HomeMy WebLinkAboutApplicant Responses to Completeness Letter 11-10-22November 10, 2022
Rachel Cohen Senior Planner
City of San Luis Obispo
Community Development Department
Subject: SPEC-0451-2022, GENP-0449-2022, & EID-0450-2022: Review of “The Link”
which includes various entitlements (Annexation, General Plan Amendment, a
Specific Plan , etc.) for a project with 725 multifamily attached units, 69,150 square
feet of retail mixed use space, 279,700 square feet of professional and medical
office uses, 209,000 square feet of industrial and warehouse space, and 237,200
square feet of mixed service commercial uses.
Thank you for your timely review of the initial Project Description and initial application
materials for The Link project (nee’ “Chevron Project”). We have followed up on a number
of the questions and comments raised by staff and offer the comments to specific questions.
Several of the comments have served to refine the project description and focus future study
and program elements. Many of the items requested are still under development.
This correspondence is intended as a status report and acknowledgement of the scope and
timing of the requested materials.
Sincerely,
Damien Mavis
Covelop, Inc. (Project Applicant)
dmavis@covelop.met
Responses to Department comments/completeness items:
Planning Division - Community Development Department
1. Please submit applications, associated material, and application fees for the
annexation, subdivision, and ALUP review required for the project.
Response: The subdivision map and associated engineering analysis are being
prepared and will be submitted by separate application at a later date. The
annexation application will be submitted upon completion of the Final EIR.
Finally, the ALUP application requires the submittal of the Draft EIR. The
conformity analysis for the ALUP is contained in the conformity determinations
provided in the application and adequately demonstrates that the project is in
conformance with the ALUP, as recently amended.
2. It is unclear how much architectural detail is to be addressed in the project. Will the
project utilize design guidelines within the AASP or create its own? As more
information becomes available, staff will be able to provide feedback on whether
Architectural Review is needed and if an additional application is required.
Response: The City has made a determination, after the submittal of the
application, that a Specific Plan is to be prepared for the project. The Specific Plan
will be prepared by the project team which will contain design guidelines for
specific land uses, consistent with the City’s requirements for Specific Plans
contained in the Zoning Ordinance and General Plan. The application only
provides the suggested land use categories for the project. It is anticipated that the
separate Major Development Permit applications will be prepared for the Phase 1
components of the project, once the design guidelines have been established and
the Draft EIR has been prepared. This will enable the Major Development Permits
to include appropriate mitigations and modifications indicated by the
environmental analysis.
Housing Division – Community Development Department
3. Provide a statement indicating how the project will meet its inclusionary housing
requirement, in accordance with San Luis Obispo Municipal Code §17.138 (which was
recently updated).
a. If the project is to use the in-lieu fee option, please provide calculations to
identify the estimated in-lieu fees (this is not recommended).
b. If affordable units are to be provided within the project, please identify the
specific units intended to be dedicated and the specific income levels of each
unit (low-, moderate-income, etc.).
Response: The project will conform to the most recent version of the City’s
Inclusionary Housing Ordinance by providing at least 6 percent of the rental units
no for sale units are proposed), with 3% for low and 3 % for very low income
households. The applicant will meet this requirement through distribution of the
affordable units throughout the various housing sites, or through a contractual
arrangement with a local affordable housing provider on a specific site. The site
will be sized to accommodate the required number of units and the likely density
bonus.
4. Please revise the Plan Data by Area and Building Table to accurately calculate density
allocation by net area (§17.70.110). Please provide a detailed calculation of the density
allocation for each property that includes residential units.
Response: The Plan Data accurately calculates density. It provides, for reference,
the number of units per Net Lot Area, and the number of density units per Zoning
Ordinance Section 17.71.110. Specifically, the Net Lot Area designated in the Plan
Data table excludes area identified in 17.71.110 B1-B4. At present the number of
density units per unit is an estimate since the number and distribution of housing
units has not been established. Once the specific floor plans have been established
for each product type and site, a revised density calculation will be provided in the
Specific Plan and the Major Development Permits. The Plan Data calculations are
provided to demonstrate compliance with City density regulations.
5. Please update the project description to specifically identify any requested standard
housing incentives associated with the proposed development for providing affordable
housing units on-site (§17.140.040).
Response: It is premature to determine any requested housing incentives. In the
aggregate, the project does not qualify for special housing under the City’s Density
Bonus Program identified in 17.140.040 (which specifies a minimum affordability
level of 10 percent). However, it is conceivable that selected sub-areas of the
multifamily housing sites may be provided the project’s affordable housing, and
that those sub-areas or lots will qualify for density bonuses. It is premature to
determine that condition.
