HomeMy WebLinkAboutFrench Hospital Expansion_Phase 2_FEIR_7-2-22July 2, 2022
Rachel Cohen
City of San Luis Obispo
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401-3218
Re: French Hospital Expansion Project Environmental and Planning Services – Change Order Request No. 1
Phase 2) SWCA Project No. P65351
Dear Ms. Cohen:
SWCA Environmental Consultants (SWCA) appreciates the opportunity to submit our proposal to provide additional
environmental and planning services in compliance with the California Environmental Quality Act (CEQA) for the
proposed French Hospital Expansion Project (project) in the city of San Luis Obispo. The attached proposed scope of
work was developed based on our conversations with City of San Luis Obispo (City) staff, as well as our experience
preparing the Draft Initial Study/Mitigated Negative Declaration (IS/MND) for the project, including receipt and review
of public comments received on the IS/MND.
Based on our correspondence with City staff and the project applicant team, it is our understanding that the City is
evaluating whether preparation of a Focused Environmental Impact Report (FEIR) is necessary to respond to the
comments raised and avoid a fair argument standard of legal review for the project environmental analysis. If the
project moves forward with an FEIR, we anticipate that key issue areas would include Aesthetics, Air
Quality/Greenhouse Gas Emissions, Biological Resources, Energy, Noise, and Transportation. The FEIR would also
include a more brief summary of environmental impact areas with potentially significant but mitigable effects
associated with Cultural and Tribal Cultural Resources, Hazards and Hazardous Materials, Hydrology and Water
Quality, Land Use and Planning, and Utilities and Service Systems. All other issue areas are anticipated to be
screened out in the Notice of Preparation (NOP) circulated for the FEIR.
In addition to preparation of additional CEQA documentation as necessary, this proposal also includes contract
planning support and project management (as an extension of City staff) through the remainder of the planning and
public meeting process as an optional task. We have assumed the project would require presentations at the Planning
Commission and City Council. Our proposed costs include adjustments based on the prior work completed in
anticipation of the previously scheduled Planning Commission meeting.
The cost to complete these tasks, as described in the attached scope of work, not including optional tasks, is a time-
and-materials not to exceed (NTE) total of $76,849.00. Thank you for providing us with the opportunity to work with
you. Should you have any questions regarding our scope of work or cost estimate, please feel free to contact me at
805) 539-2870 or ecreel@swca.com.
Sincerely,
Emily Creel Cassidy Williams
Principal Planning Team Lead Assistant Project Manager
French Hospital Expansion Project Environmental and Planning Services – Change Order
Request No. 1 (Phase 2)
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SCOPE OF WORK
The following scope of work provides a description of the planning and environmental support services that SWCA
Environmental Consultants (SWCA) will provide to the City of San Luis Obispo (City) for the proposed development of
the French Hospital Expansion Project (project).
Based on our conversations with City staff and the project applicant team, it is our understanding that the City may elect to
have a Focused EIR (FEIR) prepared to respond to the comments raised and avoid a fair argument standard of legal
review for the project environmental analysis.
PHASE 2: FOCUSED EIR PREPARATION AND PUBLIC MEETING SUPPORT
TASK 2.1: PROJECT MANAGEMENT
SWCA project management will include general management of the environmental project team, as well as
coordination/correspondence with the City and the project applicant team, as deemed appropriate by the City. SWCA
Assistant Project Manager Cassidy Williams will serve as the primary contact and project manager for the proposed
project with support from Project Manager Emily Creel.
Our management of the project will include planning support as an extension of staff, including consultation with City
departments as needed to inform the scope and analysis of the FEIR and public meeting staff reports, responding to
public inquiries, and leading regular status meetings (e.g., weekly, bi-weekly, or monthly, depending on the status of the
project) to be scheduled in coordination with the City and project applicant team, as appropriate. SWCA will prepare
agendas and/or meeting minutes for project status meetings at the request of City staff. Project management activities will
also include preparation of a project schedule and regular updates to the project team related to the schedule.
