the
City an adequate environmental document must be prepared for LAFCO's use. To
expedite the annexation process, we recommend that the City's EIR fully address the
potential environmental impacts of adding this area to the City. A comprehensive
analysis of the environmental impacts, including GC 56064 defining prime agricultural
lands, related to the area proposed for annexation will enable LAFCO to use the EIR
prepared by the City for annexing the property. The EIR should address the capability
of a jurisdiction to provide public services to existing and future residents with regard to
water supply and demand, sewer capacity and demand, fire and police response,
growth and development, roads, and financial constraints and opportunities.
4. General Comment. Annexation generally requires the following information and
activities;
a. Application through a petition of property owners or a City Resolution of Application
- Submittal of Application
b. Preparation of Maps and submittal of all related information, approvals and
documentation
c. Approval of Negotiated Tax Agreement between the City and County
d. Prezoning approved by the City; City is Lead Agency
e. Preparation of a Plan for Services by the City
f. Evaluation and Consideration by LAFCO, if approved;
g. Post annexation steps - condition compliance and Board of Equalization Filing and
other notifications
5. Project Description. The Project Description should provide a description that addresses
Prezoning, the Negotiated Tax Agreement, and the annexation processes. This will make
the project description more complete and accurate. The annexation process for these
areas should be included in the Project Description. It also should be clarified what area
would be annexed into the City. An annexation map should be included in the document. It
would appear that a Water Assessment pursuant to SB 610 will be prepared for this
14768
Froom Ranch NOP-EIR Page 3 of 3
u
LAFCO Comments August 1, 2017
proposal/project. This analysis evaluates the projects water supply to serve the anticipated
demand.
6. Impact Analysis. LAFCO policies and procedures should be incorporated into the impact
analysis discussions as appropriate. LAFCO has polices that address the following impact
areas:
Agricultural Resources Public Safety Water/Wastewater
Land Use Growth Inducing
These impact areas should be analyzed for consistency with LAFCO policies.
7. LAFCO Agricultural Policies. LAFCO's goals, policies, and guidelines regarding
Agricultural Resources should be included in the EIR analysis. These policies should be
reviewed and analyzed for consistency with the proposed specific plan. A key policy to be
considered is the 1:1 substitution ratio for preserve prime agricultural land. A clear project
description or map clarifying the agricultural easement offset and preservation of 7.1 acres
from the Madonna-Gap annexation should be included. The reconfigured 7.1 acres must
meet the intent of LAFCO's action for the Madonna-Gap development. Also if any other
prime farmland is converted as part of the Froom Ranch development, then its impacts
should be offset per LAFCO Policy 12.
8. Mitigation Measures. Mitigation Measures that assist LAFCO in achieving its legislative
goals such as reducing the impacts to agriculture and open space should be referenced.
Other key mitigation measures regarding roads and circulation, air quality, and public
services should be noted. While LAFCO has discretion over the annexation proposal,
mitigation measures that reduce impacts to resources assist LAFCO in the decision making
process and should be referenced in this section.
9. Permit Stipulations/Conditions. Unknown at this time.
10. Alternatives. Any analysis of alternatives should include an evaluation of the impacts the
proposed annexation might have on the environment. LAFCO has the discretion to modify
a boundary change proposal, however; if a particular alternative was not studied as part of
the CEQA document, LAFCO would not be able to approve a modified annexation due to
an inadequate CEQA review.
We appreciate being contacted with regard to this project and look forward to hearing more
about the plan as it progresses through the environmental review and planning process. If you
have any questions regarding our comments please contact me at 788-2096.
Sincerely,
�
David Church,
LAFCO Executive Officer
cc. Commissioners
Ray Biering, LAFCO Counsel
14769
F r � CAL F/RE
�t�;�.�t��
San Luis Obispa 635 N.Santa Rosa•San Luls 06ispo,CA 93405
Coun ty Frre De pa rtmen t Phone:805.543.4244•Fax:805.543.4248
www.calfireslo.org
h�RFr ,
.-- �
;,�[�I►,,,; Scott M.Jalbert,Unit Chief
,
�- ,D�pt;, -S
August 2, 2017
City of San Luis Obispo
Community Development
9�9 Palm Street
San Luis Obispo, CA. g�4oi
Subject: Froom Ranch Specific Plan project.
Dear Shawna Scott
We have reviewed the annexation of the Froom Ranch Specific Plan Area consists of two
parcels located at i2i65 and i2393 Froom ranch way,totaling approximately 110 acres (APN
06�-24�-03o and o6�-24�-03�)within unincorporated San Luis Obispo County,and adjacent
to City of San Luis Obispo city limits. The annexation poses no adverse impacts relative to
providing emergency services from CAL FIRE/San Luis Obispo County Fire Department. If
these lands are not annexed, any future development associated with these lands will be
reviewed by the County of San Luis Obispo.
