HomeMy WebLinkAboutItem 4c. Amendments to the Airport Area Specific Plan (SPEC-0457-2023)
PLANNING COMMISSION AGENDA REPORT
SUBJECT: REVIEW OF AMENDMENTS TO THE AIRPORT AREA SPECIFIC PLAN TO
ALLOW MIXED-USE RESIDENTIAL DEVELOPMENT WITHIN THE SERVICE
COMMERCIAL (C-S) AND MANUFACTURING (M) ZONES SUBJECT TO A
CONDITIONAL USE PERMIT WHERE APPROPRIATE AND CONSISTENT WITH THE
AIRPORT LAND USE PLAN
PROJECT ADDRESS: Airport Area Specific Plan FILE NUMBER: SPEC-0457-2023
BY: John Rickenbach, Contract Planner FROM: Tyler Corey, Deputy Director
Phone Number: 805-610-1109 Phone Number: 805-781-7169
Email: jfrickenbach@aol.com Email: tcorey@slocity.org
Rachel Cohen, Senior Planner
Phone Number: (805) 781-7574
Email: rcohen@slocity.org
APPLICANT: City of San Luis Obispo
RECOMMENDATION
Adopt a Draft Resolution (Attachment A) recommending approval to the City Council to
introduce an Ordinance to amend the Airport Area Specific Plan to allow for mixed -use
residential development in the Service Commercial (C-S) and Manufacturing (M) zones
subject to a conditional use permit, and to approve an Addendum to the Final EIR for the
Airport Area and Margarita Area Specific Plans.
SITE DATA
Applicant City of San Luis Obispo
Zone Service Commercial (C-S) and Manufacturing (M) zones in the AASP
General Plan
Land Use Services and Manufacturing in the AASP
Site Area About 1,200 acres (AASP Area)
Environmental
Determination Addendum to the Airport and Margarita Area Specific Plan Final EIR
1.0 BACKGROUND AND SUMMARY
In 2005, the City adopted the Airport Area Specific Plan (AASP) which provides a
regulatory framework for planning future development on approximately 1,200 acres in
the southern portion of the City near the San Luis Obispo County Regional Airport. The
AASP allowed uses and development standards that were guided by the 2002 San Luis
Obispo County Regional Airport’s Airport Land Use Plan (ALUP). The basic function of
Meeting Date: 2/26/2025
Item Number: 4c
Time Estimate: 30 minutes
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the ALUP is to promote compatibility between airports and land uses that surround them.
The 2002 ALUP included several safety zones and noise contours tha t limited or
prohibited residential and non-residential development. Based on these prohibitions,
when the AASP was adopted, it did not allow mixed-use residential development for
consistency with the ALUP.
In 2020, the City adopted the Housing Element an d included Program 5.5 that called for
updating the Zoning Regulations “to allow mixed -use within Service Commercial (C-S)
and Manufacturing (M) zones without a use permit within one year of the adoption of the
Housing Element.” In 2021, the City Council adopted an update to the Zoning Regulations
that removed the Conditional Use Permit (CUP) requirement and allowed mixed-use by
right in the C-S and M zones. However, updates could not be made to specific plan areas
such as the AASP because of the existing 2002 ALUP safety zone and noise contour
limitations.
As the City was updating the Zoning Regulations in 2021, the Airport Land Use
Commission (ALUC) was updating the ALUP, including revisions to the safety zones and
noise contours. Specifically, the ALUP revisions removed the limitation on residential
density within Safety Zone 6, the General Traffic Pattern Zone (see Figure 1 and
Attachment B), and narrowed noise contour areas closer to the runways (see Attachment
C). The removal of these restrictions to residential development provides an opportunity
to consider mixed-use residential projects within the AASP.