6. Please update the project description to clearly distinguish between any proposed
property development exceptions and any proposed concessions or waivers associated
with the proposed density bonus. All concessions or waivers that are requested in
accordance with §17.140.070 (Alternative or Additional Incentives) shall provide
relevant evidence for justification of the concession or waiver requested.
a. Government Code §65915(k)(1) requires that an incentive/concession must
result in an identifiable and actual cost reduction to provide affordable housing.
b. Government Code §65915€(1) states that waivers may only be requested where
a development standard would physically preclude the construction of the
project with the proposed Density Bonus.
Response: It is premature to determine any requested housing incentives. In the
aggregate, the project does not qualify for special housing under the City’s Density Bonus
Program identified in 17.140.040 (which specifies a minimum affordability level of 10
percent). However, it is conceivable that selected sub-areas of the multifamily housing
sites may be provided the project’s affordable housing, and that those sub-areas or lots will
qualify for density bonuses. It is premature to determine that condition.
Engineering Division – Public Works/Community Development Department
7. The submittal should address the drainage provisions of the Airport Area Specific
Plan, the City’s Floodplain Management Regulations, the more contemporary
provisions within the Drainage Design Manual (DDM), and the provisions of the Post
Construction Stormwater Regulations (PCR’s).
Response: The subdivision map and site engineering plans, which will be completed
and submitted at a later date, will demonstrate compliance with the City’s Floodplain
Management Regulations, and the Drainage Design Manual. The analysis will
demonstrate how improvements currently underway are implementing the approved
drainage requirements for the site. The Specific Plan will present the programmatic
elements to be applied to subsequent development permits, and each Major
Development Permit will identify how the uses in that permit comply.
8. The drainage review and submittal documents should recognize the prior drainage
analysis for the previous tentative map approval and Environmental Impact Review
supporting documents. The applicant should be aware and final reports will need to
consider any updates to the previous analysis. A new/updated analysis is being
completed by the County of San Luis Obispo in conjunction with the remediation
grading permitting processes.
Response: Copy that.
Public Works – Transportation Division
9. A comprehensive Multimodal Transportation Impact Study will be required for this
project. Staff is already in coordination with the applicant to initiate preliminary
transportation analysis to identify any critical concerns and help guide the final project
description but note that application cannot be deemed fully complete until these
technical studies have been completed.
Response: Acknowledged and agreed. Preliminary analysis will inform scope of
the final traffic analysis, the intersections to be studied, issues related to compliance
with VMT regulations, and possible project modifications to address potential CEQA
and GP Conformity issues.
10. To help guide the detailed transportation analysis, please be prepared to provide typical
street cross section exhibits for each relevant street identified in the project application:
a. Tank Farm Road (Innovation Way to Area 11 Driveway)
b. Tank Farm Road (Area 11 Driveway to A Street)
c. Tank Farm Road (A Street to Santa Fe Road-West)
d. A Street
e. B Street
f. C Street
g. Santa Fe Road (North of Tank Farm)
h. Santa Fe Road (South of Tank Farm)
i. East-West Internal Street w/ Angled Parking (Through Area #4 R&D District)
City Transportation Manager is available to discuss and provide input on street cross
section elements as needed.
Response: The roadways referenced in a-i above are accurately scaled on the
submitted plans. The cross sections will be provided as part of the subdivision map
submittal, and included in the Specific Plan.
11. Please confirm if construction of Santa Fe Road Bridge over Acacia Creek is assumed
as part of the infrastructure improvements in Phase 1?
Response. No, it is not assumed to be part of any of the project’s phases. It is
expected that there will be a very limited number of trips from the south. The access
to the project properties will be as shown on the development plan. It is expected,
however, that the Phase 1 project plans will provide the layout, alignment and right
of way planning for the extension of Santa Fe across and south of Acacia Creek
south of Tank Farm Road.
Utilities Department
12. Coordination and Communications. In order to effectively coordinate on this
project, Shawna Scott will the primary contact for the Utilities Department:
sscott@slocity.org or 805.781.7176.
Response: Copy that.
13. Preliminary Utility Plans. Regarding the proposed utility plan (Sheets UT-1 and UT-
2):
a. The Airport Area Specific Plan identifies a proposed 12-inch water main
extending the length of Tank Farm (AASP Figure 7-1 Water Distribution
System). Please revise the plans to show extension of the 12-inch water main
along the full property frontage.