If I can provide additional information or assistance, please call(805) 593-3422•
Sincerely,
Travis Craig
Battalion Chief/Fire Marshal
14770
COUNTY OF SAN LUIS OBISPO
� DEPARTMENT OF AGRICULTURE /WEIGHTS & MEASURES
;, ,� �neasures
DATE: August 4, 2017
TO: Shawna Scott,Associate Planner
FROM: Lynda L.Auchinachie,Agriculture Department
SUBJECT: Froom Ranch Specific Plan Notice of Preparation (1957)
Thank you for the opportunity to comment on the scope and content of the draft
environmental impact report(DEIR)for the Froom Ranch Specific Plan Project. In addition to the
issues identified in the initial study the following is recommended to be evaluated in the DEIR:
• The project includes annexation to the City of San Luis Obispo.The Cortese-Knox-Hertzberg
Local Government Reorganization Act's definition of"prime agricultural land" should be
included as part of the evaluation of project impacts to agricultural resources. Prime
agricultural land as defined in Government Code 56064 includes:
"Prime Agricultural land"means an area of land, whether a single parcel or contiguous
parcels, that has not been developed for a use other than an agricultural use and that
meets any of the following qualifications:
a) Land that qualifies, if irrigated, for rating as class I or class II in the USDA Natural
Resources Conservation Service land use capability classification, whether or not land is
actuall�irrigated, provided irrigation is feasible.
Irrigation was determined to be feasible on the project site at the time the agricultural
easement offset was proposed and established for the Madonna-Gap annexation.
• How will the integrity of the existing agricultural easement be maintained with the
proposed development?
Thank you for your consideration. If you have questions, please call 781-5914.
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
14771
From: Lea Brooks <leabrooks332@gmail.com>
Sent: Tuesday, August 01, 2017 11:50 AM
To: Fukushima, Adam
Subject: More Froom Ranch and Broad Street Bike Blvd
Hi Adam:
Regarding Froom Ranch scoping, I rode the west segment of Calle Joaquin today to KSBY and the Mountainbrook
Church at the top of the hill. The proposed secondary emergency access from Froom Ranch is a road to the
church. Planning Commission Chair Chuck Stevenson was concerned that this road would be closed unless there
is an emergency and expressed support for keeping it open and visible so residents of Froom Ranch will know of
its existence. It's surprisingly remote back there.
From a BAC perspective, I'm not sure if it's worthwhile to augment Chuck's concerns. This segment of Calle
Joaquin is definitely not a complete street. If the emergency road is open and residents use it, some
improvements to make it safer for bicyclists should be added. I didn't realize there is access to the Irish Hills Open
Space via the driveway to the church. Do you know if the driveway is part of the church property- maybe the trail
access was a mitigation -or a city maintained road? It looks more like a driveway, but you never know.
Regarding the bicycle boulevard: How can the BAC invite city council members on a tour to show the three
alternatives? As an advisory body, do we need to vote via e-mail to offer a tour and can staff participate? I think a
tour would be really helpful to council members.
Thanks.
Lea
14772
STATE OE'CAL]F4RI�IA�'ALIFURNIA STATE TRANSPURTATIUN AGENCY ED�v1U1Vp G.13ROWN Jr Governor
DEPARTMENT OF TRANSP�RTATI�N �
50 E-[[Gi1ERA STREET r`r����l
SAN LU[S bB[SF'O,CA 93401-5415 ����
PHQtJE {�OS)549-31a1
FAX (SOS)549�3329
TTY 7l 1 Flcx yoau�power!
http:ll�vww.dot.ca.�ov;'dlti[�5i 13e eiaeigv efficiertl!
August 10, 2017
Ms. Shawna Scott OS-SLO-25.9
City of San Luis Obispo Coinmunity Develapment SCH: 2017071033
919 Palm Street
San Luis Obispo, CA 43401
Dear Ms. Scott:
NOTICE OF PREPARATION FOR FROOM RANCH SPECIFIC PLAN PROJECT
Thank you for providing Caltrans the opportunity to comment on the Notice of Preparation (NOP)
for the Froom Rancll Specific Plan. This project includes a Specific Plan, General Plan
A�nendment, and related actions that propose the addition of 578 residential units, 100,000 sf
commercial retail, 59 acres of conservationlopen space and other public facilities and road
improvements. We commend the project's goals of providing additional work force housing to
promote a job�-�lausir�g balance as a stra�egy to reduce Vehicle Miles Traveled (VMT) and single
accupancy vehicle dependency. These objectives are consist�nt with the Caltrans' Strategic
Manc�genzent Plan 2015-2020 and 5tate planning priorities.
Caltrans appreciates continued coordination with the City on this project as it relates to
transpartation analysis and identification of impacts to the State Highway Systein and provides
the follawing camments regarding transportation analysis. The Preliminary Transportation
Analysis for the NOP identifies that the project will generate an additional 353 PM Peak Hour
trips. Caltrans believes that this woulc� potentially have significant impacts to US 101, especially
in consideration of tl�e additional trips to be generated by the San Luis Ranch and Avila Ranch
projects. Therefore, it is important that the transportation analysis for the project factor in the trips
anticipated frorn tk�ese and other significant locai development projects.