Based on the update to the ALUP and Major City Goal of Housing and Homelessness,
City Council included work program item 3.1.c in the 2023-25 Financial Plan; Initiate an
update to the Airport Area Specific Plan to allow mixed -use residential development,
where appropriate and consistent with the County Airport Land Use Plan . As such, the
City is proposing to amend the AASP to allow mixed-use development within parcels
zoned either Service Commercial (C-S) or Manufacturing (M) in ALUP Safety Zone 6. A
Conditional Use Permit (CUP) will be required to evaluate existing conditions in the AASP
such as water and sewer capacity and infrastructure, fiscal neutrality, potential for
incompatible uses, consistency with the ALUP, and emergency response.
No development would occur directly as a result of this action, which is simply a
modification of existing land use requirements under the AASP. Future development
under the modified land use requirements could occur as a result of individual project
applications that must be approved by the City through its normal development and CUP
review processes.
2.0 COMMISSION'S PURVIEW
The Planning Commission’s role is to review the proposed AASP amendments for
consistency with the City’s General Plan, AASP and applicable Zoning Regulations, and
to make a recommendation to the City Council.
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3.0 PROJECT DESCRIPTION
Figure 1: The top map shows the Airport Safety Zones overlaid on the parcels
zoned C-S and M within the AASP.
Outlined in black, the bottom map shows the areas of the AASP that are zoned C-
S and M and fall within ALUP Safety Zone 6.
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3.1 Project Location and Affected Parcels
The Project Area includes all property within ALUP Safety Zone 6 and designated as
Service Commercial (C-S) or Manufacturing (M) within the 1,200-acre AASP planning
area. Figure 1 (above) shows the location of C-S and M zoned areas within the AASP
and their relationship with all the ALUP safety zones and also shows all the C-S and M
zoned areas that fall specifically within ALUP Safety Zone 6.
A land use inventory was prepared in 2024 to determine the amount of C -S or M zoned
lands within the AASP. Table 1 below summarizes the total acreage of vacant and
developed parcels in these two land use designations.
Table 1. Summary of Land Use Inventory
C-S and M Parcels in the AASP
Land Use Designation
Acreage
Developed
(or entitled) Vacant Total
Service Commercial (C-S) 140.4 85.6 226.0
Manufacturing (M) 94.7 20.4 115.1
Total 235.1 106.0 341.1
Of this total, 236.4 acres are fully within Safety Zone 6, while the remaining 104.7 acres
are at least partially within that safety zone. Consistent with ALUP policies and the AASP
as proposed for amendment, mixed-use residential development could be considered on
the portion of any parcel within Safety Zone 6, even if the remainder of the parcel is within
a more restrictive safety zone. However, as will be discussed further below, the AASP
amendment will propose that any residential portion of a mixed -use residential
development must be located wholly within Safety Zone 6.
3.2 Overview of Proposed Amendment to the AASP
The City Council has prioritized the need for additional housing, including affordable
housing, to meet ongoing demand. With the update to the ALUP and the Major City Goal
of Housing and Homelessness, City Council included work program item 3.1.c in the
2023-25 Financial Plan; Initiate an update to the Airport Area Specific Plan to allow mixed-
use residential development, where appropriate and consistent with the County Airp ort
Land Use Plan.
The City is proposing to amend the AASP to allow mixed -use development within Service
Commercial (C-S) or Manufacturing (M) zoned parcels with the approval of a Conditional
Use Permit (CUP). As noted above, mixed-use residential development would only be
considered within ALUP Safety Zone 6. No development would occur directly as a result
of this action. No existing zoning designations are proposed to change. Instead, the
resulting amendment would allow mixed-use residential development, subject to specific
findings, and consistent with the requirements of the City’s Zoning Regulations, as they
currently apply to C-S and M designated lands in the rest of the City.