TASK 2.2: PREPARATION OF THE INITIAL STUDY/NOTICE OF PREPARATION
SWCA will prepare an Initial Study/Notice of Preparation (IS/NOP), based largely off of the previous IS/MND, that
identifies key issue areas to be evaluated in the FEIR and screens out environmental issues that do not require further
analysis in the FEIR. We anticipate the following issue areas will be screened out in the IS/NOP: Agriculture, Geology &
Soils, Mineral Resources, Population and Housing, Public Services, Recreation, and Wildfire. The IS/NOP will be provided
to the City in electronic format for review and approval. This task includes two rounds of review by the City.
TASK 2.3: PREPARATION OF THE ADMINISTRATIVE DRAFT FEIR
SWCA, in conjunction with its subconsultants Robert G. Carr, RLA (Visual Specialist), and AMBIENT Air Quality & Noise
Consulting (AQ/GHG, Energy, and Noise Specialist), will prepare an Administrative Draft FEIR (Admin Draft FEIR) in a
format approved by the City. The Admin Draft FEIR will include the following sections:
Executive Summary
Introduction
Project Description
Environmental Setting
Environmental Impact Analysis
o Aesthetics
o Air Quality and GHG Emissions
o Biological Resources
o Energy
o Noise
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Request No. 1 (Phase 2)
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o Transportation
o Other Issue Areas (with mitigation)
Cultural Resources / Tribal Cultural Resources
Hazards and Hazardous Materials
Hydrology and Water Quality
Land Use and Planning
Utilities and Service Systems
Alternatives
Other CEQA Considerations
Mitigation Monitoring and Reporting Plan
References and Report Preparers
Preparation of the Admin Draft FEIR will include graphics prepared by GIS Specialist Sarah Halpern and would be
formatted and edited by Technical Editor Jaimie Jones. The Admin Draft FEIR will reflect the highest internal quality
control standards, to streamline City reviews and reduce the need for revisions.
Technical studies that were prepared to support the project IS/MND would be used to support the environmental impact
analysis of the Admin Draft FEIR, as described below.
Aesthetics / Visual Resources
A Visual Impact Assessment (VIA) was prepared by Robert G. Carr, RLA (Visual Specialist) to support the preparation of
the project IS/MND. This assessment analyzed potential visual impacts that would result from the project, including, but
not limited to, evaluation of the aggregate effect that the project may have on the overall visual character of the project
site and surrounding landscape, consistency with applicable City planning policies and regulations, and exposure of
viewers from public areas or residences to new point-source lighting visibility and nighttime light spill-over. The analysis
presented in this report is comprehensive and is not anticipated to require any substantial changes for incorporation into
the Admin Draft FEIR. SWCA would prepare the Aesthetics section of the Admin Draft FEIR with support from Robert G.
Carr based on the analysis presented in the previously prepared VIA.
Air Quality / Greenhouse Gas Emissions
An Air Quality and Greenhouse Gas Impact Assessment and a CAP Consistency Analysis Memorandum were prepared
by AMBIENT Air Quality and Noise Consulting to support the preparation of the project IS/MND. The Air Quality and
Greenhouse Gas Impact Assessment provided a summary of existing conditions in the project area and the applicable
regulatory framework pertaining to air quality and climate change and a quantitative analysis of air quality and greenhouse
gas impacts associated with the project using the California Emissions Estimator Model (CalEEMod) version 2020.4.0.
The CAP Consistency Memorandum provided a subsequent analysis of the project’s greenhouse gas impacts to reflect
the revised CAP Consistency Checklist prepared by the project applicant. The analysis presented in these documents is
comprehensive and is not anticipated to require any substantial changes for incorporation into the Admin Draft FEIR.
SWCA would prepare the Air Quality/Greenhouse Gas Emissions section of the Admin Draft FEIR with support from
AMBIENT Air Quality and Noise Consulting based on the analysis presented in the previously prepared Air Quality and
Greenhouse Gas Impact Assessment and CAP Consistency Memorandum.