A transportation analysis of US IO1/Los Osos Valley Road (LOVR) interchange, US 1O11South
Higu�ra Street interchange, and the US �41/Madonna Street interchange is necessary to fully
disclose all patential iinpacts. For the US 101 freeway study segments between Madonna Road
and South Higuera Street, the analysis should also include freeway weave (Leisch Method}, and
mergeldiverge analysis. Caltrans requests that the cumulative conditions o� the TIS reflect the
currei�t Prado Road interchange praject scope that includes an overerossing with northbouild
rainps (not as "full-access" assu�ning northbaund and southbound ramps}. Caltrans would Iike to
clarify t�at tE�e above transportation analysis recominendations �or the Froom Ranch Specific Alan
are based on Caltrans engineering judgeinent tl�at supersedes general guidance or thresholds
outlined in Caltrans' Giaicle for the Prepa�ation of Traffrc Impact Stuclies.
`Pl•oricde ca sca�e,sit�sta�:n.able, d��.te��•a�Led a�ri,rf effi.cr�eti�G Grc�ii�spor•laG�=oiE s��sGem. 14773
to e�ah�nx�ce Californra's eco��oriay a-ri.d li��a.bildty"
Ms. Scott
August 10, 2Q17
Page 2
Caltrans supports six smart mobility principles of location efficiency, reliable mobility, health and
safety, enviranmental stewards�lip, social equity, and robust econamy. We request that the
transportation analysis discuss multimodal transportation strat�gies that improve comlectivity to
the existing and planned transportati�n network that is consistent with the six sinart mobility
princip�es.
Caltrans also requests t�lat any additional post-development water run-off fram the proj ect site,
during or after construction, should not be added to Perfumo Creek ar Froom Creek, as this could
create potential advers� impacts to culverts within Caltrans right-of-way near US 101. This area
has a history of flooding as portians of the project site are within khe 100-year and 500-year
FEMA fload zones. Caltrans cannot allo�v additianal s�orm n.�n-off impacts fram the project to U�
1Q1.
Thank you far considering these comments and we appreciate cantinued coordination through the
subsequent phases of environmental revievv for this praject. Please feel welcorne ta contact me at
(805) 549-3800 or melissa.streder�dotca.�with any questions.
Sincerely,
%��� -�-�
MELISSA STREDER
Caltrans District 5
Development Review
`Pr�oc�rde a sa/'e,srestai��abl.e, in.tegrntecd rri�.c!effrcien.t trcri�s�artatrori.systeriz 14774
ta ert.laa.rtce Ca�li�orrtcct:5 eco�aon�.y a11,d dlca�6ility"
.��.,.�.,..,.k.b..�.�..
California Native Plant 5ociety R�c�°''�°
CiTY OF SAN LU;`a()B15P0
San Luis Obispo County Chapter
P o.Box �s4 f-�IJG � 1 2Q97
San Luis Obispo, CA. 93406
,� COMIUUIVI7Y D�I��LOPMENT
,�..._,.�ri.�..r,_,.r.�..,.��.,......w.. .
August 11, 2017
Ms. Shawna Scott
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA. 93401
RE: Response to Notice of Preparation(NOP) of an Environmental Impact Report(EIR) on a
Proposed Development on the Froom Ranch at Calle Joaquin and Los Osos Valley Road.
Dear Ms. Scott:
The San Luis Obispo County Chapter of the California Native Plant Society wishes to respond to
the above captioned Notice of Preparation(NOP) for a large proposed development on the
Froom Ranch at Calle Joaquin and Los Osos Valley Road in the City of San Luis Obispo.
We have significant concerns about this proposal and request that these concerns be addressed in
the EIR.
I. Development above the 1 SO foot level. The City's General Plan requires that new
development in the Irish Hills stay below the 150 foot elevation line. The current proposal
ignores that restriction and extends well above that line in two areas of the property. (For
purposes of discussion we will refer to the larger southern area as the "plateau" and the smaller
northern area as the "storage area".) This action, if permitted, would have aesthetic, biological,
hydrological, and noise impacts on the project site, on the adjacent Irish Hills Natural Reserve
and on the larger community. These are discussed below.
Aesthetic Impact. Development above the 150 foot elevation on the plateau would be
highly visible and very different from what currently exists in the city limits in the Irish Hills.
The nearby Vineyard Church was developed in the County (which had and has no elevation limit
for development). Church leaders made a conscious decision to develop in the County rather
than annex into the City because of this restriction; therefore the Church's existence in that
location should not be used as a justification for the City abandoning its policies in this regard. It
is also fair to question whether this change could be considered a special privilege: prohibition of
development above the 150 foot elevation has been City policy for more than twenty years, and
it must be demonstrated that the project cannot be undertaken unless this change in City policy is
granted. The current project proposes to construct several buildings on the plateau,together with
the necessary infrastructure to support them; this would include roads, water, sewer, and power
lines (presumably underground), and a generally significant increase in level of activity. A
public hiking trail exists on public land here close to where the road access would be;the road
would create an entirely new social environment in that spot, bringing noise and pollution to an
area free of such disturbances today. This potential needs to be addressed in the EIR.