Response: The engineering plans will be modified to reflect this sizing
across the western limits of the northeast development area of the site.
b. The Airport Area Specific Plan shows a planned 12-inch water main within
Santa Fe (north of Tank Farm). Please assume that a 12-inch water main will
be required (the final size will depend on further analysis and engineering
calculations).
Response: The engineering plans will be modified to reflect this sizing.
c. Regarding the proposed private 8-inch water main within Local Public Streets
A and B, please coordinate with Utilities to determine how to provide service
with a backflow preventor.
Response: The project has been modified so that all of the streets will be
public streets and the sewer, water and storm drainage mains will be public
and in public streets. Each parcel will be provided service through an
approved later. No private mains are proposed.
d. Please revise the plans to show the extension of the recycled water line along
the full property frontage.
Response: The engineering plans will be modified to reflect this sizing.
e. The Airport Area Specific Plan shows a planned 12-inch sewer main within
Santa Fe (north of Tank Farm). Please assume that a 12-inch water main will
be required (the final size will depend on further analysis and engineering
calculations).
Response: The engineering plans will be modified to reflect this sizing.
f. Please clarify infrastructure phasing; will Phase 1 (west, adjacent to 250 Tank
Farm) connect to public water, sewer, and recycled water in Tank Farm?
Response: Yes.
14. Airport Gravity Sewer Main/Alignment within Santa Fe (South). The conceptual
plans do not appear to show the correct alignment of Santa Fe south of the Tank
Farm/Santa Fe roundabout. The new extension of Santa Fe should shift to the west to
align with the existing roadway, and to accommodate the Airport Gravity Sewer Main.
Response: The engineering plans have been reviewed and there will be no
inconsistency with the Airport Gravity Sewer Main. The engineering plans for the
subdivision will accurately show the facilities proposed by the project and the
eventual connection to the proposed Airport Gravity Sewer Main.
15. Water Supply Analysis.
a. Please submit analysis consistent with AASP Section 7.2 Water: “Individual
development projects shall demonstrate compliance with the City’s Potable
Water Distribution System Operations Master Plan and provide a detailed
engineering assessment of the project’s water demand and an assessment of
the ability of the City’s infrastructure system to handle the project in
question. The scope of the study shall be to the approval of the Public Works
Director and the Utilities Director.” Prior to initiating the analysis, please
provide the consultant’s qualifications and proposed scope of work for
review.
Response: The engineering plans will include this analysis. RRM Design
Group will be completing this Water Supply Feasibility Analysis.
b. Please submit a Water Supply Assessment pursuant to SB 610.
c. The Water Supply Analysis shall evaluate consistency with the City’s
General Plan, including an analysis and conclusion how the proposed General
Plan Amendment and associated implementation of the project will affect
existing and future identified water supply.
Response: A SB 610/WSA will be prepared as part of the technical report
submittals once the land uses and development program are finalized.
16. Wastewater Analysis.
a. Please submit analysis consistent with AASP Policy 7.2.1: “Engineering
Feasibility Study (Wastewater). Before specific project review and approval
of projects the project proponent will submit a detailed engineering
assessment of the project’s wastewater generation and an assessment of the
ability of the City’s infrastructure system to handle the project in question.
The scope of the study shall be to the approval of the Public Works Director
and the Utilities Director.” Prior to initiating the analysis, please provide the
consultant’s qualifications and proposed scope of work for review.
Response: The project will not be part of the AASP. The referenced
policy was included in the AASP to address issues related to the
development of sewer, water and storm drainage systems associated with
the transition of land uses in the County to City land uses. Inclusion of
the additional residential units in the project will require that the
subdivision application include the referenced analysis. RRM Design
Group will be completing this Wastewater Feasibility Analysis.
17. Continued Restoration Water Demand. Regarding the County’s responsibility for
long-term biological restoration and mitigation compliance, will the City have any
water responsibilities related to restoration efforts within the areas designated
Conservation/Open Space?
Response: The current site owner will remain responsible for the restoration
and remediation of the project site, including all irrigation requirements.
18. Hazardous Materials. Please provide all available hazardous materials documents
and reports related to onsite contamination and associated remediation (electronic files
preferred). Please submit Environmental Site Assessment(s), consistent with AASP
Mitigation Measure HAZ-1.2. Please clarify remediation responsibilities in the event
of hazardous material discovery during infrastructure construction.