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Attachment A, Exhibit A includes the proposed amendments to the AASP. The crucial
aspect of these changes relates to the findings that would need to be made in order for
the Planning Commission to approve a CUP for a mixed-use residential project within the
AASP. These include the following:
1. There is demonstrable water and sewer capacity to serve the project;
2. Any fiscal impact of the project to the City must be offset to achieve fiscal
neutrality;
3. There are no nearby uses that generate sufficient air emissions, noise, odors or
vibration to create an incompatibility with proposed mixed-use development;
4. Proposed mixed-use residential development is consistent with land use, safety
or noise restrictions set forth in the ALUP, and any residential portion of a mixed-
use development shall be wholly located within Safety Zone 6; and
5. There is adequate emergency response.
Future individual project applications must be reviewed by the City through its normal
development and conditional use permit review processes, and subject to environmental
review under the California Environmental Quality Act (CEQA). However, the magnitude
and timing of such development is speculative at this time, and would be influenced by a
variety of factors, including market demand, property owner desire to develop,
consistency with the Airport Land Use Plan (ALUP), and potential environmental
constraints that may apply to specific parcels where project development applications are
under consideration.
The other noteworthy aspect of the AASP amendment is the elimination of Table 4 -1
within the AASP, which provided a land use inventory and described buildout potential
within the area. The reasons for its removal are that it is out of date, reflects buildout
potential based on assumptions made when the specific plan was first adopted 20 years
ago, does not aid in implementing the specific plan, and with less interest in purely
commercial development and the ability to pursue mixed-use residential development,
any estimate of potential buildout within the area is likely to be inaccurate.
4.0 PREVIOUS REVIEW
On January 15, 2025, the project was informally presented to Airport Land Use
Commission (ALUC) for preliminary review. Per the ALUP, the ALUC is required to review
certain types of actions that affect land use in the vicinity of airports to ensure that the
action proposed by the referring agency, the City, is consistent with the ALUP. The ALUC
provided comments, which were addressed by City staff and included in ALUC’s staff
report (Attachment D) for a formal conformity determination, which occurred on February
19, 2025. At that meeting, ALUC found the project to be in conformance with the ALUP,
subject to findings and conditions, which have been incorporated into the proposed AASP
amendment (Exhibit A of Attachment A.)
A key ALUC condition would limit the construction of the residential portion of mixed-use
development to Safety Zone 6, and not in any of the more restrictive safety zones (see
Figure 2). However, nearly all the C-S and M zoned parcels are either wholly located or
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mostly located in Safety Zone 6. In all, 117 of the 132 parcels zoned C-S or M are wholly
within Safety Zone 6, encompassing 236 acres. Of the remaining 15 parcels (104 acres),
most include substantial area within Safety Zone 6. As the AASP amendments have been
found to be in conformance with the ALUP, future mixed -use residential development
projects in the AASP would not be required to be reviewed by the ALUC.
5.0 POLICY CONSISTENCY ANALYSIS
5.1 Consistency with the General Plan and Major City Goals
The AASP was found to be consistent with the General Plan at the time of its adoption in
2005, as have all subsequent amendments to the AASP. The proposed amendment to
the AASP would allow mixed-use residential development within land zoned as Service
Commercial (C-S) and Manufacturing (M), consistent with the Services and
Manufacturing designation under the General Plan. The concept of mixed uses in
appropriate locations within the City is supported in multiple policies within the General
Plan, notably in the Housing and Land Use Elements and implements work program item
3.1.c in the 2023-25 Financial Plan Major City Goal of Housing and Homelessness. Table
2 summarizes the proposed specific plan amendment’s consistency with the Housing and
Homelessness Major City Goal that relates to housing and homelessness, as well as key
General Plan goals, policies and programs.
Table 2. Major City Goals and General Plan Policy Consistency Analysis
Goal/Policy/Program Consistency Analysis
Major City Goal
Housing and Homelessness. Support the
expansion of housing options for all, and
continue to facilitate the production of
housing, including the necessary supporting
infrastructure, with an emphasis on affordable
and workforce housing as well as accessibly
connected development. Collaborate with
local non-profit partners, non-governmental
agencies, the county, the state, and federal
governments to advocate for increased
funding and implementation of
comprehensive and effective strategies to
prevent and reduce homelessness.
Consistent. By allowing mixed-use in the
AASP, the proposed project directly
addresses this major city goal by creating a
new means of providing additional housing in
the City.
Work Program Item #3.1.c. Initiate an
update to the Airport Area Specific Plan to
allow mixed-use residential development,
where appropriate and consistent with the
County Airport Land Use Plan.