Biological Resources
A Biological Resources Assessment was prepared by David Wolff Environmental to support the project application for a
Conditional Use Permit and was used to support the preparation of the project IS/MND. The Biological Resources
Assessment is technically sound and will be used to support the FEIR. However, the assessment did not include several
components that are commonly included in EIRs, such as a comprehensive analysis of potential impacts to sensitive
species known to occur in the region (e.g., monarch butterflies, etc.), jurisdictional features mapping, a botanical survey,
or a mitigation plan. Therefore, our scope includes preparation of an information request, in conjunction with other
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Request No. 1 (Phase 2)
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information needs, for supplemental biological resources information. We assume that this additional supporting
information will be provided by the applicant team so that these components can be included to supplement the analysis
provided in the previously prepared Biological Resources Assessment. SWCA would prepare the Biological Resources
section of the Admin Draft FEIR based on the Biological Resources Assessment and supplemental information provided
by the applicant team with support from SWCA Senior Biologist Travis Belt.
Energy
An Energy Impact Assessment was prepared by AMBIENT Air Quality and Noise Consulting to support the preparation of
the project IS/MND. This assessment provided a summary of existing conditions in the project area and the applicable
regulatory framework pertaining to energy and an analysis of the potential energy impacts associated with the project,
including a quantitative assessment of project energy use using CalEEMod version 2020.4.0. The analysis presented in
this assessment is comprehensive and is not anticipated to require any substantial changes for incorporation into the
Admin Draft FEIR. SWCA would prepare the Air Quality/Greenhouse Gas Emissions section of the Admin Draft FEIR with
support from AMBIENT Air Quality and Noise Consulting based on the analysis presented in the previously prepared
Energy Impact Assessment.
Noise Impact Assessment
An Acoustic Assessment was prepared by 45dB Acoustics to support the project application for a Conditional Use Permit
and was used to support the preparation of a Noise Impact Assessment prepared by AMBIENT Air Quality and Noise
Consulting and the project IS/MND. The Acoustic Assessment prepared by 45dB Acoustics provided an analysis of
potential noise impacts associated with the project based on long-term continuous noise levels. The Acoustic Assessment
prepared for the project did not include an evaluation of short-term/instantaneous noise associated with helicopter
operations and the consultant that prepared the noise analysis is no longer in business. At the request of the City, SWCA
utilized the 45dB Acoustics report to support a qualitative noise assessment of short-term/instantaneous noise impacts in
the Noise Impact Assessment and project IS/MND.
Based on public comments received on the project IS/MND, SWCA recommends that additional noise modeling be
conducted to support a quantified noise analysis in the FEIR. Our scope includes remodeling of helicopter noise levels in
order to adequately address short-term/instantaneous noise impacts associated with helicopter operations. Additional
noise measurement surveys will also be required to document existing short-term/instantaneous noise levels associated
with nearby railroad operations. This analysis will also include measuring of onsite stationary source noise levels and
additional ambient noise measurement surveys.
Information needed to complete the remodeling of helicopter noise levels would include, but not be limited to, details
regarding the potential helicopter models that would use the proposed helistop, anticipated flight frequencies, and details
regarding the proposed landing and takeoff flight paths. Our scope includes preparation of an information request in
conjunction with other information needs for this information. The results of the noise modeling would be provided in a
stand-alone revised Noise Impact Assessment and would be incorporated into the preparation of the Noise section of the
Admin Draft FEIR. SWCA would provide one electronic copy of the Draft Noise Impact Assessment in Microsoft (MS)
Word format and assumes one round of review by City staff.
Transportation
A Focused Multimodal Transportation Analysis and Vehicle Miles Assessment Memorandum (VMT Memorandum) were
prepared by Michael Baker International to support the project application for a Conditional Use Permit and were used to
support the preparation of the project IS/MND. The Focused Multimodal Transportation Analysis provided an analysis of
the projected traffic conditions associated with the project and its associated impacts on existing and projected operations
of proximate vehicle, bicycle, and pedestrian infrastructure. The VMT Memorandum provided an assessment of project-
level vehicle miles travelled and the project’s overall impact on regional vehicle miles travelled levels.