Response: Please note that the current remediation and restoration of the
site is not a part of this application. The current site owner will remain
responsible for this work as approved in their 2013 FEIR. The project
applicant and the current site owner continue to have conversations to clarify
remediation responsibilities in the event of hazardous material discovery
during infrastructure construction. The project applicant’s commissioned
Phase I Environmental Site Assessment Report is being provided by separate
email.
19. Standard information required for development review (note additional
comments may be generated upon review of the complete entitlement package):
a. Submit a plan that delineates the location of the properties’ proposed water
meters, water service, wastewater collection services, individual PRVs, and
sewer laterals to the points of connection at the water and sewer mains. Water
services cannot cross property line boundaries. Commercial and residential
uses shall be metered separately. Water service meters shall be adequately
sized to serve the proposed project. Provide site map identifying the existing
meter size and service laterals for the proposed project. Demonstrate
compliance with Municipal Code 13.04.130 (Water Meters).
Response: The engineering plans will include this analysis.
b. Please show the proposed utility easements for the proposed private sewer
and water infrastructure that will be outside of the public right of way.
Response: The project has been modified so that no sewer, water or
storm drainage mains will be in private streets, and there will be no
private sewer and water facilities other than service and fire laterals.
c. Please note: The proposed utility infrastructure shall comply with the latest
engineering design standards effective at the time the building permit is
obtained and shall have reasonable alignments needed for maintenance of
public infrastructure.
d. Fire sprinkler info: show size and location of existing water main that is
proposed for the fire sprinkler riser connection.
e. Show all existing wells, leachfields, and private infrastructure and provide a
proposal (and show on plans) if the elements will be demolished, abandoned,
capped, etc.
Response: This information will be provided for each Major
Development Permit and/or building permit application package, as
appropriate. It is premature to provide at this point.
f. Submit a conceptual landscape plan including MAWA and ETWU
calculations. The project’s proposed landscape and irrigation plans must
comply with the City’s Water Efficient Landscape Standards (Municipal
Code 17.70.220) and the City’s Engineering Standards.
Response: This information will be provided in the Water Supply
Assessment, the Specific Plan, and in the individual building permit
packages as appropriate. It is premature to provide at this point.
g. The proposed project shall comply with the City’s Development Standards
for Solid Waste Services. Include the size, capacity, and location of the solid
waste enclosures and bins to serve the project (including trash, recycling, and
organics) consistent with the City’s Solid Waste Enclosure Standards
available here and here). Commercial and residential refuse services shall be
separate unless a letter of agreement between the tenants and a Conditional
Exception Application from the City’s Development Standards for Solid Waste
Services are provided to the City for review. Please show the location of the waste
bins during pickup if different than the location of the proposed enclosures. Contact
San Luis Garbage Company (SLG) and obtain in writing that the proposed
enclosures and collection method meets the SLG requirements. SLG also need to
confirm truck access and clearances needed to reach the trash bins.
Response: This information will be provided in the individual Major
Development Permit and/or building permit packages as appropriate. It is
premature to provide at this point.
h. If commercial uses in the project include food preparation, provisions for
grease interceptors and FOG (fats, oils, and grease) storage within solid waste
enclosure(s) shall be provided with the design. These types of facilities shall
also provide an area inside to wash floor mats, equipment, and trash cans.
The wash area shall be drained to the sanitary sewer.
i. If the proposed use includes food preparation, or any type of process
discharge, a pre-treatment design shall be provided with the site plan, and a
pre-treatment application shall be completed. The pre-treatment application
will need to be coordinated with the building department, and the City’s
Industrial Waste Program Manager.
Response: This information will be provided in the individual Major
Development Permit and/or building permit packages as appropriate. It
is premature to provide at this point.
j. Please specify if a Vesting Map is proposed.
Response: Yes.
Fire Department
20. Hazardous Materials Exposure: Verify that site is being remediated to Residential
contamination standards, not just commercial. There are different thresholds.
Response: The review by the Central Coast Regional Water Quality Control Board
will include a determination of the suitability of the site for residential uses. This
may include ground floor residential uses and/or upper floor-only residential uses.
21. Fire Services: Identify projects fair share of fire services. Will project be included in
Community Facilities District upon annexation?
Response: The City has established a fire facilities fee to assess the fair share of
new fire facilities to development projects. The project will pay the applicable fees
to meet its fair share obligations. The City does not require a CFD to support fire
facilities. A CFD may be used for various maintenance obligations, if the project
involves a fiscal deficit, but that has not been determined at this time.