Consistent. The proposed update to the
AASP would fulfill MCG work program item
3.1.c to allow additional residential
development as part of a mixed-use project
consistent with the ALUP.
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General Plan Housing Element
Program 5.5. Update the Zoning
Regulations to allow mixed-use development
within Service Commercial (C-S) and
Manufacturing (M) zones without a use
permit within one year of the adoption of the
Housing Element.
Consistent. This program has already been
implemented in C-S and M zones throughout
the City, with the exception of in the AASP
(and other specific plan areas). Due to the
recent update of the Airport Land Use Plan
(ALUP), there is now the opportunity to
implement this policy in the AASP. However,
a Conditional Use Permit (CUP) would be
required subject to specific findings due to
existing conditions in the AASP such as
water and sewer capacity and infrastructure,
fiscal neutrality, potential for incompatible
uses, consistency with the ALUP, and
emergency response.
Program 6.13. Consider General Plan
amendments, as projects are proposed, to
rezone commercial, manufacturing, or public
facility zoned areas for higher-density, infill or
mixed-use housing, where compatible with
surrounding development…
Consistent. While this program encourages
mixed-use residential development through
amendments to the General Plan (and not to
specific plans), its intent is consistent with the
specific plan amendment currently being
proposed, which would allow for mixed-use
residential development in a substantial
portion of the City where it had not been
previously allowed and would have a similar
effect to what would occur through a General
Plan amendment.
General Plan Land Use Element
Policy 3.8.5. Mixed Uses. The City
encourages compatible mixed uses in
commercial districts.
Consistent. By allowing for mixed-use
residential development within the Service
Commercial and Manufacturing zones within
the AASP, the project directly implements this
policy.
5.2 Consistency with the Zoning Regulations
As described in Section 4.1 above, the proposed specific plan amendment would allow
for mixed-use development in the C-S and M zones subject to a Conditional Use Permit
within the AASP. The maximum density of residential development within mixed-use
projects in the AASP would be 24 density units per acre, which is identical to what is
allowed in other mixed-use projects elsewhere in the City within C-S and M zones. The
project is therefore consistent with the Zoning Regulations.
6.0 FISCAL IMPACTS
Kosmont prepared a fiscal impact analysis to examine the effects of allowing mixed -use
residential development within the C-S and M zones in the AASP, which is included as
Attachment E. The analysis evaluated two scenarios of potential land development within
the AASP in order to estimate net fiscal impacts from potential future development. The
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first examined likely development in the AASP under current market conditions based on
the existing General Plan and AASP, which do not allow for mixed -use. The second
scenario reflects the potential for mixed-use residential development in the AASP in the
C-S and M zones. In both cases, the analysis considered current market conditions and
demand, which is generally stronger for residential than the predominantly industrial uses
currently allowed in the AASP.
6.1 Development Scenarios, Assumptions and Conclusions
Existing General Plan and AASP Scenario. While the 2014 LUCE land use scenario
(office, retail, industrial with no residential) would achieve an annual fiscal “surplus” for
the City’s General Fund, Kosmont’s study identifies that the level of office and retail land
uses assumed does not reflect current market and economic conditions (additionally
evidenced in lack of non-residential development over previous 10 years), and is
therefore an unrealistic view of what is likely to be developed in the foreseeable future.
Mixed Use Scenario. Kosmont’s study further explores that a more likely future AASP
land use development scenario would include a mix of uses, including both “vertically”
blended uses (e.g., housing over commercial), as well as “horizontally” blended uses
(e.g., commercial or hospitality behind or adjacent to housing). Based on this, Kosmont
in consultation with City staff developed a potential market-based, blended-use land use
scenario, primarily based on a combination of demonstrated developer interest within the
City, Kosmont’s previous market supply and demand analysis in the region, and broader
real estate development trends across the State and nationally. Assumptions also reflect
proposed and approved projects within the AASP, but excludes the remaining residential
units within Avila Ranch, as that project already includes a maintenance Community
Facilities District (CFD) to augment funding for municipal services.