14775
The proposal for the plateau area is not just seeking to go a few feet above the 150 foot
elevation; it proposes a quantum leap of some 88 feet, to a"roof elevation" of 238 feet. This
may mean(despite denials by the project sponsors) that a large water tank will need to be
constructed at an even higher elevation in order to provide the necessary pressure and flow
volume to meet the needs of domestic water use and firefighting capability. This is because the
main water supply for this entire portion of the city comes from the Edna Saddle Tank some
three miles away. Such a new tank will need pipelines to get the water to it as well as back
down, and will require a lar�e cleared and flattened area on the hillside to locate the structure.
This will have its own impacts, which need to be analyzed in the EIR. (It is important to note
that the City of San Luis Obispo Utilities Department has desired such a facility in the Irish Hills
area for many years, but has been unable either to find a suitable site or to figure out how to
finance it. This proposal will make that desire much more urgent.)
The storage area above 150 feet, although currently of limited natural resource value,
could be restored and used as a trailhead and neighborhood park, and as a superior location for
an historic park preserving the historic buildings of the Froom Ranch. A public use such as this
is a possible justification for development above the 150 foot elevation in that location, while a
private apartment complex that can just as easily be developed below that elevation, is not.
Private development there would in our opinion"privatize"the nearby public lands, creating
possible use conflicts where none exist at this time. This is because the area immediately
adjacent to the storage area is a popular trail and trail junction, experiencing considerable use by
hikers, bicyclists,joggers, etc. This potential conflict needs to be examined by the EIR.
Biological Impact. The Froom Ranch is known or believed to contain at least 13 species
of rare plants (including one Federally listed endangered plant species) and at least 22 species of
animals. Most of the plants occur on the plateau area or on the nearby hills and rocky outcrops.
The plateau also supports an unusual plant community, serpentine bunchgrass grassland. The
Federally listed species, Chorro Creek bog thistle (Cirsium fontinale var. obispoense) in our
opinion at particular risk and this will be addressed further below. The EIR needs to investigate
each of these species, as well as the existing vegetation types, and determine the impacts upon
them occasioned by the project.
Hyd�ological resou�ces on the Plateau. We are concerned that development of the
plateau would disrupt the groundwater flow regime,potentially leading to the loss of the Chorro
Creek bog thistle populations in that location. This is especially true of the fairly large (300
individuals)population near the northern end of the plateau,which is a well-developed seep
whose water source is unclear. The groundwater flow regime at this site needs to be studied and
understood. We believe that road and underground pipe installation could easily interrupt such
flow and cut the seep off from its water supply. At the southern end of the plateau there is a
small creek which also has a healthy population of bog thistle. Earlier proposals for the
development appeared to actually cover over this stream; it is uncertain whether such is still the
case. This potential needs to be addressed in the EIR.
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II. Protection of Chorro Creek bog thistle stands. The Federally listed Chorro Creek bog thistle
occurs in at least two areas on the property, and has been reported in other areas in the past. The
project proposes to stay 50 feet away from the populations of this rare plant; however, nothing is
said about the conditions that support these populations. This species occurs in wet areas such as
springs or seeps in serpentine soils. It is possible, even likely, that development around or near
them could change or interrupt the flow of groundwater and result in the destruction of the
stands, especially the larger northern one. Both of these populations are above the 150 foot
elevation on the plateau. Potential impacts to Chorro Creek bog thistle, especially the potential
for being cut off from an existing underground water source, needs to be analyzed in the EIR.
III. Realignment of Froom Creek and Destruction of Wetlands. The project proposes to
"restore"Froom Creek, whose flow line evidently was changed at some time in the past. The
proposal, however, seems to have more to do with creating space for new development than any
particular desire to "restore"the creek. The proposed alignment would bring the creek very
close to Los Osos Valley Road, picking up the drainage alongside the road, and then circling
back to the point where the creek currently leaves the property. This alignment would
effectively destroy a rich and valuable wetland alongside Calle Joaquin by grading, levee
construction, and interruption of the groundwater flow regime.
Current Condition of Froom Creek. Froom Creek originates in the Irish Hills some 2.5-3
miles northwest of the project location, and flows in a southeasterly direction through a scenic
canyon on mostly publicly-owned and protected lands. After exiting the canyon the creek turns
in a southerly direction and flows for about another mile into San Luis Obispo Creek.
Near its headwaters Froom Creek is pristine and permanent, and is known to contain
southern steelhead; however, in the lower portions of the canyon road construction from many
years ago deposited huge amounts of rock, silt, and debris into the streambed and radically
altered it. In certain areas the creek flows on the surface only for short periods during and after
storm events, and in the lower reaches of the canyon it becomes seasonal. This seasonal
character continues after the creek leaves the canyon and flows on the valley floor toward its
confluence with San Luis Obispo Creek. Once in the valley the creek has essentially no riparian
vegetation; it gives the appearance of being little more than a stormwater conveyance. It is
possible (but is not known for certain)that the creek was placed into its current alignment by
construction; older maps indicate a different location for the creek than is the case today.