Based on the evaluation of the project using the City’s Travel Demand Model, the project would exceed the City’s VMT
significance threshold of 17.43 VMT per service population. Mitigation measures were identified in the project IS/MND in
French Hospital Expansion Project Environmental and Planning Services – Change Order
Request No. 1 (Phase 2)
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coordination with the City Transportation Division to implement on-site traffic demand management measures as well as
off-site improvements, such as funding pedestrian/bicycle/transit infrastructure improvements or increasing transit service
frequency to and from the hospital through either private shuttle service or working with SLO Transit to increase their
service frequencies. Our scope includes consultation with the City Transportation Division as needed to verify/modify this
approach and incorporation of the analysis provided in the previously prepared Focused Multimodal Transportation
Analysis and VMT Memorandum into the Transportation section of the Admin Draft FEIR. If, after consultation with the
City’s Transportation Division, additional technical analysis is warranted, we assume it would be provided by the applicant
team.
TASK 2.4: PREPARATION OF THE DRAFT FEIR AND NOTICES
SWCA will incorporate all comments and edits to the Admin Draft FEIR received from the City and assumes two rounds of
review for completion of this task. SWCA will make changes to the Admin Draft FEIR using the track changes option in
MS Word to allow changes to be easily identified. We assume the City will compile their comments on the Admin Draft
FEIR and submit a single comment document to SWCA. The revised Draft FEIR will be submitted electronically to the City
in MS Word format for review and approval of the proposed changes. A conference call or in-person meeting with the City
may be scheduled to discuss the changes to the document, if necessary. At the time of submittal of the Draft FEIR, SWCA
will prepare a Mitigation Monitoring and Reporting Plan that details all applicable mitigation measures, their associated
compliance methods, timing, and responsible party.
Once the City has approved the changes or submitted additional comments, SWCA will finalize the document and prepare
the Draft FEIR for public distribution. An electronic version of the Draft FEIR in MS Word and pdf will be provided to the
City for final review prior to distributing it to the public. SWCA will prepare the draft Notice of Availability (NOA) and we
assume the City will arrange publishing of the NOA in the newspaper. SWCA will also prepare the California State
Clearinghouse Summary Form and draft Notice of Completion. SWCA assumes the City will file the Draft FEIR and
appropriate notices with the State Clearinghouse. If requested by the City, SWCA can assist with filing the Draft FEIR and
appropriate notices with the State Clearinghouse under assignment by the City.
TASK 2.5: RESPONSE TO COMMENTS AND FINAL FEIR
After the close of the 45-day public comment period on the Draft FEIR, SWCA will prepare responses to written comments
received on the Draft FEIR.
Based on the nature of the proposed project, the project’s history, and previous project controversy, SWCA anticipates
substantial interest in the project, including, at minimum, from the law firms representing labor union organizations that
previously provided comments on the IS/MND. SWCA’s budget includes responding to up to 50 individually substantive
comments and master responses would be considered one comment. Responses to comments will clearly identify any
necessary clarifications that are made in the Final FEIR, to allow for easy cross-referencing by staff, reviewing agencies,
the public, and County decision makers. A draft of the Response to Comments Chapter will be provided to the City for
review and approval. We assume no major revisions to the Draft FEIR will be required and changes important to the
analysis of content of the FEIR will be tracked to allow for easy identification by the reader.
SWCA will incorporate any necessary clarifications and edits and prepare a Final FEIR, CEQA Findings, and Notice of
Determination (NOD). SWCA will provide one electronic copy of the Final FEIR and the NOD to the City for review and
approval. SWCA assumes the City will be responsible for posting the final NOD with the County Clerk, including payment
of the CDFW Environmental Filing Fee.