In this scenario, this analysis projects a net negative fiscal impact for the General Fund,
driven largely by the tax sharing agreement that limits the City’s receipt of property tax
revenue from new development in this area.
6.2 Recommendations
In order to support long-term fiscal solvency for the City General Fund while not over-
prescribing non-residential uses beyond market and financial feasibility, and while not
relying solely on future non-residential uses which are difficult to predict, Kosmont
identifies four potential strategic approaches to achieving fiscal neutrality:
1. Maintenance/services Community Facilities District (CFD), similar to the
mechanism utilized for the Avila Ranch development project within the City
(potentially most feasible strategy)
2. Renegotiation of the Property Tax Sharing Agreement with the County
3. Infrastructure Financing District negotiation with the County (as a backup to #2
above)
4. Minimum commercial use requirements for residential projects
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Kosmont’s report recommends that the most feasible approach of the four is to implement
a CFD. However, without a CFD or another mechanism that can apply to the entire AASP,
fiscal neutrality can also be achieved on a project -by-project basis, through the
implementation of Homeowners Associations or similar mechanisms that use fees
collected from homeowners to provide public services. The proposed specific plan
amendment responds to this analysis by requiring that in order to approve a Conditional
Use Permit for any individual project, any fiscal impact of that project to the City must be
offset to achieve fiscal neutrality.
7.0 ENVIRONMENTAL REVIEW
The Final Programmatic EIR for the Airport Area and Margarita Area Specific Plans and
Related Facilities Master Plans (“Final EIR”, or “AASP Final EIR”) addressed future
development within the Airport Area Specific Plan. The Final EIR was certified in
September 2003 and has provided the basis for evaluating the impacts of future
development within the AASP area. Subsequent amendments to the AASP were subject
to separate CEQA evaluations to address the potential impacts stemming from those
amendments.
An Addendum to the Final EIR has been prepared to address changes to the approved
project, and is included as Attachment F. Pursuant to Section 15164(b) of the CEQA
Guidelines, an addendum to an adopted Final EIR may be prepared by the Lead Agency
that prepared the original Final EIR if only minor technical changes or additions are
necessary or none of the conditions described in Section 15162 have occurred that
require preparation of a subsequent EIR. An Addendum is appropriate to address the
modified project because the proposed changes to the approved project do not meet the
conditions of Section 15162(a) for preparation of a subsequent EIR.
The County of San Luis Obispo Airport Land Use Commission conducted an Initial S tudy
and prepared a Negative Declaration for the 2021 update of its Airport Land Use Plan
(ALUP). That environmental document was used in part to inform some of the conclusions
contained in the Addendum prepared for the proposed AASP amendment.
8.0 ALTERNATIVES
1. Continue project. An action to continue the item should include a detailed list of
additional information or analysis required to make a decision.
2. Deny the project. An action recommending the City Council deny the proposed
amendments and should include findings that cite the basis for denial and should
reference inconsistency with the General Plan, Zoning Regulations, or other policy
documents.