However, subsurface flows are another matter, and those flows are our primary concern.
Subsurface Flows. As noted above, upon exiting the canyon and entering Los Osos
Valley, Froom Creek is seasonal, flowing during the winter but drying up in late winter or early
spring. However, there is evidence of significant subsurface flows, which presumably continue
in a southeasterly direction,then surface to create a healthy, rich wetland near the junction of Los
Osos Valley Road and Calle Joaquin.
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Effect of Froom Creek Realignment Proposal. The project proposes to realign Froom
Creek in a large sweep to the east nearly to Los Osos Valley Road, picking up a tributary
drainage there, then swinging back in a wide curve to exit the project site at the same location at
which the creek exits the site today. To do this will require the construction of a large channel
that will cross the subsurface flow pattern possibly intercepting that flow and cutting off the
Calle Joaquin wetlands from their source of water. It would lengthen the creek and reduce its
gradient, thus making it flow more slowly. Furthermore, as an engineered waterway,the creek
will need to be able to contain a 100 year storm event. This in all likelihood means that there
will be a levee on one or both sides of the creek, which in many areas will bury and destroy other
valuable habitat. We believe that the very concept is inconsistent with the City's creek setback
ordinance; the creek's location should establish the setback, rather than moving the creek
somewhere else and saying that it is now res�ecting the setback rules. This is standing the creek
setback ordinance on its head.
The Froom Creek Floodplain and Potential for Flooding. The potential for major
flooding in the project site seems to be understated. Dramatic photographs of several storm
events emphasizing this potential are available on various local websites; we have included one
from flooding in 1973. Flood protection would appear to be a tremendously important
consideration, and the steps needed to protect the development and neighboring properties along
Los Osos Valley Road and Calle Joaquin need to be studied and addressed. This may need to
include the potential for "back-flooding" from San Luis Obispo Creek and Prefumo Creek.
All of these possible impacts of the "restoration" concern us greatly; we are not at all
convinced that the proposal is a net benefit to the local environment. We therefore insist that the
EIR at a minimum include:
1. A thorough analysis of the groundwater and subsurface streamflow of Froom Creek as it
exists today;
2. Engineering calculations and maps depicting the current flood plain of Froom Creek as it
exits the canyon and crosses the project site, and continuing to Froom Creek's confluence with
San Luis Obispo Creek;
3. A design plan for the creek realignment, showing all grading, including elevations of both the
newly formed creek channel, and all levees or other containment features intended to contain at
least the 100 year storm event, together with representative cross sections at appropriate
intervals, and recognizing the potential for back-flooding;
4. A description of the planting palette and distribution that would constitute the "restoration";
5. An analysis of the likely impacts of this project on subsurface water flow and the Calle
Joaquin wetlands, as well as proposed mitigations for those impacts; and
6. Consideration of alternatives, including simply leaving the creek in its current location or
with only minimal realignment, and revegetating its banks with"dry riparian"plantings such as
coast live oak, California bay, elderberry, islay, toyon, and other native species found in similar
situations nearby.
14778
IV. Historic Resources. The Froom Ranch buildings have been found to be of community-wide
historical value by the City's Cultural Heritage Commission, which recommended that they be
retained in their current location if possible. Our view is that the retention and restoration of
these buildings should not be a stand-alone effort,but rather should be done in concert with other
community goals associated with this project. We do not believe that maintaining the buildings
in their current location would result in the most attractive setting for such a facility, and to the
degree that they can be moved and repositioned, they should be placed in an appropriate layout
at the current storage area, with the dairy barn forming one side of the replica historic site (we
understand that the dairy barn cannot be moved). An existing berm provides visual and noise
separation from nearby activities, which would result in a more attractive and appropriate setting
for this rural complex. This would be combined with a trailhead park and perhaps a creekside
trail or walkway describing restoration efforts that would be undertaken on Froom Creek in that
location. In this way the historic site would support and complement City General Plan policies,
by having the only development above the 150 foot elevation be a public amenity.
V. "Double dipping"and other measurements with regard to open space percentage; loss of
open space in the detention basins. There is a seven acre agricultural conservation easement that
would be effectively destroyed by the creek realignment; this was due to the fact that the soils in
that area are rich and productive enough to qualify for such an easement, and it was required by
LAFCO as mitigation for impacts associated with development of the Target shopping center
some years ago. It is possible that LAFCO could require retention of this easement or its
effective replacement. At the very least that seven acres should not be counted toward the
minimum open space requirement(50%) of the project; it has been counted once and should not
be counted again. Doing so would be contrary to City policy and should be disallowed. In
addition, the project uses certain small areas of no real open space value (such as strip of land
between the project site and the roadway alongside the Irish Hills Plaza) as open space. Areas
claimed as open space should be of sufficient size to be able to support wildlife populations with
reasonable connection to larger areas in the Irish Hills. This situation should also be examined in
the EIR, and City Natural Resources staff can make the judgment of whether the areas claimed
as open space can actually be included. We are not particularly impressed by the 50% land
conservation proposal: open space to development ratios of past projects in the City have been
far more generous to the community. These include Tolosa Ranch at 4.5 to 1; Prefumo Homes at
13 to 1; and Bowden Ranch at 16 to 1. Even Tract 2428 in the high-density middle-of-town
Margarita Area was 2.5 to 1.
