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Home My WebLink AboutAirportAreaAASPMargaritaArea FPEIR RTC FINAL PROGRAM ENVIRONMENTAL IMPACT REPORT Airport Area and Margarita Area Specific Plans and Related Facilities Master Plans Volumes I and II Prepared by the City of San Luis Obispo, Community Development Department, 990 Palm Street, San Luis Obispo, CA 93401 With assistance from Jones & Stokes, 2600 V Street, Sacramento, CA 95818 State Clearinghouse #2000051062 September 2003 NOTE TO READER This environmental impact report (EIR) has been prepared pursuant to the California Environmental Quality Act (CEQA) (Public Resources Code Sections 21000, et seq.) and the State CEQA Guidelines (Title 14, California Code of Regulations, Chapter 3). An EIR is an informational document that must be considered by every public agency before approval or disapproval of a project. The purpose of an EIR is to provide public agencies and the general public with information about the effects that a proposed project is likely to have on the environment; to provide ways to minimize any adverse effects; and to suggest alternatives to the project. This final EIR comprises the following: # Volume I: Responses to Comments contains a list of persons, organizations, and public agencies commenting on the draft program EIR; the comments and recommendations received on the draft EIR; and the City’s responses to significant environmental issues raised in the review and consultation process. # Volume II: Revisions to the Draft EIR contains the full text of the draft program EIR, with minor changes shown as text that is struck-out (deleted) or underlined (added) in response to comments or for clarification purposes. The content and format of this final EIR meets the requirements of CEQA and the State CEQA Guidelines. VOLUME I: Responses to Comments Final Program Environmental Impact Report for the Airport Area and Margarita Area Specific Plans and Related Facilities Master Plans State Clearinghouse #2000051062 Prepared for: City of San Luis Obispo Community Development Department 990 Palm Street San Luis Obispo, CA 93401 Contact: Mike Draze 805/781-7274 Prepared by: Jones & Stokes 2600 V Street Sacramento, CA 95818-1914 Contact: Maggie Townsley 916/737-3000 September 2003 Jones & Stokes. 2003. Final program environmental impact report for the Airport Area and Margarita Area Specific Plans and related facilities master plans. Volume I: Responses to Comments. State Clearinghouse #2000051062. September. (J&S 97-360.) Sacramento, CA. Prepared for City of San Luis Obispo, CA. Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Table of Contents and Related Facilities Master Plans September 2003 i Contents of Volume I CHAPTER 1. INTRODUCTION............................................................................................1-1 Preface ..............................................................................................................................1-1 Purpose of a Program EIR...............................................................................................1-1 Background......................................................................................................................1-2 Public Review of the Draft EIR.......................................................................................1-2 Public Hearing and Oral Comments....................................................................1-2 Written Comments...............................................................................................1-2 Contents of Volume I: Responses to Comments.............................................................1-2 CHAPTER 2. RESPONSES TO WRITTEN COMMENTS ON THE DRAFT EIR.........2-1 California Regional Water Quality Control Board, Central Coast Region, Roger W. Briggs.............................................................................................................2-3 San Luis Obispo County Department of Planning and Building, Warren Hoag.............2-5 San Luis Obispo County Department of Planning and Building, Bill Robeson..............2-9 County of San Luis Obispo Department of General Services, Klaasje Nairne .............2-11 The Local Agency Formation Commission, Paul Hood................................................2-27 Senn, Charley Senn........................................................................................................2-29 Senn, Charles L. Senn....................................................................................................2-33 Senn, Charles Senn........................................................................................................2-35 Unocal 76, William J. Almas.........................................................................................2-37 Richard W. Ferris...........................................................................................................2-41 Nick Muick....................................................................................................................2-43 Member of the public (D.M.).........................................................................................2-45 Jeanne Anderson............................................................................................................2-47 Jeanne Anderson............................................................................................................2-49 Stella Koch.....................................................................................................................2-51 Judith Jennings...............................................................................................................2-53 Dave Romero.................................................................................................................2-55 Bill Wilson.....................................................................................................................2-57 CHAPTER 3. RESPONSES TO ORAL COMMENTS ON THE DRAFT EIR.................3-1 Summary of Public Hearing.............................................................................................3-1 Public Comments.................................................................................................3-1 Commission Comments.......................................................................................3-2 Table Page 2-1 List of Agencies, Individuals, and Organizations Commenting on the Draft EIR: Airport Area and Margarita Area Specific Plans and Related Facilities Master Plans, 2002..............................................................................2-1 Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Table of Contents and Related Facilities Master Plans September 2003 iii ACRONYMS AND ABBREVIATIONS AASP Airport Area Specific Plan ALUC Airport Land Use Commission ALUP Airport Land Use Plan Caltrans California Department of Transportation CEQA California Environmental Quality Act City City of San Luis Obispo CNEL Community Noise Equivalent Level CO carbon monoxide Commr. Commissioner Corps U.S. Army Corps of Engineers dB decibel EIR environmental impact report ESA Endangered Species Act LAFCO Local Agency Formation Commission MASP Magarita Area Specific Plan NOx oxides of nitrogen PM10 particulate matter 10 microns or less in diameter ROG reactive organic gases SAY safe-annual-yield TPH total petroleum hydrocarbons URL Urban Reserve Line USFWS U.S. Fish and Wildlife Service Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 1. Introduction Related Facilities Master Plans September 2003 1-1 Chapter 1. Introduction PREFACE City of San Luis Obispo (City) prepared and circulated a draft program environmental impact report (EIR) for the Airport Area Specific Plan (AASP) and Margarita Area Specific Plan (MASP) and related facilities master plans for water, wastewater, and storm drainage. The draft EIR was made available for public review and comment for 83 days, from February 15, 2002, to May 8, 2002. This final program EIR has been prepared in response to comments received during the public review period, and comprises two volumes: # Volume I: Responses to Comments contains a list of persons, organizations, and public agencies commenting on the draft program EIR; the comments and recommendations received on the draft EIR; and the City’s responses to significant environmental issues raised in the review and consultation process. # Volume II: Revisions to the Draft EIR contains the full text of the draft program EIR, with minor changes shown as text that is struck-out (deleted) or underlined (added) in response to comments or for clarification purposes. The content and format of Volumes I and II of this final EIR meet the requirements of the California Environmental Quality Act (CEQA) and the State CEQA Guidelines (Section 15132). PURPOSE OF A PROGRAM EIR CEQA and State CEQA Guidelines require that a lead agency (in this case, the City) consider the environmental consequences of a project (i.e., the specific plans and facilities master plans) before taking action to implement the project. The State CEQA Guidelines (Section 15168) further encourage agencies to use a program EIR in certain circumstances involving the implementation of a series of related projects. Use of such a document allows the City (as the lead agency) to characterize the overall plan or program as the project being approved at the time and to consider broad policy alternatives and program-wide mitigation measures early in the plan development and facilities planning effort. This approach also avoids duplicative consideration of policies when future portions of the project are evaluated. The draft EIR prepared and circulated by the City was developed at a program level, as allowed by CEQA and the State CEQA Guidelines. This final EIR contains analysis, at a program level, of the basic issues that will be used in conjunction with subsequent tiered environmental documents for specific projects related to Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 1. Introduction Related Facilities Master Plans September 2003 1-2 the AASP, the MASP, and the related facilities master plans. Once the AASP, MASP, and the related facilities master plans are adopted by the City, the basic policy issues will not need to be revisited by subsequent (second-tier) documents. However, in many cases, actual development of these plans will involve subsequent CEQA review. BACKGROUND The City prepared the AASP and MASP to implement the development provisions of its general plan. Each of the specific plans is intended to contain policies and standards that will facilitate the development of land, protection of open space, and construction of adequate public facilities. Adoption and implementation of these plans will allow the City to annex the plan areas. The City also prepared supporting facilities master plans for water, wastewater, and storm drainage facilities that will accompany the proposed developments under each of the specific plans. PUBLIC REVIEW OF THE DRAFT EIR Public Hearing and Oral Comments The City held a public hearing during the 80-day public review period of the draft EIR to solicit public testimony. The public hearing was held on May 8, 2002, at the joint Planning Commission/City Council hearing rooms in the City. Formal testimony was received related to the draft EIR; a summary of the comments received is included in Chapter 3 of this volume. Written Comments Chapter 2 of this volume lists the agencies, groups, and individuals that commented in writing on the draft EIR. The review period for receiving written comments was February 15 through May 8, 2002. Written comments and the City’s responses to them are also provided in Chapter 2 of this volume. CONTENTS OF VOLUME I: RESPONSES TO COMMENTS The content and format of this document (Volume I) were developed to meet the requirements of CEQA and the State CEQA Guidelines as follows: # Chapter 1, “Introduction,” describes the background of the specific plans and an overview of the EIR process. Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 1. Introduction Related Facilities Master Plans September 2003 1-3 # Chapter 2, “Responses to Written Comments on the Draft EIR,” includes the written comments of all agencies, organizations, and individuals commenting on the draft EIR, as well as responses to those comments. # Chapter 3, “Responses to Oral Comments on the Draft EIR,” includes the oral comments of all agencies, organizations, and individuals commenting on the draft EIR, as well as responses to those comments. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-1 Chapter 2. Responses to Written Comments on the Draft EIR Agencies, individuals, and organizations that commented in writing on the draft EIR are listed below. Comment letters were solicited during the 83-day review period between February 15, and May 8, 2002. Table 2-1 presents a list of agencies, individuals, and organizations that submitted written comments on the draft EIR. Table 2-1. List of Agencies, Individuals, and Organizations Commenting on the Draft EIR: Airport Area and Margarita Area Specific Plans and Related Facilities Master Plans, 2002 Comment Letter Date Agency or Individual State Agencies 1 May 9, 2002 California Regional Water Quality Control Board, Central Coast Region Roger W. Briggs Local Agencies 2 May 3, 2002 San Luis Obispo County Department of Planning and Building Warren Hoag 3 May 8, 2002 San Luis Obispo County Department of Planning and Building Bill Robeson 4 May 8, 2002 County of San Luis Obispo Department of General Services Klaasje Nairne 5 May 8, 2002 The Local Agency Formation Commission Paul Hood Individuals and Organizations 6 May 1, 2002 Senn Charley Senn 7 May 1, 2002 Senn Charles L. Senn 8 May 8, 2002 Senn Charles Senn 9 May 7, 2002 Unocal 76 William J. Almas 10 May 8, 2002 Richard W. Ferris 11 May 8, 2002 Nick Muick 12 May 8, 2002 Member of the public (D.M.) 13 May 8, 2002 Jeanne Anderson Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-2 Comment Letter Date Agency or Individual 14 May 8, 2002 Jeanne Anderson 15 May 7, 2002 Stella Koch 16 May 8, 2002 Judith Jennings 17 May 7, 2002 Dave Romero 18 May 8, 2002 Bill Wilson Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-3 Responses to Comments by the California Regional Water Quality Control Board, Central Coast Region, Roger W. Briggs Response to Comment 1-1: The additional information provided by the commenter on the reports addressing Unocal’s Tank Farm is appreciated. However, the additional information only supplements the existing information already contained in the EIR (see, for example, page 3G-3 of the draft EIR, which begins the discussion of the numerous reports reviewed as part of the environmental analysis for the AASP and the MASP) and does not change the actual conclusions in the EIR. The comment does not clearly identify the locations of statements in the EIR that refer to land uses in the vicinity of soil or groundwater contamination. However, page 3G-5 specifically states that Phase I and Phase II site assessments would need to be completed for parcels in and adjacent to potential sources of hazardous materials, and Mitigation Measure HAZ-1.2 requires the preparation of Phase Is (and Phase IIs if needed). As described in Chapter 1 of Volume I, the analysis is intended to serve as a program-level review of the potential impacts associated with the AASP, among other project components. Site-specific conditions would need to be assessed in more site-specific project approvals and CEQA compliance documents. Response to Comment 1-2: The commenter’s concerns regarding land use designations are noted. However, any future development of the contaminated area will require extensive site- specific investigations and, if needed, remediation, regardless of the land use designation. The environmental impacts associated with implementation of the proposed project are addressed in Chapter 3 of the draft EIR. Impacts of past activities not related to the proposed project are not analyzed in the EIR. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-5 Responses to Comments from San Luis Obispo County Department of Planning and Building, Warren Hoag Response to Comment 2-1: Figure 3A-1 in the draft EIR shows the locations and geographic extent of the City’s existing general plan land use designations for both the Airport Area and Margarita Area. Percentages of each general plan land use designation for the Airport Area and the Margarita Area (corresponding to Figure 3A-1) are provided on pages 3A-10 and 3A-12, respectively, of the draft EIR. Furthermore, Tables 2-1 and 2-2 of the draft EIR provide a breakdown of the proposed project’s land use designations in hectares, acres, and as percentages of the total. As stated on page 3A-14 of the draft EIR (in the impact discussion), the greater level of analysis during the specific plan development process resulted in the refinement of the land use designation acreages, not a large-scale change in the overall development plans for the areas. Regarding the commenter’s concern about Business Park–designated areas: for the proposed AASP, the Business Park and Services and Manufacturing designations (approximately 45% of the total area) represent slightly less area than identified by the existing general plan designation (roughly half of the total area). The MASP identifies roughly 16% of the total area for Business Park compared to the approximate 10% identified in the general plan. This difference represents a minimal change, especially when considering that the locations of the Business Park– designated areas under both specific plans are essentially contiguous (see revised Figure 2-3, showing the locations of the proposed land use designations). As shown in Volume II of this final EIR, the impact conclusion for Impact LU-1 has been changed from “beneficial” to “less than significant.” Response to Comment 2-2: The program EIR identifies the inconsistency between the existing County general plan designations for land adjoining the planning area and the policies of the City’s general plan which promote the retention of open space outside the City’s Urban Reserve Line (URL) as a significant impact. This inconsistency predates the proposed specific plan and is a baseline condition. As such, it is not a result of the proposed project. Because the land in question is under County jurisdiction, the City staff does agree that it is appropriate for the City and County to resolve any discrepancies in the respective plans and URL policies. Because the land is within the County, the County should take the lead in seeking to reconcile their land use designations. Mitigation Measure LU-2.1 has been revised to encourage cooperation between the County and City over this issue and to provide a 2-year deadline for its resolution. Response to Comment 2-3: Page 3D-16 identifies, as part of buildout, a full interchange at U.S. Highway 101 and Prado Road and a widened bridge and ramp improvements at U.S. Highway 101/Los Oso Valley Road. Furthermore, as identified on page 3D-17 and 3D-18, additional Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-6 improvements to U.S. Highway 101 in the city are identified in a Major Investment Study and Regional Transportation Plan, which are also included in the buildout assumptions. Response to Comment 2-4: The commenter’s concerns regarding the current regional employment/housing balance and the proposed project’s potential to exacerbate the problem are noted. However, Table 3D-5 in the draft EIR shows that, in 1990, 75% of the city residents worked within the city. Furthermore, the proposed AASP and MASP represent a balanced employment/housing approach to development. Major objectives of the master plans include accommodating business and manufacturing development that would support household- supporting income as well as providing access for residents to employment and services. Response to Comment 2-5: See the response to Comment 2-4. Response to Comment 2-6: The commenter raises the question of whether the draft EIR must be updated to include more recent information on existing traffic in order to be adequate. Section 15125 of the State CEQA Guidelines provides that the “baseline” for consideration of project impacts is the environmental setting in existence at the time the NOP is released for review. This approach has been upheld in several cases, including Fat v. County of Sacramento (2002) 97 Cal.App.4th 1270 (baseline is existing airport operations, not previously approved, lesser level of operations) and Riverwatch v. County of San Diego (1999) 76 Cal.App. 4th 1428 (impacts of previous illegal activity were not part of the project’s baseline). There is no regulation that would require the City to update the baseline traffic measurements. Furthermore, as described on page 3D-20, under “Introduction and Methodology,” the draft EIR discloses the significance of project buildout, based on level of service thresholds. In other words, the project’s level of impact at buildout does not depend on the difference between existing traffic levels and projected levels. Rather, the level of impact is determined by comparing the projected delay at intersections and volume-to-capacity levels that would exist at project buildout to the City’s standards of significance. Therefore, the level of significance is unlikely to change because the traffic projections prepared for the project at buildout continue to be accurate, even if existing levels of traffic have changed. The fact that current traffic levels may differ from those in the draft EIR’s traffic study is not in itself a significant effect. Therefore, if the traffic data were updated to reflect current traffic levels, it would clarify existing traffic levels, but would not change the significance determinations in the draft EIR. Response to Comment 2-7: The commenter’s statement that the No-Project Alternative analysis is conflicting within the draft EIR is erroneous. Page 5-8 states that “urban development within the Airport and Margarita Areas would not be allowed by the City General Plan until adoption of specific plans,” which is consistent with the statement on page 3D-34. Response to Comment 2-8: As described in Chapter 1 of Volume II, the analysis in the EIR of the AASP, MASP, and the facilities master plans is, by necessity, presented at a program level. Approval of the AASP, MASP, and related facilities master plans is the first step in providing guidance for future development and provision of municipal services in the project area, and allows the City to consider the cumulative and other secondary effects of fully implementing the project. Although not stated clearly in Chapter 4, the analyses in the various sections of Chapter 3 in the draft EIR evaluate the project in conjunction with other related projects and plans in the Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-7 region (see, for example, the discussion of planned improvements, beginning on page 3D-15, which describes other related transportation projects included in the project buildout as part of the City’s general plan). Chapter 4 of the draft EIR has been modified to clarify this issue. Response to Comment 2-9: See the response to Comment 2-8. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-9 Responses to Comments from San Luis Obispo County Department of Planning and Building, Bill Robeson Response to Comment 3-1: This letter, dated May 6, 2002, from Bill Robeson, County of San Luis Obispo, is directed at the content of the AASP and its relationship to the ALUP. Since circulation of the draft EIR, the ALUP was adopted (in June 2002), after which the City has worked with the San Luis Obispo County ALUC to update the AASP to be consistent with the adopted 2002 ALUP. This comment specifically addresses the relationship between the AASP and the ALUP and does not involve the draft EIR; therefore, this comment is noted and addressed in the AASP itself. Response to Comment 3-2: This comment specifically addresses the relationship between the AASP and the ALUP and does not involve the draft EIR; therefore, this comment is noted and addressed in the AASP itself. Also, see the response to Comment 3-1. Response to Comment 3-3: See the response to Comment 3-2. Response to Comment 3-4: See the response to Comment 3-2. Response to Comment 3-5: See the response to Comment 3-2. Response to Comment 3-6: See the response to Comment 3-2. Response to Comment 3-7: See the response to Comment 3-2. Response to Comment 3-8: See the response to Comment 3-2. Response to Comment 3-9: See the response to Comment 3-2. Response to Comment 3-10: See the response to Comment 3-2. Response to Comment 3-11: See the response to Comment 3-2. Response to Comment 3-12: See the response to Comment 3-2. Response to Comment 3-13: See the response to Comment 3-2. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-11 Responses to Comments by County of San Luis Obispo Department of General Services, Klaasje Nairne Response to Comment 4-1: The Airport Master Plan and EIR are in fact used and referenced in the AASP, MASP, and related facilities master plans EIR. For example, page 3F-5 of the Noise section indicates, under “Introduction and Methodology,” that the assessment of aircraft noise was “based on information from the Airport Master Plan EA/EIR.” See Volume II of this final EIR for the corrected citation. As described in Section 3A, “Land Use and Aesthetics,” development in the Airport Area primarily is governed by the San Luis Obispo County ALUP. The ALUP policies and requirements that govern land use on or adjacent to airport property are described in Section 3A, particularly on pages 3A-1 through 3A-8. The County of San Luis Obispo ALUC’s responsibilities and goals are also described on page 3A-8. Additionally, this discussion discloses the compatible land uses and standards for the six established zones in the ALUP area. Figure 3A-1 illustrates the boundaries and land use designations of the Airport Area and the six land use zones. Impacts affecting the airport and its adjacent areas are fully disclosed, in terms of their land use implications, in Section 3A of the draft EIR. In addition, the EIR figures have been updated to reflect the recent airport runway extension, property acquisition, and relocation of Buckley Road. These figures are provided in Volume II of this final EIR. Response to Comment 4-2: The comment is noted. The County of San Luis Obispo’s request that the project description include language to indicate that annexation of the airport property is not the intent of the City is noted. However, the ultimate decision would be made at a policy level, not at a staff level, and would therefore result from a City Council action. Response to Comment 4-3: The general comment is noted; specific responses are provided where specific issues are raised below. Response to Comment 4-4: The State CEQA Guidelines, Section 15126.6(a), state that: An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR not need not consider every conceivable alternative to a project….The lead agency is responsible for selecting a range of alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. The City, as lead agency under CEQA, has acted in accordance with Section 15126.6(a) because it has chosen a reasonable range of alternatives to the project that would meet the project objectives and strive to minimize or lessen any significant effects of the project. Choosing the range of alternatives is the discretion of the lead agency. Exclusive implementation of an AASP- Only Alternative or an MASP-Only Alternative would not meet the overall project objective of Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-12 implementing both plans pursuant to the provisions of the City General Plan. Also, in accordance with Section 15126.6(a), the discussion provided in Chapter 5 of the draft EIR describes the reasoning behind the inclusion of the range of alternatives presented in the draft EIR. Response to Comment 4-5: The revised figures are included in Volume II of this final EIR. Response to Comment 4-6: As described in Chapter 1 of Volume II, the analysis in the EIR of the AASP, MASP, and the facilities master plans is, by necessity, presented at a program level. Approval of the AASP, MASP, and related facilities master plans is the first step in providing guidance for future development and provision of municipal services in the project area, and allows the City to consider the cumulative and other secondary effects of fully implementing the project. The program EIR is intended to be augmented by subsequent, second-tier environmental documents when additional details for the specific projects are identified during the development and engineering design process. Specific projects included in the specific and master plans will be reevaluated in more detail when they are proposed for implementation. Details for each subsequent project may include development bubbles and building footprints, siting details, ancillary facilities locations, parcel sizes, refinement of alignment locations, specific right-of- way limits, and detail sufficient to identify any specific impacts that may occur in areas that would be disturbed or otherwise affected by project construction or implementation. With regard to the specific components of the specific plans or the facilities master plans, whether these include construction of a housing development, a road, a bridge, a pump station, or a reservoir, the range of potential impacts on biological resources is disclosed in the draft EIR (i.e., Impact BIO-1 through Impact BIO-19). The specific acreage affected, or species disturbed, would need to be assessed when detailed, site-specific, project-level information is made available at a later date (i.e., when the City is considering adoption of a specific action). Summaries of each of the impacts are provided in each of the resource sections of Chapter 3 for the AASP, MASP, and the facilities master plans; consideration of the various plans associated with the project allows the City to review the cumulative impacts associated with implementation of all of the projects together. Response to Comment 4-7: The comment is noted. Response to Comment 4-8: The comment is noted. However, the setting sections specifically identified in the comment are for information purposes only. These sections provided the context for understanding the impact conclusions in both Section 3A and Section 3H. The location of the information does not change the impact conclusions for the issues identified. Response to Comment 4-9: The comment is unclear. Page 3D-34 identifies Alternative 4 as the No-Project Alternative in the section heading at the bottom of the page. To assist the reader in understanding the organization o the chapter and that a No-Project Alternative is evaluated in Chapter 3D, text has been added on page 3D-1 of the draft EIR. See Volume II of this final EIR. The “Planned Improvements” section of the draft EIR, beginning on page 3D-15, clearly presents City-planned road extensions, road widening projects, freeway interchange projects, and Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-13 other transportation improvements that are part of the proposed project. Other improvements are proposed by other agencies (i.e., Caltrans, SLO Council of Governments, and the County). Whether the proposed improvements are included in the adopted general plan or would be adopted as part of the specific plans has no bearing on the impact analysis. The differences in the number of intersections shown in Figure 3D-3 (13) versus the tables (generally 10) is a function of how the intersections of localized streets are analyzed versus how freeway interchanges are analyzed (different methods are used). This issue was not explained clearly in the draft EIR. Text and tables have been modified to clarify why some intersections are not shown in the various tables. See Volume II of this final EIR. Response to Comment 4-10: The comment is noted. The State CEQA Guidelines, Section 15064(d), indicate that the baseline conditions for an environmental analysis should be the time of publication of the NOP for the EIR. That date was April 2000 for the project at hand. From a practical standpoint, many available/usable data as of April 2000 predated the April 2000 NOP publication date. Where feasible, information was updated to reflect changes in the existing conditions. However, CEQA does not require a “consistent baseline” for establishing existing conditions for each resource topic, as asserted in the comment. In many cases, the analysis is more meaningful if based on average conditions or using another means than if the same year is blindly applied to all issue areas. A common example of applying different baseline years for different resource topics is the analysis of water-related issues using an average of various years to reflect both drought-year conditions and high-flow conditions, whereas traffic may be analyzed using one single year of data for the baseline. Also see the response to Comment 2-6. Response to Comment 4-11: The comment is noted. The specific areas identified do not actually provided baseless conclusions in the draft EIR. For example, for the noise impact, the setting information indicates that the City Noise Element requires noise mitigation for any new development proposed. Response to Comment 4-12: The comment is noted. See the response to Comment 4-1. Response to Comment 4-13: The area shown in the draft EIR figures as a proposed school site is no longer designated as such in the MASP project description, and all figures have been revised to reflect this change. That area is currently proposed for Open Space. See the revisions in Volume II of this final EIR. Response to Comment 4-14: The comment is noted. The minor differences between the proposed project and Scenario 1 regarding land use allocation in the MASP are not figuratively depicted because of the less than 1% to 2% change between the two land use scenarios. For example, under the “Open Space” category, the proposed project is allocated 67.3 hectares and Scenario 1 is allocated 67.7 hectares; there is less than a 1% difference between the two. These differences between the proposed project and Scenario 1, although important, are not large; as such, the table accurately depicts the differences that cannot be shown at scale in the correlating figures. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-14 Response to Comment 4-15: The comment is noted. The improvements listed on page 2-7 are specific to improvements proposed under the Wastewater Master Plan update and are shown in Figure 2-8. These improvements are listed to provide a context for other related facilities improvements in the project area. Response to Comment 4-16: Since circulation of the draft EIR, the Storm Drain Master Plan has been revised and will not include reconfiguration of the West Fork of Tank Farm Creek or portions of the East Branch of San Luis Obispo Creek. See Volume II of this final EIR for the revised text describing the Storm Drain Master Plan. Response to Comment 4-17: The comment is noted. The road improvements are part of the facility master plan and therefore are included as part of the proposed project. The proposed road improvements are set forth in the AASP, but are considered facility improvements; as such, they are included in the section of the project description specifically describing the facility master plan. Response to Comment 4-18: Bullet 2 describes a road improvement project that is not part of the proposed project and has been deleted. Bullet 3 is relevant to the proposed project only for the part that states that the widening of the two-lane segment would include a median and bikeway. See the revisions in Volume II of this final EIR. Response to Comment 4-19: The map referred to by the commenter is the City’s adopted General Plan Land Use Map, which does include land use designations for all lands within the City’s URL. The comment is correct that the ALUP areas have been superimposed on the General Plan Land Use Map to show their relative locations. The figure name has been modified to note this superimposition. See the revisions in Volume II of this final EIR. Response to Comment 4-20: The comment is noted. The language and terminology presented in the paragraph are intended to provide a description and discussion of land use compatibility. The ALUP goals and policies strictly applicable to the project area are discussed accurately. Response to Comment 4-21: The correct number is 577 hectares. This revision is included in Volume II of this final EIR. Response to Comment 4-22: The reference to “170-hectare (420-acre) Margarita Area” is consistent with the same reference in Chapter 2, “Project Description.” See page 2-2 of the draft EIR, under “Margarita Area.” Response to Comment 4-23: The comment is noted. A description of views from Tank Farm Road and Buckley Road is included in the description of existing views in the Margarita Area because these roads are close to the Margarita Area and because future development in the Margarita Area would be visible from each roadway corridor. Response to Comment 4-24: The correct impact conclusion is “less than significant,” not “beneficial.” This revision is included in Volume II of this final EIR. Definitions of the types of impacts the proposed project may have are provided on page 3-2 of the draft EIR. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-15 Response to Comment 4-25: The comment is noted. An EIR can and should address potential environmental impacts in areas outside the project area (Airport Area in this case). In this case, City staff is not convinced that industrial use allowed by the County General Plan on a property outside the City’s URL represents a relevant environmental issue that is directly related to the proposed project. Response to Comment 4-26: The project description has been revised to address these concerns. See the revisions in Volume II of this final EIR. Response to Comment 4-27: The discussion of impacts related to compatibility with surrounding land uses is characterized accurately under Impact LU-4. Text has been added to further clarify any potential compatibility issues with the surrounding airport. This revision is included in Volume II of this final EIR. Response to Comment 4-28: The reference to the figure is in error and has been removed. See the revision in Volume II. The discussion of effects on farmlands under Impact LU-5 and Table 3A-1 provide information on existing acreage as well as the consequences of the project associated with conversion of farmland. Response to Comment 4-29: The comment is noted. As discussed under Impact LU-6 on page 3A-19, the change in land use from a semirural setting to an urban developed setting is considered significant and unavoidable, in accordance with the provisions set out in the City’s General Plan EIR. The nature of the change in views associated with implementation of the proposed project, by definition (per the City General Plan EIR), would constitute this specific type of impact. No additional analysis is required to substantiate this conclusion. Also, scenic roads in the project area lend to the overall visual character and quality of the area; this is adequately addressed by Impact LU-6. Response to Comment 4-30: Text has been added to the discussion under Impact LU-7 to clarify the potential effects of light spillage on airport lands. The revision is included in Volume II of this final EIR. Response to Comment 4-31: The text has been revised, as shown in Volume II of this final EIR. Response to Comment 4-32: The alternatives address this question. A minor adjustment has been made to the Alternative 2 map to recognize the airport’s acquisition of land. The revised map is included in Volume II of this final EIR. The Local Agency Formation Commission (LAFCO) would need to approve either alternative. Response to Comment 4-33: The comment is noted. The discussion of impacts under this alternative simply states that an additional 58.6 hectares of farmland would be converted (compared to the proposed project) if this alternative were implemented. Table 3A-2 lists the amounts and types of farmland present in the project area. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-16 Response to Comment 4-34: The comment is noted. The City’s existing stormwater plan (pink book) designates design flows for various types and sizes of creeks. The assumptions used in the EIR analysis are consistent with these adopted guidelines. Response to Comment 4-35: The comment is noted. Impact H-3 concluded that the overall impact was less than significant because the proposed Storm Drain Master Plan improvements allowed floodwaters to pass from all properties without increasing the existing floodplain elevations. The Storm Drain Master Plan for the area has been modified since the draft EIR was written. The modifications express a new approach: contain all stormwater over predeveloped levels in detention basins and drain that stored stormwater slowly at a rate not to exceed the 2- year undeveloped flow rate. This approach ensures that all floodwater levels will be equal to or less than existing levels. Therefore, the overall impact of the new drainage system remains less than significant. Existing deficiencies in the drainage system were to be mitigated with the former Storm Drain Master Plan. The now-proposed Storm Drain Master Plan acknowledges the deficiencies but, because the overall development will not increase the state of deficiency, the correction of existing deficiencies is left to adjoining property owners as those properties develop (unless they become the responsibility of the City to eventually correct). This clarification has been made to the discussion under Impact H-3 and is included in Volume II of this final EIR. Response to Comment 4-36: The comment is noted. Because of the new storm drain approach, there will be no increased runoff from new development. Flows released from all sites will never exceed the flows of a 2-year storm from the undeveloped site. Response to Comment 4-37: The discussion of Impact H-4 has been revised to reflect the revised storm drain plans. See the revision in Volume II of this final EIR. Response to Comment 4-38: The comment is noted. Stormwater detention basins only detain water; they do not retain stormwater. Generally, all such basins are fully drained within 24 hours of a storm event. The revised drainage design proposed for the AASP and MASP provides for multiple small detention basins rather than the larger ones originally proposed. The smaller ones would be located in developed areas and, as such, should not attract bird life for the short duration that water may be present. This clarification has been made to the discussion under Impact H-4 and is included in Volume II of this final EIR. Response to Comment 4-39: The comment is noted. Impacts on creeks and natural areas associated with creeks in the project area are addressed in Section 3C, “Biological Resources.” The impact section discusses potential effects on specific types of habitat, such as riparian corridors and open water habitat. Also, as described on page 3C-15, under “Summary of Impacts,” the policies and goals outlined in both of the specific plans would inherently uphold the intent of City Policies OS 1.1.2 and OS 3.1.1. Finally, implementation of mitigation measures, such as Mitigation Measures BIO-1.1, BIO-6.1, and BIO-8.1, further ensure protection of natural resources in the project area. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-17 Response to Comment 4-40: Figure 3C-1 has been revised to reflect the recent modifications to the airport lands and areas. See the revision in Volume II of this final EIR. Habitat types shown on this map are accurate as drawn. Response to Comment 4-41: The comment is noted. As described on page 3C-11, under “Ruderal and Developed Areas,” ruderal habitat is found interspersed among developed areas throughout the project area. The designation of the mobile home park as “ruderal” does not mean that the area is undeveloped; rather, it means that the area contains ruderal vegetation habitat and is developed, like most of the area between the airport and Broad Street (where the mobile home park is located). Response to Comment 4-42: As stated on page 3C-14 of the draft EIR, the biological resources setting section was updated in December 2001, before release of the public draft EIR, by a qualified Jones & Stokes biologist. Part of this update included an additional review of the California Natural Diversity Database to ensure that conclusions about the presence or absence of special-status species remained valid. As far as the commenter’s statement that additional surveys are needed, Chapter 1 of Volume II of the final EIR clearly indicates the environmental analysis is presented at a program level and is not intended to replace site-specific environmental review for projects as they are designed and put forth for approval and consideration. Furthermore, Mitigation Measure BIO-1.1 specifically requires that surveys be conducted before ground-disturbing activities associated with project-specific proposals are initiated. Response to Comment 4-43: The table identifies plant species with the potential to occur in the project area and its surrounding areas, which directly includes the airport. The table title has been revised to reflect this point. The title of Table 3C-5 has also been revised to reflect this point. See the revisions in Volume II of this final EIR. Response to Comment 4-44: The comment is noted. Section 3C, “Biological Resources,” accurately describes the plant species that occur in the project area (page 3C-13). Response to Comment 4-45: The comment is noted. There is no reference to “temporary disturbance” on page 3C-14. However, the identification of temporary impacts is included to account for effects that may occur during construction activities. Response to Comment 4-46: The comment is noted. The details about the location of the mitigation site and the specifications for the mitigation are to be developed through formal consultation with the appropriate federal and state resource agencies. The City must obtain permits from these agencies before development can occur. Response to Comment 4-47: The comment is noted. As described on page 3C-17, under Impact BIO-3, development under the MASP would not involve development of the South Hills area, where the serpentine bunchgrass grasslands are located. Assuming that introduction of urban uses next to this area would result in humans destroying the habitat is speculative. Uses proposed to be located next to the South Hills area are consistent with its open space use, as described on page 3A-16, under Impact LU-4. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-18 Response to Comment 4-48: The comment is noted. Impacts BIO-5, BIO-6, and BIO-7 describe effects on wetlands and provide estimates of total acreage in the Airport Area and Margarita Area. However, because the exact development footprints of the individual projects are not known at this time, specific acreages of wetlands lost cannot be realistically calculated. The total amount of affected wetland habitat includes the amounts identified under each impact discussion. Specification of the amount of replacement habitat is a condition of the required Clean Water Act Section 404 permit, to be issued by the U.S. Army Corps of Engineers (Corps) to the City when an actual project application is presented. Specifications would be incorporated as part of the permit approvals that the City must secure before implementation of the project. As far as prohibiting any wetland replacement/mitigation sites within 10,000 feet of the runway, specific details would need to be coordinated among the actual agencies at the time a permit to fill a jurisdictional wetland is requested. Response to Comment 4-49: This revision has been made, as shown in Volume II of this final EIR. Response to Comment 4-50: The comment is noted. The measure set forth in Mitigation Measure BIO-9.1 is required to minimize the potentially significant impact resulting from implementation of the proposed project. Without the adoption of this mitigation measure, the proposed project could not be implemented because of the resulting impacts on special-status plant species. Response to Comment 4-51: Mitigation Measure BIO-9.2 has been renumbered as BIO-12.1, and its discussion is now included under “Impact BIO-12: Impacts on Non-Listed Special-Status Wildlife Species,” on page 3C-23. This revision is shown in Volume II of this final EIR. Response to Comment 4-52: The comment is noted. The basis for this conclusion is provided in the description (page 3C-11) of the type of ruderal habitat present in the project area. The ruderal habitat described is characterized by typical compositional species, which were considered to be present in that habitat in the project areas. No further analysis is required. Response to Comment 4-53: The comment is noted. Predicting the level of human disturbance in open spaces designated in the MASP or presupposing that disturbance will occur is a speculative exercise. Allowable uses in open space areas containing special-status plant species would be regulated by conditions of state and federal permits issued by resource agencies to the City. Typically, these permits prescribe the uses and specific levels of disturbance allowed in close proximity to special-status resources. No further analysis is required. Response to Comment 4-54: The comment is noted. At the time of an actual proposal, the City would complete a consultation process with the U.S. Fish and Wildlife Service (USFWS) to comply with the Endangered Species Act (ESA). Preparation of a biological assessment may be required, followed by issuance of a biological opinion by USFWS to address adverse effects on California red-legged-frog. Incorporation of mitigation measures that are conditions of another lead agency’s permit with the Corps would not be appropriate or relevant to the proposed project. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-19 Response to Comment 4-55: The suggested revisions to the text have been made, as shown in Volume II of this final EIR. Response to Comment 4-56: The comment is noted. Impact T-1, on page 3D-30, discusses the secondary impacts of the proposed road improvements. The discussion addresses effects on nonvehicular transit modes. Response to Comment 4-57: The comment is noted. It is more appropriate to reference traffic data sources in the specific section of the report in which they are used. The consultant subjectively used the two quoted sources of data “not referenced later on” to verify the other data actually used in the analysis; these sources are mentioned in the paragraph to show that multiple data sources were consulted to make valid judgments, which remain valid. The EIR must set a moment in time in which to perform analysis and identify impacts and mitigation measures. Response to Comment 4-58: The comment is noted. This paragraph refers to peak-hour turning movements and further references Figure 3D-3, showing peak-hour movements. The EIR analyzes the impacts and identifies appropriate mitigation measures for peak-hour traffic volumes. The traffic consultant that prepared the traffic section of the EIR used data from all four sources to arrive at the most realistic existing peak-hour projections for buildout conditions. These projections were then used to calculate the impacts of the project and identify necessary mitigation measures. Response to Comment 4-59: The suggested revisions to the text have been made on page 3D-5, and the title of Figure 3D-1 has been revised to reflect the changes to the text. See the revisions in Volume II of this final EIR. Response to Comment 4-60: Figure 3D-2 is intended to show existing traffic volumes on roadway segments to characterize the existing conditions, and not to contribute to the intersection analysis, as indicated in the comment. Regarding the selection of intersections for analysis: the key intersections that would most represent traffic impacts for the proposed project were selected. It was not the intent of the traffic analysis to analyze every intersection in the study area. Response to Comment 4-61: The comment is noted. The City’s circulation element was developed based on evening (or p.m.) peak-hour volumes, not a.m. volumes. Response to Comment 4-62: See the response to Comment 4-9. Changes were made to the draft EIR to clarify this issue; see Volume II. Response to Comment 4-63: The commenter is correct that Table 3D-2 does not include the “worst movement” for intersection 8. Apparently, this information was not calculated in the traffic analysis prepared for this project. Nonetheless, the basic information presented is correct. This is a minor technical omission and does not affect the adequacy of the traffic analysis or the final EIR. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-20 Response to Comment 4-64: See the response to Comment 4-9. Changes were made to the draft EIR to clarify this issue; see Volume II. Response to Comment 4-65: The suggested revision to Table 3D-2 has been made, as shown in Volume II of this final EIR. Response to Comment 4-66: Level of service thresholds are based on maximum average daily traffic volumes obtained from the Florida Department of Transportation capacity manuals. These tables are based on the methods of the Transportation Research Board Highway Capacity Manual, as described in Table 3D-3. These methods and assumptions are further described in the traffic study prepared for the proposed project (Fehr & Peers 2001). Text has been added to the discussion on page 3D-8 to clarify this point, as shown in Volume II. Response to Comment 4-67: The north leg of this intersection is a driveway, not Santa Fe Road. Figure 3D-4 has been corrected accordingly. Response to Comment 4-68: The label of intersection 6 shown in Figure 3D-4 has been corrected. See Volume II of this final EIR. Response to Comment 4-69: The commenter is correct. The street depicted is Calle Joaquin South, which aligns with the southbound off ramps. Figure 3D-4 has been corrected. Response to Comment 4-70: The traffic study is based on the baseline conditions at the time the Notice of Preparation was released for public review. An updated configuration is not shown because the traffic study was undertaken prior to the improvement of the road, and after establishment of the baseline. Response to Comment 4-71: The comment is noted. The data in Table 3D-5 are described on page 3D-10 in the first paragraph. Table 3D-5 represents only the top places of work for San Luis Obispo residents. Response to Comment 4-72: The figure has been updated, as shown in Volume II. Response to Comment 4-73: The text on page 3D-13 has been revised, as shown in Volume II. Response to Comment 4-74: Figure 3D-6 has been revised to accurately reflect proposed and existing bicycle transportation facilities in the project area. See the revision in Volume II. Response to Comment 4-75: The comment is noted. Figure 3D-8 shows only “planned improvements within the study area” (see paragraph 2, page 3D-15). Response to Comment 4-76: The comment is noted. Figure 3D-8 clearly shows the planning area and that the extension of Buckley Road is within the planning area. Response to Comment 4-77: The comment is noted. Two roadways that are planned to extend north of Prado Road are roads that are part of the MASP, not the AASP. Therefore, they are not Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-21 represented as a responsibility of the AASP. The AASP would provide for connector roads from Tank Farm Road to Prado Road. Response to Comment 4-78: The comment is noted. The discussion of previous transportation improvements is intended to provide background information for the transportation improvements currently proposed under the MASP. Past improvements are not part of the proposed project. Paragraph 2 on page 3D-19 clarifies this point. Response to Comment 4-79: The draft EIR does not clearly describe the comparison between the no-project scenario and the proposed project for Roadway Network Assumptions. Even though paragraph 3 on page 3D-20 states that the projects listed are not located in the Airport Area or Margarita Area, the language of the paragraph and the subsequent title of Table 3D-7 may lead readers to believe a comparison is being made. In fact, the improvements shown under the no-project scenario are base improvements that will occur with buildout of the City, and are shown in the City’s adopted Circulation Element. The first three and the last two projects listed under the project scenario should have been eliminated from that list, making all remaining projects “additive” to the base (no-project) conditions. The wording and table have been been corrected accordingly, as shown in Volume II of this final EIR. Response to Comment 4-80: The comment is noted. The Prado Road extension is the same for both cases. Response to Comment 4-81: The comment is noted. The revised Table 3D-7, provided in Volume II, makes clear that proposed project–only roadway network improvements are not included in the no-project scenario. Although the City’s Circulation Element shows a master plan of the roadway network needed at buildout, it is the City’s Transportation Impact Fee Program that assigns responsibility for construction of any improvements needed. Therefore, the statement in paragraph 2 on page 3D-21 is correct that some of the improvements in the Airport Area or Margarita Area will be the responsibility of development in that area. The key roadway network improvement in this category is the extension of Prado Road to Broad Street, which is the responsibility of the MASP. Response to Comment 4-82: The comment is noted. Traffic numbers are not applicable “north of Prado” for Alternative 2 because Prado Road does not exist with Alternative 2 (see Figure 3F- 3). The only alternative that shows an extension of Los Osos Valley Road is Alternative 3. There is no extension of Los Osos Valley Road shown in any other document. The No-Project Alternative traffic volumes do not need to be shown because that scenario simply assumes buildout of the areas as shown in the current general plan (see page 3D-34). The project and alternative traffic volumes are not assumed to be higher than identified for the general plan because very few land use changes, compared to those in the general plan, have been assumed in each case. Table 3D-8 reflects how traffic volumes change on various roadway segments as the roadway network changes with each scenario. Response to Comment 4-83: Trip distributions for buildout scenarios are not normally shown as output data when the traffic model is used because it is not a manually assigned distribution, but rather included as one parameter of the model. Trip distributions for buildout scenarios Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-22 would normally be found in a simple traffic impact study where a smaller project’s trips are manually distributed into the roadway system. Although it is tempting to compare Figure 3D-2 to Table 3D-8 to ascertain impacts, the true comparison is of traffic volumes to roadway capacity and intersection capacity. As most often found, intersections have less capacity than roadway segments and, as such, are the crucial links in traffic analyses. Table 3D-9 presents the impacts of each of the scenarios on critical intersections. Response to Comment 4-84: The comment is noted. See the response to Comment 4-107. Response to Comment 4-85: The commenter’s concerns about consistency of presentation are noted. However, the purpose of Table 3D-9 is to compare the proposed project’s impacts at intersections against those of the alternatives. In this case, the table clearly shows the level of service differences among the alternatives. Response to Comment 4-86: The comment is noted. See the response to Comment 4-79. Response to Comment 4-87: The suggested revision to the text has been incorporated on pages 3D-26 through 3D-29. The revised pages are shown in Volume II of this final EIR. Response to Comment 4-88: The comment is noted. Response to Comment 4-89: The suggested revision to the text has been made, as shown in Volume II of this final EIR. Response to Comment 4-90: The comment is noted. See the response to Comment 4-82. Response to Comment 4-91: Table 3D-9 shows the projected intersection levels of service under the proposed project and the levels of service under the alternatives. The table title has been revised to reflect this clarification. The revision is shown in Volume II of this final EIR. Response to Comment 4-92: The comment is noted. Table 3D-10 shows the projected intersection levels of service for the proposed project only. Table 3D-9 shows the projected intersection levels of service under the proposed project and the levels of service under the alternatives. Response to Comment 4-93: The comment is noted. Figure 3D-9 shows, as examples, two key intersections where improvements are needed. This figure is provided to enhance and clarify the written text. Full diagrams for each intersection are not necessary. Response to Comment 4-94: The comment is noted. Figure 3D-4 has been revised to reflect the correct existing conditions at the Tank Farm Road/South Higuera Street intersection. The text on page 3D-26 accurately describes the potential intersection improvement scenarios as proposed. Note that the bullet list describing improvements at this intersection provides three options; these options are exclusive of one another, as is indicated by the use of the term “or” in the bullet list. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-23 Response to Comment 4-95: The comment is noted. The discussion was prepared before the improvements were made at the intersection of Buckley Road and Broad Street. The number of lanes and turning movements needed remain the same; the degree of improvements needed may now be less, but this would not change the impact assessment or mitigation measures for the project. The text on page 3D-27 has been revised, as shown in Volume II of this final EIR. Response to Comment 4-96: The suggested revision has been incorporated, as shown in Volume II of this final EIR. Response to Comment 4-97: The improvements to Santa Fe Road involve realigning and extending the roadway, not just extending its current terminus. See Volume II of this final EIR for the clarification made in response to this comment. Response to Comment 4-98: The comment is noted. The text in the impact discussion has been revised, as shown in Volume II of this final EIR. Response to Comment 4-99: The results of the traffic analysis conducted for the proposed project and its alternatives (Fehr & Peers 2001) show that, in general, the proposed traffic improvements would enhance traffic conditions in the project area. Response to Comment 4-100: The comment is noted. The first sentence of the Alternative 4 (no-project alternative) discussion states: “The no-project alternative assumes that if the proposed project is not approved, then development would proceed as allowed under the City General Plan.” Thus, development would occur and would require project-by-project mitigation measures for project-specific impacts. Response to Comment 4-101: The comment is noted. The organization of the document has not been changed. Response to Comment 4-102: The comment is noted. See the response to Comment 4-79. Response to Comment 4-103: See the response to Comment 4-9. The intersection status and analysis were done for the baseline at the time of Notice of Preparation was released for public review. The Buckley/Broad intersection had not yet been realigned or signalized at that point in time. Response to Comment 4-104: The traffic improvements that were part of the proposed project would not be implemented under the No-Project Alternative. Traffic improvements are provided as appropriate mitigation measures to alleviate the significant traffic impacts expected to result from implementation of the No-Project Alternative. Response to Comment 4-105: The commenter is correct in pointing out that the Aero/Broad intersection is not analyzed for the proposed project. CEQA does not require that the project and its alternatives be analyzed at an equal level of detail. The text has been revised to address the possible impact at Aero Drive/Broad Street intersection under the project and a mitigation Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-24 measure added. With the mitigation measure added in response to this comment, the impact will be less than significant. Response to Comment 4-106: South Higuera Street is classified as an arterial street (4-lanes), as discussed on page 3D-5, and was analyzed as such for future conditions under the project. Response to Comment 4-107: The omission of the table showing the proposed project’s long- term emissions was in error; the table has been added (see Volume II). The assessment of air quality impacts caused by increased emissions of air pollutants is based on the local air pollution control district’s own criteria, which is derived from the ambient air quality standards (shown in Table 3E-1). The national and state ambient standards are established to protect public health and welfare and are used by the local air districts in developing thresholds in various units of measure, such as amount of emissions within a specified timeframe (i.e., pounds per day, tons per year). Pollutants listed in Tables 3E-4, 3E-5, and 3E-6 include reactive organic gases (ROG), oxides of nitrogen (NOx), carbon monoxide (CO), and particulate matter 10 microns or less in diameter (PM10). As described on page 3E-5, ROG and NOx are ozone precursors and are depicted separately to underscore the potential for ozone formation during operation of the proposed development, which is the standard practice for measuring impacts of ozone. A description of parameters and assumptions used in determining operational emissions is provided under Impact AIR-2, on pages 3E-11 through 3E-13. Response to Comment 4-108: The comment is noted. The basis of the noise evaluation is explained on page 3F-5, under “Introduction and Methodology.” Response to Comment 4-109: Section 3F of the draft EIR indicates that, “because the project will ultimately be incorporated into the City, the City Noise Element policies will be used to evaluate noise impacts…” and that the County policies “are included for information only.” However, from a land use perspective, the relevant ALUP policies are identified and evaluated in the Land Use and Aesthetics chapter of the draft EIR. Response to Comment 4-110: The suggested revision to the text has been incorporated, as shown in Volume II of this final EIR. Response to Comment 4-111: The title of Table 3F-2 has been revised, as shown in Volume II of this final EIR. Response to Comment 4-112: The suggested revision to the text has been incorporated, as shown in Volume II of this final EIR. Response to Comment 4-113: Page 3F-2 of the draft EIR has been modified to summarize the mitigation measures identified in the General Plan Noise Element. See Volume II of this final EIR. Response to Comment 4-114: Residential land uses are not located within the 60-decibel (dB) Community