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9.0 ATTACHMENTS
A - Draft PC Resolution
B - ALUP Safety Zones Overlaying the AASP
C - ALUP Noise Contours Overlaying the AASP
D - ALUC Staff Report 2-19-25
E - Fiscal Impact Analysis
F - Addendum to Final EIR
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RESOLUTION NO. PC-XXXX-25
A RESOLUTION OF THE SAN LUIS OBISPO PLANNING COMMISSION
RECOMMENDING APPROVAL OF AMENDMENTS TO THE AIRPORT
AREA SPECIFIC PLAN TO ALLOW MIXED-USE DEVELOPMENT
WITHIN THE SERVICE COMMERCIAL (C-S) AND MANUFACTURING
(M) ZONES SUBJECT TO A CONDITIONAL USE PERMIT WHERE
APPROPRIATE AND CONSISTENT WITH THE AIRPORT LAND USE
PLAN; AND A DETERMINATION THAT THE PROJECT IS CONSISTENT
WITH THE CERTIFIED FINAL EIR FOR AIRPORT AREA AND
MARGARITA AREA SPECIFIC PLANS AND RELATED FACILITIES
MASTER PLANS (FEIR) WHEN CONSIDERED IN CONJUNCTION WITH
AN ADDENDUM TO THE FINAL EIR; AS REPRESENTED IN THE
AGENDA REPORT AND ATTACHMENTS DATED FEBRUARY 26, 2025
(SPEC-0457-2023)
WHEREAS, the 2014 General Plan Land Use and Circulation Elements (LUCE)
update includes numerous policies that support the development of additional housing,
particularly affordable housing, to meet ongoing demand; and
WHEREAS, consistent with Housing Element Program 5.5, the City in 2021
updated Title 17 (Zoning Regulations) to allow for mixed-use development in Service
Commercial (C-S) and Manufacturing (M) zones by right throughout the City except in
Specific Plan Areas such as the Airport Area Specific Plan (AASP) in order to help
address ongoing housing demand; and
WHEREAS, the City has not allowed for mixed -use development in Service
Commercial (C-S) and Manufacturing (M) zones in the AASP because the 2002 San Luis
County Regional Airport (SBP) Airport Land Use Plan (ALUP) established safety and
noise areas that limited or prohibited noise sensitive residential uses or high-density
residential development in effect at the time of the adoption of the AASP in 2005; and
WHEREAS, the San Luis Obispo County Airport Land Use Commission (ALUC) in
2021 amended and restated the ALUP to address new technical information related to
safety and noise, which resulted in a refinement of areas subject to land use restrictions
under the ALUP, including areas within the AASP and as a result, there is now substantial
area within the AASP where the land use restrictions have changed and create d
opportunities for mixed-use developments within the AASP; and
WHEREAS, the Airport Land Use Commission of the County of San Luis Obispo,
upon receipt of a formal referral from the City of San Luis Obispo, conducted a hearing
on February 19, 2025, and determined the proposed SPA is consistent with the San Luis
Obispo County Regional Airport Land Use Plan subject to conditions, pursuant to a
proceeding instituted under SPEC-0457-2023, City of San Luis Obispo, applicant; and
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Resolution No. PC-XXXX-25
Page 2
WHEREAS, the Planning Commission of the City of San Luis Obispo conducted a
public hearing in the Council Chamber of City Hall, 990 Palm Street, San Luis Obispo,
California on February 26, 2025, for the purpose of recommending amendments to the
AASP to allow mixed-use development within the Service Commercial (C-S) and
Manufacturing (M) zones subject to a conditional use permit where appropriate and
consistent with the ALUP; and
WHEREAS, notices of said public hearings were made at the time and in the
manner required by law; and
WHEREAS, the Planning Commission of the City of San Luis Obispo has duly
considered all evidence, including the testimony of the applicant, interested parties, and
evaluation and recommendations by staff, presented at said hearing; and
NOW, THEREFORE, BE IT RESOLVED by the Planning Commission of the City
of San Luis Obispo as follows:
SECTION 1. Findings. Based upon all evidence, the Planning Commission makes
the following findings:
1. The proposed amendment to the Airport Area Specific Plan (AASP) is consistent
with the intent of the General Plan because it will not result in additional impacts
beyond those anticipated in the Airport Area and Margarita Area Specific Plans
and Related Facilities Master Plans Final EIR, and because the concept of mixed
uses in appropriate locations within the City is supported in multiple policies within
the General Plan, notably in the Housing and Land Use elements.
2. The proposed AASP amendments are intended to allow for mixed-use
development consistent with the intent of the General Plan and in a manner
generally consistent with how it is considered in C-S and M zones elsewhere in the
City.
3. The proposed AASP amendments do not substantively change the policy
framework or overall land use or circulation pattern envisioned in the originally
adopted Specific Plan.
4. The proposed AASP amendments will not cause serious health problems,
substantial environmental damage, or cause impacts beyond those disclosed in
the certified Final EIR and Addendum for this action.