Finally, the current project apparently proposes to relocate the existing detention basins in order
that they may be used for development. The basins are evidently now proposed to be relocated
downstream onto the neighboring Mountainbrook Church property. It is uncertain whether they
will function at the same scale and in the same manner as the current basins; they may in this
location be subject to back-flooding from San Luis Obispo Creek as noted above. Furthermore it
is uncertain whether the wildlife value of the basins (which held many water birds during the
past winters, including drought years)has been adequately studied, as this change seems to be a
recent concept. We believe that at least one of the basins involves another open space easement,
which would be lost if the project went forward as proposed. That possibility needs to be
14779
examined. Losing dedicated open space is a serious concern and requires mitigation. This
situation needs careful examination in the EIR, especially to determine that habitat losses are
adequately mitigated at the proposed new detention basin site.
Alternatives
We believe that several alternatives offer superior environmental conservation of the project site
while still allowing a reasonable level of urban development there. Among these are:
1. No development above the 150 foot elevation at the plateau. By upholding the current
General Plan, the project's impacts would be significantly reduced. Looking at the "constraints
map"prepared by the project sponsors, one can easily see how many constraints coalesce on the
plateau. This situation cries out for avoidance, and a development staying below that elevation
will avoid many otherwise significant impacts.
2. No development other than a possible historic park and trailhead above 150 foot elevation at
the storage area. The current storage area appears from project maps to be at an elevation of
approximately 160 feet. The project sponsors propose to fill this area with apartments of
unknown floor or roof elevations. We believe that a more appropriate approach in this location
would be to relocate the smaller historic buildings of the Froom Ranch(the dairy barn is said to
be too large to move) in order to create a replica of the original site. An existing berm would
provide visual separation from the current surroundings—the back side of Home Depot and the
queue at the gasoline station at Costco—and provide a more attractive setting for this rural
farmstead. In addition it would allow for a trailhead at the origination of five different trails
radiating out from this point. It would also provide an excellent point from which to learn about
restoration of Froom Creek, which in this area is degraded but which can be restored without
great difficulty.
3. Retention of Froom Creek in its current location. Froom Creek does not need to be relocated
in order to be restored. It has been in its current location for many years, and can be restored
with the so-called"dry riparian"plantings commonly found along similar waterways in the San
Luis Obispo area. These include trees such as coast live oak, California bay,bigleaf maple, and
California buckeye, and shrubs such as toyon, islay, elderberry, California rose, snowberry,
ocean spray, and others, which would make a rich and diverse vegetative palette alongside the
immediate waterway. Indeed, we question whether such a wholesale repositioning of the creek
is consistent with the City's creek setback ordinance.
Summary
In summary, CNPS requests that the following matters be analyzed in the EIR:
1. The visual, noise, and other aesthetic impacts of the development.
2. The biological and hydrological conditions of the plateau area, the impacts of development
upon those resources, and mitigation for those impacts;
14780
3. The groundwater flow regime of the Froom Creek delta and its relationship to the Calle
Joaquin wetlands;
4. Analysis of the Froom Creek floodplain,history of flooding, how the project would attempt to
control this flooding (including back-flooding), and what possible impacts (such as interruption
of groundwater flows) might occur as a result(see specific requests in the discussion about
Froom Creek above);
5. Specific analysis of the surface and groundwater flow regimes supporting the stands of
Chorro Creek hog thistle on the plateau, what the impact of development there would be, and
how such impacts would be mitigated;
6. Impact of the residential development at the storage area, and consideration of alternatives;
7. Impact of the relocation of the detention basins on wildlife use of the basins and their
functioning as wildlife habitat;
8. Propriety of including lands already conserved as part of the conservation("open space")
portion of the project.
Thank you for the opportunity to comment on this NOP.
Sincerely,
�' ' ��,���
��
Neil Havlik, PhD.
California Native Plant Society, San Luis Obispo County Chapter
672 Serrano Drive#11
San Luis Obispo, CA. 93405
805-781-9624
neilhavlik@aol.com
14781
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August 14, 2017
Emily Creel
Contract Planner and City Project Manager
SWCA
Shawna Scott
Associate Planner(Staff Liaison)
City of San Luis Obispo
RE: Froom Ranch Specific Plan Environmental Impact Report(Notice of Preparation)
Dear Ms. Creel and Ms. Scott:
This letter submits comments from the San Luis Obispo Council of Governments (SLOCOG) related to the
scope of the Environmental Impact Report (EIR)to be prepared for the subject project.
Many comments reference SLOCOG's 2014 Regional Transportation Plan and Sustainable Communities
Strategy(2014 RTP-SCS). A link to this document, along with project references, is included at the end of
this letter.