TASK 2.6: PLANNING COMMISSION MEETING SUPPORT
SWCA will revise and update, as necessary, the previously prepared draft staff report package for review of the project
during a Planning Commission meeting, which will comprise the staff report, graphics, and findings and conditions of
approval. The staff report will include a brief overview of the history of the project, a description of the proposed
development, and a preliminary evaluation of the project’s consistency with the City General Plan. SWCA assumes two
French Hospital Expansion Project Environmental and Planning Services – Change Order
Request No. 1 (Phase 2)
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rounds of review for this task and will coordinate with the City on preparation and review timelines based on the current
Planning Commission meeting milestone deadline matrices. All documents would be provided electronically.
SWCA will prepare an MS PowerPoint presentation to be presented at the meeting using the Planning Commission
meeting presentation template. This presentation would include, but not be limited to, a brief overview of the project
history, description of the proposed project, summary of the environmental review of the project, and preliminary
evaluation of the project’s consistency with the City General Plan. SWCA assumes one round of review to allow City staff
to provide comments and suggestions for revisions to the presentation prior to the Planning Commission meeting. The
SWCA project team will also review agenda correspondence and be prepared to modify the presentation and/or
information presented at the Planning Commission meeting accordingly.
Assistant Project Manager Cassidy Williams will attend one Planning Commission practice session and the Planning
Commission meeting at which the project would be reviewed. We will present the project to the Planning Commission and
be available to respond to any questions received from Planning Commission, local agencies, and/or members of the
public.
TASK 2.7: CITY COUNCIL MEETING SUPPORT
SWCA will prepare a staff report package for review and final decision on the project during a City Council meeting, which
will comprise the staff report, graphics, findings, and conditions of approval. The staff report will include a brief overview of
the history of the project, a description of the proposed development, and a summary of previous review by the City’s
Architecture Review Commission, Tree Committee, and Planning Commission. SWCA assumes two rounds of review for
this task and will coordinate with the City on preparation and review timelines based on the current City Council meeting
milestone deadline matrices. All documents would be provided electronically.
SWCA will prepare an MS PowerPoint presentation to be presented at the meeting using the City Council meeting
presentation template. SWCA assumes one round of review of the presentation to allow City staff to provide comments
and suggestions for revisions to the presentation prior to the City Council meeting. The SWCA project team will also
review agenda correspondence and be prepared to modify the presentation and/or information presented at the City
Council meeting accordingly.
Assistant Project Manager Cassidy Williams will attend one City Council practice session and the City Council meeting at
which the project would be reviewed. We will present the project to the City Council and be available to respond to any
questions received from the City Council, local agencies, and/or members of the public.
Cost to complete Phase 2: $76,849
PHASE 3: OPTIONAL TASKS
OPTIONAL TASK 3.1: UPDATED AIR QUALITY AND ENERGY IMPACT ASSESSMENT
Since the preparation of the Air Quality and Greenhouse Gas Emissions Impact Assessment and the Energy Impact
Assessment for the project in 2021, a new version of the California Emissions Estimator Model (CalEEMod) has been
made available to the public. As an optional task upon request by the City, and in order to ensure that the FEIR uses the
most accurate and up to date information, SWCA would update the emissions and energy use modeling prepared for the
project using the recently approved CalEEMod, version 2022, computer program. This model incorporates updated
emission factors and modeling assumptions that are anticipated to result in overall reductions in emissions, when
compared to the modeling previously conducted. There is currently some uncertainty about the immediate availability of
the updated model to be utilized in new projects, as the California Air Pollution Control Officers Association (CAPCOA)
continues to troubleshoot issues with the model raised since it was made public in May 2022. SWCA will continue to
consult with the San Luis Obispo County Air Pollution Control District (APCD) regarding the need and/or ability to update
the AQ/GHG modeling for the project.
French Hospital Expansion Project Environmental and Planning Services – Change Order
Request No. 1 (Phase 2)
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OPTIONAL TASK 3.2: ADDITIONAL RESPONSES TO COMMENTS
If more than 50 substantive comments are received on the Draft FEIR, SWCA has included this optional task to respond
to an additional 50 substantive comments. Responses to comments will clearly identify any necessary clarifications that
are made in the Final FEIR, to allow for easy cross-referencing by staff, reviewing agencies, the public, and County
decision makers.