Noise Equivalent Level (CNEL) contour or the 65-dB CNEL contour, as depicted in Figure 3F-1. The text on pages 3F-11 through 3F-14 has been revised to clarify the noise Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-25 analysis, as shown in Volume II. Please also refer to note “c” in Table 3F-1 for an explanation of the use of 60 versus 65 dB CNEL as the maximum allowable noise exposure level. Response to Comment 4-115: The comment is noted. The cross-hatching depicted in Figure 3F-1 shows that business park uses, not open space, would be located within the 60-dB CNEL contour. In accordance with the maximum allowable noise exposure levels summarized in Table 3F-1, the land use is located in an area compatible with its adjacent uses. Response to Comment 4-116: The comment is noted. Response to Comment 4-117: The suggested revision has been made, as shown in Volume II of this final EIR. Response to Comment 4-118: The intent of the table is to show City Fire Department facilities; County Fire Station 21 is identified in the text above Table 3H-2 in the draft EIR. Response to Comment 4-119: See the responses to Comments 4-34 and 4-35. Response to Comment 4-120: The paragraph referred to in the comment states that the airport is not proposed for annexation. The airport is still part of the project. This revision has been made to the text on page 3H-21 and is included in Volume II of this final EIR. Response to Comment 4-121: The comment is noted. The City has changed the land use plan and has eliminated plans for construction of an elementary school in the Margarita Area. However, the discussion under Impact PS-9 is still relevant to the environmental analysis. Response to Comment 4-122: The comment is noted. Please see the response to comment 4-121. Response to Comment 4-123: The comment is noted. The discussion of the National Historic Preservation Act is provided because it is anticipated that federal permitting may be required to implement the proposed project, as described in the last paragraph on page 3I-3. Section 106 compliance is required when federal permits are issued for a project action. Implementation of the proposed project may require federal permits from the Corps and USFWS. Response to Comment 4-124: See the response to Comment 2-8. Response to Comment 4-125: The comment is noted. Tables 5-1, 5-2, 5-3, and 5-4 have been revised and are included in Volume II of this final EIR. Response to Comment 4-126: The list of preparers shown in Chapter 7 of the draft EIR accurately lists the project manager with major responsibility for preparing the draft EIR; as project manager and coordinator for the project, Mr. Weiss was responsible for preparing the draft EIR until the end of November 2001. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-27 Responses to Comments by the Local Agency Formation Commission, Paul Hood Response to Comment 5-1: The comment is noted. Response to Comment 5-2: LAFCO’s policies and procedures would be in effect mainly after certification and adoption of the project, but before annexation and development of any portion of the project area. Consequently, the City generally would consider LAFCO policies and procedures after CEQA clearance has been established. For clarification purposes, the policies and procedures relevant to the proposed project are included in Volume II of this final EIR. Response to Comment 5-3: The comment is noted. LAFCO’s requirements for completing a sphere of influence update and municipal service review before annexation would be in effect mainly after certification and adoption of the project, but before annexation and development of any portion of the project area. Consequently, the City would consider LAFCO requirements for completing a sphere of influence update and municipal service review after CEQA clearance has been established but before the City submits its application to LAFCO. This issue is relevant to the planning process, but is not directly applicable to the EIR. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-29 Responses to Comments by Senn, Charley Senn Response to Comment 6-1: The comment is noted. The impact discussions for the No-Project Alternative and Alternatives 1, 2, and 3 in Section 3A, “Land Use and Aesthetics,” address these issues. Response to Comment 6-2: The comment is noted. Discussion of the absorption rate of proposed commercial developments is a planning issue and out of the scope of the environmental analysis. Response to Comment 6-3: The comment is noted. Estimated timelines for water supply projects are as follows. Water Reuse. Project has been bid, and funding has been secured. Two construction contracts are expected to be awarded in June 2003. One contract is for improvements at the City’s Water Reclamation Facility, and the other is for construction of the pipelines. Construction is expected to be completed by the end of 2004. The Water Reuse Project will initially replace about 130 acre-feet per year of potable water that is currently being used for irrigation. Ultimately, more than 1,200 acre-feet of recycled water will be available to support general plan buildout. Groundwater. Exploratory wells have been drilled. The City is proceeding to evaluate treatment processes and to develop plans and specification packages for the construction of additional wells, treatment facilities, and pipelines necessary to connect to the City water distribution system. Plans and specifications are expected to be completed in spring 2005, with construction occurring in summer/fall. The additional safe-annual-yield (SAY) from the Groundwater Development Project is expected to be 500 to 1,000 acre-feet per year. Conservation. As of 2002, approximately 30,100 of the estimated 39,000 toilets in the City have been retrofitted with low-flow fixtures. Although the development retrofit program has ended, the retrofit-upon-sale ordinance remains in effect. Other conservation programs, such as technical assistance and water audits, also remain in place. In addition, the Utilities Department is working with schools and others to develop public education and water awareness programs. The relative success of these ongoing conservation programs is measured by dividing the amount of water delivered by the City’s current population, then comparing that to the adopted planning figure of 145 gallons per person per day. The actual per capita water usage is also tracked over time, to relate seasonal trends in demand with the effectiveness of new and ongoing conservation programs. The Utilities Department is just beginning a new program of commercial water conservation. The details of the program are still being Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-30 developed. With demonstrated long-term reduction of the actual per capita water usage figure, Council may decide to lower the adopted planning figure of 145 gallons per person per day, which will reduce the City’s water supply needs for general plan buildout. With regard to the City’s decision not to pursue state water, this is not in conflict with Planning Principle II, because the City has several other water supply options available that are capable of meeting the City’s water demand at buildout. In addition, pursuing state water would not be considered “reasonable,” because it was rejected by Council and twice denied by a public vote. Response to Comment 6-4: The comment is noted. The timeframes provided in the AASP and the MASP address implementation of annexation and new development. The buildout scenario would also occur in accordance with the general plan land use objectives for urban development. Response to Comment 6-5: The comment is noted. The conservative approach to the environmental analysis, which includes evaluation of four alternatives in addition to the proposed project, accounts for multiple scenarios in which buildout may occur in a prompt fashion. The City’s undertaking of the preparation of this EIR and the finalization of the AASP, the MASP, and the facilities master plans also ensures the expedition of the planning and environmental process that will lead to project approval and construction. Response to Comment 6-6: The comment is noted. The analysis of Alternatives 1, 2, 3, and 4 adequately addresses the uses that could occur if the proposed project were not implemented. Please refer to the discussion of these alternatives in Section 3A, “Land Use and Aesthetics,” as well as in Chapter 5, “Alternatives Analysis.” Response to Comment 6-7: The comment is noted. See the discussion of Alternatives 1, 2, 3, and 4 in Section 3A, “Land Use and Aesthetics,” as well as in Chapter 5, “Alternatives Analysis.” Response to Comment 6-8: The comment is noted. The environmental effects that would result if the proposed project, including its improvements to Tank Farm Road, were not implemented are described in the impact discussions presented under Alternatives 1, 2, 3, and 4 on pages 3D-32 through 3D-42. Response to Comment 6-9: See the response to Comment 4-10. Response to Comment 6-10: The comment is noted. The mitigation measures provided to minimize potentially significant air quality impacts are adequate; are in accordance with the State CEQA Guidelines, Section 15364; and do not represent volunteer-oriented, unenforceable mitigation. Also, the adequacy of the mitigation measures proposed in the EIR will be identified by the lead agency (the City) before adoption of the EIR, during the final EIR process when the findings are prepared. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-31 Response to Comment 6-11: The comment is noted. See the response to Comment 6-3 and page 3H-4, under “General Plan LU1.13.4; Policy,” with regard to development and City services. Response to Comment 6-12: The comment is noted. See the responses to Comments 6-3 and 6-11. Response to Comment 6-13: The comment is noted. Mitigation Measure CR-1.1 addresses potentially significant impacts on archaeological resources in the project area. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-33 Responses to Comments by Senn, Charles L. Senn Response to Comment 7-1: The comment is noted. This letter pertains to the AASP rather than the EIR. Also, the project description has been revised to designate most of Unocal’s developable property as Services and Manufacturing. The project description changes are shown in Volume II of this final EIR. Response to Comment 7-2: The comment is noted. This letter pertains to the AASP rather than the EIR. The issue of who funds the resource management plan will be addressed during the hearing process for the AASP. Response to Comment 7-3: The comment is noted. This comment will be addressed as part of the hearing process for the AASP. Response to Comment 7-4: The comment is noted. This comment will be addressed as part of the hearing process for the AASP. Response to Comment 7-5: The comment is noted. This comment will be addressed as part of the hearing process for the AASP. Response to Comment 7-6: The comment is noted. The procedures for addressing potential petroleum contamination are in place and are largely outside the jurisdiction of the City. State and federal resource agencies are currently working on the resolution of these issues. Response to Comment 7-7: The comment is noted. This City policy decision will be addressed as part of the hearing process for the AASP. Response to Comment 7-8: The comment is noted. The City agrees that any resolution of such issues should be achieved through cooperation among the property owners, the City, and appropriate resource agencies. Response to Comment 7-9: The comment is noted. This letter pertains to the AASP rather than the EIR. See the response to Comment 7-2. Response to Comment 7-10: The comment is noted. This City policy decision will be addressed as part of the hearing process for the AASP. Response to Comment 7-11: The comment is noted. Policy 4.13 refers to Tank Farm Road design issues. If the comment refers to Policy 4.11 on the Tank Farm Site development, this City policy decision will be addressed as part of the hearing process for the AASP. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-34 Response to Comment 7-12: The comment is noted. These City policy decisions will be addressed as part of the hearing process for the AASP. Response to Comment 7-13: The comment is noted. This City policy decision will be addressed as part of the hearing process for the AASP. Response to Comment 7-14: The comment is noted. This City policy decision will be addressed as part of the hearing process for the AASP. Response to Comment 7-15: The comment is noted. This issue is being addressed through revisions to the AASP and MASP that will significantly reduce infrastructure costs, particularly the costs of the areawide drainage system and some street improvement requirements. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-35 Response to Comment by Senn, Charles Senn Response to Comment 8-1: The project description has been revised to address the concerns expressed by the commenter. See the revisions in Volume II of this final EIR. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-37 Responses to Comments by Unocal 76, William J. Almas Response to Comment 9-1: The inconsistencies have been reviewed, and the AASP has been revised to be consistent with the ALUP. The subsequent revisions to the EIR have been incorporated, as shown in Volume II of this final EIR. Response to Comment 9-2: This comment, requesting a change in the land use designation, has resulted in a revision of the project description that would designate most of Unocal’s developable property as Services and Manufacturing. The project description changes are shown in Volume II of this final EIR. Response to Comment 9-3: The comment is noted. Detailed modeling was used to assign the correct percentage of public facility costs to the appropriate beneficiary. It should be understood that the “city as a whole” does not actually need the facilities included in the facilities master plans, but certainly will benefit from some of them. Likewise, the developers in the Airport and Margarita Areas will benefit from existing facilities in the rest of the city. Response to Comment 9-4: The comment is noted. The comment pertains to the AASP and impact fee program rather than the EIR. Response to Comment 9-5: The analysis of proposed changes in land uses focuses on the change in currently adopted City general plan designations to the AASP’s and MASP’s proposed land uses (as stated in Impact LU-1) because the project area is contained within the URL and, as such, has been marked for future annexations to the City, with the exception of the Avila Ranch area, as described in Impact LU-2. With regard to the No-Project Alternative, page 5-8 of the draft EIR states that, although this alternative would avoid the impacts associated with development of the project area, the alternative would not comply with the designated land uses of the City or County. Response to Comment 9-6: The comment is noted. Biological effects and monitoring are described in Section 3C, “Biological Resources.” Hazardous materials effects are described in Section 3G, “Hazardous Materials.” Response to Comment 9-7: The comment is noted. Allowable land uses are those previously established by the City General Plan Land Use Element and the County General Plan Land Use Policy. Anticipated uses would be implemented only after the proper planning processes have taken place to ensure consistency with City and County general plans. Chapter 5, “Alternatives Analysis,” compares impacts that would occur under different specific plan development scenarios. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-38 Response to Comment 9-8: The comment is noted. Each of the resource areas evaluated in the EIR is analyzed comparatively using the development scenarios of the proposed project and Alternatives 1, 2, 3, and 4. Response to Comment 9-9: The comment is noted. The Water System Master Plan was never intended to address water supply issues. Water supply is addressed in the City’s Urban Water Management Plan and the annual Water Resources Status Report. See the response to Comment 6-3 for the status of the City’s “Tier 1” water supply projects. In addition to the Tier 1 projects, the City is participating in San Luis Obispo County’s Nacimiento Water Supply Project and furthering the Salinas Reservoir Expansion Project. . Response to Comment 9-10: The comment is noted. For further explanation of water supply issues, see the responses to Comments 6-3 and 9-9. Response to Comment 9-11: Revisions have been incorporated in the project description to reflect updated storm drainage plans for the Margarita Area. The revised project description is provided in Volume II of this final EIR. Response to Comment 9-12: The comment is noted. The evaluation of storm drainage effects on biological resources is tiered from the analysis in the City General Plan EIR of the same type of impacts. As such, the level of detail is sufficient to address potential drainage impacts on biological resources (State CEQA Guidelines, Sections 15152[c–e]; Public Resources Code, Section 21083.3). Response to Comment 9-13: The comment is noted. Tables 3B-2 and 3B-3 describe the capacity deficiencies of the channels in the project area. The evaluation of capacity deficiencies is adequately tiered from the City General Plan EIR, and the level of detail provided in addressing these impacts is also adequate (State CEQA Guidelines, Sections 15152[c–e]; Public Resources Code, Section 21083.3). Response to Comment 9-14: The comment is noted. Alternatives 1, 2, 3, and 4 address development scenarios that could occur if the proposed project were not implemented. Chapter 5, “Alternatives Analysis,” also presents a comparison of these alternatives. Response to Comment 9-15: The comment is noted. Policy 4.13 does not require “Unocal, or its successor’s in interest” to fund the improvements of Tank Farm Road. The requirement is simply to fund the preparation of improvement plans for that portion of the road. Response to Comment 9-16: The comment is noted. The existing two-lane Tank Farm Road has sufficient capacity to carry existing traffic volumes. New development will increase traffic and is responsible for necessitating corresponding improvements. Response to Comment 9-17: The comment is noted. Please refer to the description of the methods used in evaluating traffic and circulation impacts (page 3D-20). Response to Comment 9-18: The comment is noted. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-39 Response to Comment 9-19: The title of Mitigation Measure BIO-8.1 has been revised, as shown in Volume II of this final EIR. Response to Comment 9-20: The City does not assume that Unocal is obliged to allow for mitigation on Unocal-owned property. The text of Mitigation Measure BIO-9.1 has been clarified, as shown in Volume II of this final EIR. Response to Comment 9-21: The comment is noted. The use of “fair share” is a common planning principle and practice. Negotiation of each developer’s fair-share contribution is not part of the environmental process. Response to Comment 9-22: The comment does not accurately interpret the intent of the mitigation measure. The mitigation measure is intended to ensure that construction activities that could result in the discovery of known or unknown hazardous materials will be conducted in accordance with appropriate hazardous materials laws and safety procedures. Furthermore, the depth of each management plan would be directly related to the known presence of hazardous materials at the site. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-41 Responses to Comments by Richard W. Ferris Response to Comment 10-1: The comment is noted. This comment pertains to the AASP and not to the EIR. This comment will be addressed as part of the hearing process for the AASP. Response to Comment 10-2: The commenter’s concerns regarding the use of raised medians are noted. However, the City has found, based on published reports and accident data, that raised medians allow for more controlled traffic movements and safer thoroughfares. Response to Comment 10-3: The comment is noted. However, expansion of the mobile home park is not feasible because of its proximity to the San Luis Obispo County Airport and restrictions in the adopted ALUP. Response to Comment 10-4: These comments refer to the proposed Public Facilities Financing Plan, not to the EIR itself. Although many of these comments raise appropriate fiscal issues, from both policy and technical perspectives, these are not significant environmental issues related to the EIR. As the AASP and the related infrastructure financing plan move forward for public review, opportunities to further explore these issues will be provided. Response to Comment 10-5: The comment is noted. Response to Comment 10-6: See the response to Comment 10-4. Response to Comment 10-7: See the response to Comment 10-4. Response to Comment 10-8: The comment is noted. As part of the proposed project, housing will be built in close proximity to proposed employment centers in the Margarita Area. Previous development did not adequately plan for pedestrian and bicyclist use, making it difficult for people to commute to those locations. The City’s proposal to provide adequate walking and bicycling facilities is intended to correct past mistakes. Response to Comment 10-9: See the response to Comment 10-4. Response to Comment 10-10: See the response to Comment 10-4. Response to Comment 10-11: The commenter’s concerns regarding sewer capacity are noted. However, the proposed sewer line is needed to serve future growth and not necessarily existing uses in the area. Response to Comment 10-12: See the response to Comment 10-4. Response to Comment 10-13: See the response to Comment 10-4. Response to Comment 10-14: See the response to Comment 10-4. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-42 Response to Comment 10-15: See the response to Comment 10-4. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-43 Responses to Comments by Nick Muick Response to Comment 11-1: The comment is noted. Also see the response to Comment 6-3. Response to Comment 11-2: The comment is noted. Descriptions of and justifications for proposed traffic circulation and roadway improvements associated with the proposed project, as well as their effects, are provided in Section 3D, “Traffic and Circulation.” Also, see the response to Comment 17-4. Response to Comment 11-3: The comment is noted. The text on page 3I-9 describes the potentially significant impacts associated with future development either on or near this archaeological site. Construction of proposed developments could require ground-disturbing activities, such as grading. The discussion states that any development requiring such activities on or adjacent to this site would likely result in a significant impact. Mitigation is proposed to reduce the significance of the impact. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-45 Responses to Comment by Member of the Public (D. M.) Response to Comment 12-1: The comment is noted. The project that is proposed is the adoption of the AASP, the MASP, and related facilities master plans. As the lead agency under CEQA, the City has chosen to evaluate these plans as one project. Evaluation of these plans as one project within the EIR is in accordance with CEQA’s definition of what a project may entail (State CEQA Guidelines, Section 15378[a]). The lead agency has discretion to prepare one EIR that addresses the environmental impacts of all the plans (Public Resources Code, Section 21157[a],[c]). With regard to the environmental impacts of the AASP, the plan correctly references the EIR; the scope of the specific plan does not include environmental analysis of its own provisions. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-47 Response to Comment by Jeanne Anderson Response to Comment 13-1: The draft EIR evaluates, on a program level, the air quality and noise impacts associated with the AASP, the MASP, and the related facilities master plans, including proposed improvements to the roadway system (such as the Prado Road extension). Both construction- and anticipated operation-related impacts are disclosed at a program level in the draft EIR. Subsequent projects associated with implementation of the AASP, MASP, or related facilities master plans (such as the roadway extension) would be further evaluated on a project-by-project basis. The California Department of Transportation (Caltrans) has no immediate plans to own, control, or operate Prado Road, although at some time in the future it may become a part of the state system. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-49 Responses to Comments by Jeanne Anderson Response to Comment 14-1: The comment is noted. Bicycle routes proposed for Prado Road originate from the City’s Bicycle Transportation Plan. Only a revision to this plan would allow for a change from Class II to Class I bicycle routes on Prado Road. Such a revision is not a part of the proposed project. Impacts on bicyclists are discussed under Impact T-1, on page 3D-30 of the draft EIR. This discussion provides specific guidelines that must be implemented during the design phase of proposed roadway improvements that would affect bicycle transit in the project area. Response to Comment 14-2: The comment is noted. Bicycle facilities are discussed on pages 3D-13 and 3D-14 and shown, conceptually, in Figure 3D-6. Impacts of the proposed project, including bicycle facilities, on biological resources, are discussed in Section 3C, “Biological Resources.” As specific facilities, including the bicycle overpass, underpass, and creek crossing, are designed, a study of each specific project’s individual impacts will be required. These studies will identify additional mitigation measures, if needed. Response to Comment 14-3: The comment is noted. Figure 3D-1 depicts the City’s currently adopted General Plan Circulation Element. Changes to the Circulation Element can occur only via specific City Council action. Therefore, any Circulation Element changes regarding the Orcutt Area would occur only when the City Council adopts the Orcutt Area Specific Plan. Adoption of this plan would involve a simultaneous amendment to the Circulation Element to reflect the roadway network shown in the plan. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-51 Responses to Comments by Stella Koch Response to Comment 15-1: Figure 3D-7 identifies truck routes in the project area. Page 3D-14 indicates that proposed truck routes would be limited to major arterial roadways; truck routes would not be located on minor streets fronting residences or parks. Noise impacts resulting from traffic, including truck traffic, are analyzed in Section 3F, “Noise.” Response to Comment 15-2: The comment is noted. The City initiated coordination with Caltrans during the publication and circulation of the NOP for the proposed project. Caltrans did not provide comments on the draft EIR. The City will continue its coordination with Caltrans as necessary and in accordance with CEQA. Response to Comment 15-3: The comment is noted. Environmental impacts on plants, drainage, and water quality are discussed in Section 3B, “Hydrology and Water Quality,” and Section 3C, “Biological Resources.” Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-53 Responses to Comments by Judith Jennings Response to Comment 16-1: The figure has been updated, as shown in Volume II of this final EIR. Response to Comment 16-2: See the response to Comment 2-6. Response to Comment 16-3: See the response to Comment 2-6. Response to Comment 16-4: The comment is noted. As discussed on page 3D-4, traffic and circulation in the project area is contiguous. As such, a combined description of the traffic and roadway network under the “Setting” section is appropriate. Evaluation of traffic impacts in this context is also appropriate. Furthermore, combining the discussion of traffic and circulation does not preclude a complete discussion of traffic or circulation issues in each specific plan area; rather, it ensures that all traffic impacts generated by the project components are considered in their totality and not segmented. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-55 Responses to Comments by Dave Romero Response to Comment 17-1: The comment is noted. The City will consider revisions to its URL as part of the sphere of influence study being conducted by LAFCO and the City. Although the AASP could include land outside the URL, and does include part of this area in Alternative 3, the City would not include this much development potential within the AASP until the issue of the URL is resolved. Response to Comment 17-2: The comment is noted. The alternative road alignments were discussed early during the public scoping process for the project and its alternatives. As a result of that process, the three project alternatives described in the draft EIR were chosen as the most appropriate. The elimination of a signal on Broad Street is part of Alternative 1, whereas the southeast direction and connection of Prado Road to Tank Farm Road is somewhat mirrored by Alternative 2. Response to Comment 17-3: The comment is noted. The project involves connecting Buckley Road to South Higuera Street. However, traffic modeling predicts that the traffic generated by development in the Airport or Margarita Areas will not be sufficient to warrant classifying and building the road as an urban arterial. Therefore, there is no need to require right-of-way dedication or acquisition at this time. Response to Comment 17-4: A two-lane Tank Farm Road has carrying capacity sufficient to accommodate traffic needs in the area shown for open space. The lack of turning movements and side friction allows the roadway to function at acceptable levels of service. The roadway also is located along wetland and critical habitat areas, and should be designed to minimize the effects of additional right-of-way acquisitions and other effects on those areas. The two-lane configuration with bike lanes is considered the widest practicable solution in this area. Buckley Road is no longer considered an arterial road. Given the low volumes of traffic that would be generated by the AASP and MASP, the City now proposes that Buckley Road remain in its current configuration—only the extension (from Vachel to Higuera Street) is proposed as a new road requiring a new configuration. This segment of Buckley Road is proposed to have two travel lanes and two bicycle lanes only. See revised Figure 3D-1 in Volume II for the correct depiction of Buckley Road. Response to Comment 17-5: The comment is noted. Caltrans has expressed no interest in Price Canyon Road as a new segment of Highway 227. Caltrans is in the process of developing a Major Investment Study for the highway from its intersection with Broad and South Streets to its intersection with Price Canyon Road. This study will determine what improvements will be needed in the long term. However, the study will not analyze alternative alignments for the highway inside the city limits. Final Program Environmental Impact Report for the Volume I: Responses to Comments on the Draft EIR Airport Area and Margarita Area Specific Plans and Chapter 2. Responses to Written Comments on the Draft EIR Related Facilities Master Plans September 2003 2-57 Response to Comment by Bill Wilson Response to Comment 18-1: The comment is noted. The City Council reviewed and approved a Negative Declaration of Environmental Impact for the Damon-Garcia Sports Fields Project [GPA/R 44-02] on June 18, 2002, as a project separate from the proposed AASP, MASP, and related facilities master plans. The negative declaration addressed the potential environmental issues involved in developing and operating the sports fields. Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 3. Responses to Oral Comments on the Draft EIR Related Facilities Master Plans September 2003 3-1 Chapter 3. Responses to Oral Comments on the Draft EIR SUMMARY OF PUBLIC HEARING COMMENTS One public hearing was held in the City of San Luis Obispo by the City Council/Planning Commission on May 8, 2003, to receive public comments on the draft program EIR. The comments received at the public hearing include those provided by members of the public and City Council/Planning Commission members and are summarized below. The person making the comment is identified in the summary of each comment. A response to each comment is provided immediately after each comment. Comment 1: Peter Brown, of San Luis Obispo, asked why Santa Fe Road would be jogging westward to meet up with Prado Road and why there would be a fourth parallel route, LOVR, from Higuera Street all the way to Broad Street. Response 1: Santa Fe makes a diagonal turn to Tank Farm Road to avoid an area of native grassland in this location. As for the fourth parallel route, the EIR considered general alignments as options, looking at possible connection points. Comment 2: Nick Muick, 3731 Orcutt Road, requested a summary of the discussion and changes to the EIR after more information is added to the EIR, pending a new expanded discussion of water supply. He also requested the opportunity to comment at the next meeting discussing the EIR. Response 2: The comment is noted. The expanded discussion of water supply is provided in Chapter 2 of Volume I of this final EIR, “Responses to Written Comments on the Draft EIR.” Comment 3: John French, of San Luis Obispo, stated that the EIR wasn’t what he expected, but understood why it was structured the way it was, given the large and diverse land uses and potential future projects. He expressed concern with Highway 227 and felt it wasn’t clear in the EIR what the future is for that alignment. Response 3: The comment is noted; regarding Highway 227, the EIR considered several general alignments as options, looking at possible connection points. Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 3. Responses to Oral Comments on the Draft EIR Related Facilities Master Plans September 2003 3-2 Commission Comments Comment 4: Commissioner (Commr.) Peterson noted that the AASP does not call for any residential development and questioned whether there are some areas in the Airport Area where it may be appropriate to put in some housing. Response 4: The only designation for housing in the proposed plan is an existing mobile home park. The ALUC, which has authority in this area, would be adamantly opposed to residential development in the area. Comment 5: Chairperson Loh expressed concern about the EIR and asked why there cannot be any residential uses in the entire Airport Area. Response 5: The only designation for housing in the proposed plan is an existing mobile home park. The ALUC, which has authority in this area, would be adamantly opposed to residential development in the area. Comment 6: Commr. Caruso suggested that there be a map of the petroleum hydrocarbon contamination in the EIR or specific plan. He asked if it was anything that is above an undetectable level, or whether this a certain concentration of total petroleum hydrocarbons (TPH). Response 6: Steve Hammond, of Wallace, Roberts & Todd, Inc., referred to Figure 4.3 in the specific plan and explained that the two shades of gray on the map represent different concentrations of TPH in the soil. Comment 7: Commr. Peterson expressed concern about protecting open space along Buckley Road with this plan and felt that the City would annex the Airport Area as shown on the map. He suggested annexing all around the airport. He asked if there were some way the City could annex the airport. Response 7: There is an alternative in the EIR that proposes extending land use designations down to Buckley Road, with the idea that there be a hard line for the greenbelt a little farther out than presently shown in the City’s general plan. The LAFCO would likely oppose an island of unincorporated land, and the airport is owned by the County and operated by a department of the County, so annexation by the City would not change its operations. Comment 8: Commr. Peterson asked if the landowners south of Buckley Road were asked about their interest in annexing. Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 3. Responses to Oral Comments on the Draft EIR Related Facilities Master Plans September 2003 3-3 Response 8: City staff spoke with the owners several years ago, when this effort began, and they were not interested in annexing, although the City’s Natural Resources Manager had more recently contacted some owners concerning open space easements and drainage detentions. Comment 9: Vice-Chair Osborne asked if the City could require Unocal to clean up its contamination. Response 9: The responsibility for cleaning up the contamination is ultimately decided by the Regional Water Quality Control Board. Comment 10: Vice-Chair Osborne questioned whether the characterization of this situation is that Unocal got away with it. Response 10: No, there is some contamination there, and Unocal is accepting responsibility for cleaning it up. The EIR and annexation are not the proper vehicles to attempt to remediate the contamination, and there are laws and regulatory requirements to which Unocal is subject. Comment 11: Commr. Caruso asked why the areas down Tank Farm Road to the west are not shown in the EIR. Response 11: Mr. Hammond replied this area is outside the specific plan area. Comment 12: Commr. Boswell asked about the storm drainage improvements and questioned whether the majority of these improvements would be paid for as development occurs in this area. He asked about detaining stormwater on each development site. Response 12: Subsequent to this Planning Commission CEQA hearing, the project description was modified to delete the regional storm drainage system as originally proposed. See Volume II for the incorporated revisions. Comment 13: Commr. Peterson commented on regional basins versus individual basins and felt that regional basins allow for better planning because individual basins require more land area from every site. Response 13: See the response to oral comment 12. Comment 14: Commr. Boswell recommended that some additional discussion on the flood management issue be added to address generation of stormwater or to minimize stormwater on site. He commented that there is an inconsistency in the specific plan between what the City is striving to achieve in compact urban form and what it is actually specifying for onsite Final Program Environmental Impact Report Volume I: Responses to Comments Airport Area and Margarita Area Specific Plans and Chapter 3. Responses to Oral Comments on the Draft EIR Related Facilities Master Plans September 2003 3-4 development. He suggested moving Figure 2-1 (the area map) up to the front or to the inside cover. Response 14: The suggestion for the format change is noted. Subsequent to this Planning Commission CEQA hearing, the project description was modified to delete the regional storm drainage system as originally proposed. See Volume II for the incorporated revisions. Comment 15: Chairwoman Loh questioned why the Wastewater Master Plan Update for the AASP would make the City’s wastewater collection system more efficient. Response 15: John Moss, Utilities Director, noted that there are three sewage-pumping stations that currently serve the Broad Street area; this system is inefficient. What is proposed, and what has been a city plan for wastewater systems, is to run a new sewer line and construct a single lift station on Tank Farm Road, which would create a more direct route to the treatment plant. Comment 16: Chairwoman Loh asked whether there is a map showing the different flight paths. Response 16: The different flight paths are reflected in the County ALUP designations, shown on Figure 3A-1. Comment 17: Chairwoman Loh asked whether the ALUC is a standing committee or an ad-hoc committee. Response 17: The ALUC is an independent, permanent commission. Comment 18: Commr. Boswell questioned whether the ALUC is expected to process some general plan amendments with this specific plan when it comes back. Response 18: Yes, some changes will be needed. Comment 19: Vice-Chair Osborne commented on the circulation issue, with LOVR extending through the Airport Area, and on the growth-inducing aspects of installing the road there. Response 19: The LOVR extension is one alternative, but is not actually part of the proposed project.