Land Use/Planning
1. The site is not within an adopted Target Development Area of the 2014 RTP-SCS(p. 2-18).
2. The 2014 RTP-SCS's Sustainable Communities Strategy(SCS, Ch. 2) includes policies that
support, among other things, reducing vehicle miles traveled (VMT) and related emissions
(SCS 4); compact, mixed-use, and infill development in Target Development Areas (SCS 5);
equitable, affordable housing (SCS 7); and protection of important farmland and valuable
habitats (SCS 14 and 15).These policies are related to CEQA impacts, including agricultural
resources, biological resources,transportation/traffic, climate change, and population and
housing.
Population/Housing
3. SLOCOG's 2050 Regional Growth Forecast(2017)found that San Luis Obispo County's
housing market is the tenth-least affordable market in the country, and fourth-least
affordable small market in 2016 Q4 (National Association of Home Builders/Wells Fargo
Housing Opportunity Index [HOI]). Based on the HOI, only 21.1 percent of family households
could afford a median-priced home in the region in 2016 Q4 (see Figure 31, page 62).The
2014 RTP/SCS's Sustainable Communities Strategy includes policy language that is
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supportive of equitable, affordable housing... for people of all ages, incomes, races and
ethnicities to increase mobility and lower the combined cost of housing and transportation
(SCS 7).
The EIR should consider the potential impacts of not accommodating deed-restricted
affordable housing as part of the project. Not accommodating very low-, low-, and
moderate-income households may result in increased regional traffic congestion from
intercity commutes and an associated increase in vehicle-generated greenhouse gas
emissions.
Transportation/Traffic
US 101
4. The 2014 RTP-SCS (Figure 4-3, p. 4-11) projects the following LOS for US 101 between South
Higuera and Monterey:
a. 2010 peak hour: LOS F
b. 2035 PM peak hour: LOS F
The EIR should consider these projections as it evaluates the project's impacts to freeway
LOS.
Prado Road
5. The 2014 RTP-SCS recommends construction of an overcrossing and interchange at Prado
Rd. (see "References" section at the end of this letter). The EIR should analyze the project
trip contribution to the anticipated Prado Rd. overcrossing and US 101-Prado Rd.
northbound ramp improvements discussed in the San Luis Ranch EIR (now certified) and
potential mitigations.
Senior transportation
6. The EIR should assess the availability of senior shuttle services, fixed-route bus service, and
other transportation services for seniors. It should consider a senior shuttle service or
contribution to existing senior shuttle services that would provide transportation from the
project to services in San Luis Obispo.
Transportation demand management
7. The EIR should consider transportation demand management (TDM), including
encouragement and education about non-single-occupancy-vehicle travel modes, as a
potential mitigation measure.
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SLOCOG's 2014 RTP-SCS MSE Policy 3 states: "Assist local jurisdictions in developing communities in
ways that reduce the demand on the roadway system by coordinating residential, commercial and
industrial development in ways that reduce the need to drive".
Multi-modal access
8. The number of internal capture trips assumed in the multimodal transportation study's trip
generation calculations will affect the projected net external auto trips into and out of the
site. In addition to internal capture, given the substantial amount of retail in the vicinity,the
potential for some external trips to be walking and cycling should be studied. Residents may
be more likely to make those trips if the development's layout, sidewalks, and bike facilities
offer convenient, safe, and low-stress connections to the adjoining retail.
9. The EIR should include a consideration of how potential connections to existing and
proposed future sections of the Bob Jones Trail affect the proposed development's traffic
impacts and possible mitigations. For example,the City is in the preliminary engineering
phase of two trail segments: the Oceannaire-to-Calle Joaquin/Prefumo Creek Connector
and the Los Osos Valley Rd.-to-Octagon Barn segment. Currently, Class II bike lanes exist on
Los Osos Valley Rd. between the proposed project site and the expected intersection of the
LOVR-Octagon Barn segment. The City will be making bike lane and bike-vehicle conflict
area striping upgrades as part of its repaving project, underway at the time of this writing.
San Luis Obispo County will soon commence the plans, specifications, and estimate (PS&E)
phase for the County segment between Octagon Barn and the existing trailhead on Ontario
Road. Taken together,these segments, once built,will fulfill a vision of having a bikeway
from the City of San Luis Obispo to the Pacific Ocean that is almost completely separated
from motor vehicle traffic.
10. Assess the impacts of potential use of existing and proposed open space in the vicinity of
the development, including the potential need for a public parking lot/staging area to
enhance access to trails.
Please let me know if you have any questions or need more information: 788-2104 or
jbrubaker@sloco�.or�.
Sincerely,
Jeff Brubaker,AICP
Transportation Planner
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References
SLOCOG 2014 Regional Transportation Plan and Sustainable Communities Strategy(2014 RTP-SCS)
http://www.sloco�connectin�communities.com/
SLOCOG 2050 Regional Growth Forecast
http://www.sloco�.or�/pro�rams/data-services/re�ional-�rowth-forecast
2014 RTP-SCS proiect references
Froom Ranch Way, Bob Jones Trail: Prefumo Creek Connection
1. CEN-RORS-1013: Froom Ranch Way extension: end of Froom Ranch Way to Dalidio Dr.
2. CEN-AT1-1014: Bob Jones Trail: Prefumo Creek bike path connector [Madonna Rd. to US
101]
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�"�"T°�'�F, United States Department of the Interior ����
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� FISH AND WILDLIFE SERVICE
Ventura Fish and Wildlife Office
�''4�►r 3+�"� 2493 Portola Road,Suite B �.,..