SCHEDULE
SWCA is prepared to initiate this scope of work immediately after receiving a signed contract. Table 1 sets out anticipated
and general timeframes for completion for Phase 2 of this scope of work (Focused EIR Preparation and Public Meeting
Support). Note that these timeframes are just estimates; we are willing to commit to the overall project schedule
developed by the City and will provide environmental documentation within the timeframes necessary to maintain the
overall project schedule to the extent feasible.
Table 1. Scope of Work Schedule – Phase 2: Focused EIR Preparation and Public Meeting Support
TASK ESTIMATED COMPLETION PERIOD
Task 2.1: Project Management Ongoing throughout duration of project
Task 2.2: Preparation of the IS/NOP Within 2 weeks following project kickoff
City Review of the IS/NOP 2 weeks
SWCA Finalization of the IS/NOP 1 week following receipt of City comments
IS/NOP Circulation Period 30 days
Task 2.3: Preparation of the Admin Draft FEIR Within 60 days of the close of the IS/NOP circulation period
City review of the Admin Draft FEIR 4 weeks
Task 2.4: Preparation of the Draft FEIR and Notices Within 2 weeks following receipt of City comments
Draft FEIR Circulation Period 45 days
Task 2.5: Response to Comments and Final FEIR Within 4 weeks of close of Draft FEIR circulation period
Task 2.6: Planning Commission Meeting Support TBD – based on City PC Meeting Matrices
Task 2.7: City Council Meeting Support TBD – Based on City CC Meeting Matrices
TOTAL Approximately 9-10 months
COST ESTIMATE
Based on thoughtful consideration of the project requirements, and a thorough estimate of the attendant labor and direct
costs, SWCA’s estimate for completion of the scope of work described above (not including the optional tasks) is a time-
and-materials cost not-to-exceed (NTE) $76,849.00. This total is based on the following subtotals, by task.
SWCA will not proceed with any work in excess of the NTE budget without prior authorization to proceed. The budget
shown in Table 2 identifies the cost proposed by task for this project.
Table 2. Scope of Work Cost Estimate
PHASE 2: FEIR PREPARATION AND PUBLIC MEETING SUPPORT
Task 2.1: Project Management $6,064
Task 2.2: Preparation of the IS/NOP $2,808
Task 2.3: Preparation of the Admin Draft FEIR $46,209
Task 2.4: Preparation of the Draft FEIR and Notices $5,226
French Hospital Expansion Project Environmental and Planning Services – Change Order
Request No. 1 (Phase 2)
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PHASE 2: FEIR PREPARATION AND PUBLIC MEETING SUPPORT
Task 2.5: Response to Comments and Final FEIR $12,258
Task 2.6: Planning Commission Meeting Support $1,896
Task 2.7: City Council Meeting Support $2,388
PROJECT TOTAL (NOT INCLUDING OPTIONAL TASKS) $76,849
PHASE 3: OPTIONAL TASKS
Optional Task 3.1: Updated Air Quality and Energy Impact Assessment $11,292
Optional Task 3.2: Additional Responses to Comments $8,040
ASSUMPTIONS
The project description is final and will not undergo any major changes.
A scoping meeting will not be necessary.
All documents will be provided in electronic format; hard copies will not be necessary.
The City will be responsible for necessary public circulation tasks such as newspaper advertisement listing, filing
the NOD with the County Clerk (including payment of the CDFW Environmental Filing Fee), and noticing public
meetings per the City’s standard noticing practices.
WORK AUTHORIZATION
All terms and conditions of the Agreement between the City of San Luis Obispo and SWCA Environmental Consultants
March 15, 2022) and related Attachments are incorporated herein by reference. By signing below, SWCA agrees to
complete the scope of work identified above and the City agrees to pay all associated costs pursuant to the payment
terms set forth in the Contract.
Tyler Corey, Deputy Director of Community Development
City of San Luis Obispo
Date
7/7/2022