SECTION 2. Environmental Review. An addendum to the certified Final
Environmental Impact Report (FEIR) (SCH #2000051062) for the Airport Area and
Margarita Area Specific Plans and Related Facilities Master Plans was prepared to
address changes to the previously-approved project, pursuant to Section 15164(b) of the
CEQA Guidelines, since only minor technical changes or additions are necessary to the
certified Final EIR and none of the conditions described in Section 15162 of the CEQA
Guidelines have occurred that require preparation of a subsequent EIR.
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Resolution No. PC-XXXX-25
Page 3
The project is consistent with the certified Final Envi ronmental Impact Report (FEIR) for
Airport Area and Margarita Area Specific Plan and Related Master Plans under the
California Environmental Quality Act (CEQA) in conjunction with an Addendum prepared
pursuant to CEQA Guidelines 15164. All mitigation measures adopted as part of the Final
EIR that were included in the Airport Area Specific Plan that are applicable to the
proposed Specific Plan Amendment (SPA) are carried forward and applied to the
proposed SPA to effectively mitigate the impacts that were previously identified.
SECTION 3. Action. The Planning Commission hereby recommends to the City
Council the introduction and adoption of an ordinance to amend the AASP to allow mixed-
use development within the Service Commercial (C-S) and Manufacturing (M) zones
subject to a conditional use permit where appropriate and consistent with the ALUP as
set forth in Exhibit A and incorporated herein.
Upon motion of Commissioner ___________, seconded by Commissioner ___________,
and on the following roll call vote:
AYES:
NOES:
ABSENT:
RECUSED:
The foregoing resolution was adopted this 26th day of February 2025.
____________________________________
Tyler Corey, Secretary
Planning Commission
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Resolution No. PC-XXXX-25
Page 4
EXHIBIT A
PROPOSED AMENDMENTS TO THE AIRPORT AREA SPECIFIC PLAN TO ALLOW
MIXED-USE DEVELOPMENT WITHIN THE SERVICE COMMERCIAL (C-S) AND
MANUFACTURING (M) ZONES SUBJECT TO A CONDITIONAL USE PERMIT WHERE
APPROPRIATE AND CONSISTENT WITH THE AIRPORT LAND USE PLAN
Additions to the Airport Area Specific Plan language is shown in underline text, with
language to be removed shown in strikethrough text.
Chapter 1—Introduction
Page 1-3. Environmental Review. Add the following paragraph following the first
paragraph on the page, which describes the CEQA review that was conducted for this
specific plan amendment.
Pursuant to Section 15164(b) of the CEQA Guidelines, an Addendum to the Final EIR
was prepared to address changes to the Specific Plan Amendment approved in 202 5,
which allowed mixed-use development in Service Commercial (C-S) and Manufacturing
(M) zones subject to a Conditional Use Permit within the AASP.
Page 1-7. The Planning Process. Add a new paragraph at the end of this section related
to allowing mixed-use in the Service Commercial (C-S) and Manufacturing (M) zones
within the AASP:
In 2025, the AASP was amended to allow mixed-use in the Service Commercial (C-S)
and Manufacturing (M) zones subject to a Conditional Use Permit and findings described
in Table 4-3, consistent with the 2021 amended and restated San Luis Obispo County
Regional Airport Land Use Plan.
Chapter 2—The Planning Area
No changes proposed.
Chapter 3—Conservation and Resource Management
Page 3-12. Aircraft Operations. Add the following to the end of this section:
The Airport Land Use Commission adopted a major amendment to the Airport Land Use
Plan on May 26, 2021. The amended and restated ALUP provides for noise contours that
are tied to aircraft and airport activity that are consistent with adopted federal Terminal
Area Forecasts, and on safety zones that are based on and consistent with those
described in the Caltrans Airport Land Use Planning Handbook. These revised safety
areas and noise contours have the general effect of opening certain areas in the AASP
to residential development.