Ventura,California 93003
IN REPLY REFER TO:
08E V EN00-2017-C PA-0183
August 14, 2017
Shawna Scott,Associate Planner
Community Development Department
City of San Luis Obispo
919 Palm Street
San Luis Obispo, California 93401
Subject: Notice of Preparation of a Draft Environmental Impact Report for the Froom
Ranch Specific Plan Project, San Luis Obispo County, California
Dear Ms. Scott:
This letter provides the U.S. Fish and Wildlife Service's(Service) comments on the Notice of
Preparation(NOP)regarding the Draft Environmental Impact Report(DEIR)for the subject
project area located within unincorporated San Luis Obispo County immediately west of Los
Osos Valley Road between U.S. 101 and the Irish Hills Plaza. The 110-acre project includes a
Specific Plan, General Plan Amendment, and related actions that would allow for the
development of the Froom Ranch Specific Plan Area(SPA) identified in the City of San Luis
Obispo's General Plan. Completion of a Specific Plan is necessary before the project area can be
annexed into the City of San Luis Obispo. Project elements would consist primarily of residential
uses with some commercial development adjacent to Los Osos Valley Road and the existing
Irish Hills Plaza.
The Service's responsibilities include administering the Endangered Species Act of 1973, as
amended (Act), including sections 7, 9, and 10. Section 9 of the Act and its implementing
regulations prohibit the taking of any federally listed endangered or threatened species. Section
3(19) of the Act defines"take"to mean"to harass,hann,pursue,hunt, shoot,wound,kill,trap,
capture,or collect,or to attempt to engage in any such conduct." Hann is further defined by the
Service to include significant habitat modification or degradationthat results in death or injury to
listed species by significantly impairing essential behavioral patterns, including breeding,
feeding, or sheltering. Harass is defined by the Service as intentional or negligent actions that
create the likelihood of injury to a listed species by annoying it to such an extent as to
significantly disrupt normal behavioral patterns which include,but are not limited to, breeding,
feeding, or sheltering. The Act provides for civil and criminal penalties for the unlawful taking
of listed species. Exemptions to the prohibitions against take may be obtained through
coordination with the Service in two ways. If a project is to be funded, authorized, or carried out
by a Federal agency, and may affect a listed species,the Federal agency must consult with the
Service pursuant to section 7(a)(2) of the Act. If a proposed project does not involve a Federal
14787
Shawna Scott 2
agency but may result in take of a listed animal species, the project proponent should apply to the
Service for an incidental take permit pursuant to section 10(a)(1)(B) of the Act.
According to the NOP, the DEIR will identify and evaluate potentially significant impacts,
whether direct or indirect,that may result from Project implementation. It will also determine
whether mitigation measures and/or alternatives can be implemented that would mitigate such
impacts to a level that is less than significant. The NOP identifies a number of environmental
issues that will be analyzed in the DEIR, one of which is biological resources. Of particular
concern to us is the presence of Chorro Creek bog thistle (aka Chorro Creek fountain thistle;
Cirsium fontinale var. obispoense), a federally-listed endangered plant, which has been
documented to occur onsite. We request an alternative that avoids impacts to this edaphic
endemic species and its necessary hydrology be considered in the DEIR.
Also of concern to us is the possibility of presence of two federally-listed threatened animal
species: California red-legged frog (Rana draytonii) and vernal pool fairy shrimp (Branchinecta
lynchi). We reviewed the evaluation for these species provided in the biological resource report
prepared for the proposed project(KMA 2016) but currently do not concur with its conclusion
that presence of either of these species is not likely. The data for vernal pool fairy shrimp is from
over 10 years ago and California red-legged frogs may use the ephemeral features identified as
drainages 1, 2, and 3 (KMA 2016) as well as Froom Creek for some portion of their life cycle.
Because there may be habitat suitable to support one or both of these species within the project
area habitat assessments for each, conducted in accordance with current Service guidance, should
be prepared for inclusion as appendices to the biological resources section of the DEIR.
We appreciate the opportunity to provide comments on the NOP for the Froom Ranch Specific
Plan Project DEIR and look forward to receiving the draft document, inclusive of all relevant
technical appendices and reports, during the public review period. If you have any questions
regarding our response to the NOP, please contact Julie M. Vanderwier of my staff at(805) 677-
3400 or at julie_vanderwier@fws.gov.
Sincerely,
1- / " !� '
�
�`� tephen P. Henry
�
Field Supervisor
cc:
Brandon Sanderson, California Department of Fish and Wildlife
Reference Cited
KMA. 2016. Froom Ranch Project, San Luis Obispo County California. Biological Resources
Inventory prepared for John Madonna Construction, Inc. January
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