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Resolution No. PC-XXXX-25
Page 5
Chapter 4—Land Use
Page 4-2. Land Use Background. Modify the third complete paragraph on Page 4 -2 as
follows:
The land use plan was developed to ensure compatibility with airport operations. Uses
that have high concentrations of people or are sensitive to airport noise (e.g., low density
residential, schools, hospitals, etc.) are not included in the planning area. The designated
AASP land uses (Figure 4-1) are consistent with the airport safety areas in the San Luis
Obispo County Regional Airport Land Use Plan (ALUP), as amended in 2021. Generally,
the critical areas in line with the runway centerlines will be maintained as open space.
Lower intensity warehousing, manufacturing, service, business park and mixed-use
development are designated for the less sensitive zones to the sides of the runways, and
further out from the ends of the runways.
Page 4-3. Land Use Background. Remove Table 4-1 (Airport Area Specific Plan Land
Use Program and Development Capacities) as shown below and all references to Table
4-1 in the text of the Specific Plan.
Page 4-23. Table 4-3. Allowed Uses. Amend Table 4-3 to include a line item for Mixed-
Use, indicating that it is allowed with a Conditional Use Permit. Add the following note
(#9) at the end of the table that refers to the development standards and findings for
Page 135 of 214
Resolution No. PC-XXXX-25
Page 6
mixed-use development within the C-S and M zones. Specific proposed changes to Table
4-3 are shown below as underlined text:
Table 4-3 – Allowed Uses
Key:
A = Allowed
D = Allowed by Administrative Use Permit
PC = Allowed by Planning Commission Use Permit
Land Use
Zoning District
PF C-S M BP
MIXED-USE (also see Footnote 9 & 10) PC PC
Footnote:
9. In order to approve a Conditional Use Permit (noted as PC in Table 4 -3) for a mixed-
use development in the C-S and M zones, the Planning Commission shall find the project
consistent with development standards outlined in San Luis Obispo Municipal Code
Section 17.70.130 (Mixed-use development) and make the following findings:
1) There is demonstrable water and sewer capacity to serve t he project;
2) Any fiscal impact of the project to the City must be offset to achieve fiscal
neutrality;
3) There are no nearby uses that generate sufficient air emissions, noise, odors
or vibration to create an incompatibility with proposed mixed-use development;
4) Proposed mixed-use residential development is consistent with land use,
safety or noise restrictions set forth in the ALUP and any residential portion of
a mixed-use development shall be wholly located within Safety Zone 6; and
5) There is adequate emergency response.
10. Avigation easements shall be recorded for each property prior to the issuance of a
building permit. All owners, potential purchasers, occupants (whether as owners or
renters), and potential occupants (whether as owners or renter s) shall receive full and
accurate disclosure concerning the noise, safety, or overflight impacts associated with
Airport operations prior to entering any contractual obligation to purchase, lease, rent, or
otherwise occupy the subject property or properties.
Page 4-28. Table 4-5. Building Intensity and Coverage Standards. Amend Table 4-5 to
indicate a maximum Floor Area Ratio (FAR) of 1.5 for the C-S and M zones, including for
mixed use development in those zones, in order to be consistent with the maximum FAR
in C-S and M zones elsewhere in the City. Specific changes are shown below in underline
text.
Page 136 of 214
Resolution No. PC-XXXX-25
Page 7
Table 4-5
San Luis Obispo Airport Area Specific Plan
BUILDING INTENSITY AND COVERAGE STANDARDS
Also See Table 4-6. Limitations on employee and customer concentrations due to
airport safety are more restrictive than the standards provided below in most cases
and may reduce maximum potential FAR.
Design Standard
Land Use Designation
Business
Park
Service
Commercial Manufacturing
Maximum floor area ratio: mixed-
use development
n/a 1.5 1.5
Page 4-30. Table 4-8. Parking Standards. Add the following note to Table 4-8:
(b) Parking standards for the residential component of mixed-use projects in the C-S and
M zones must be consistent with the parking standards for residential uses as set forth in
Section 17.72 of the Zoning Regulations.
Chapter 5—Community Design
Page 5-15. Goal 5.4, Guideline I. Modify as follows:
In R-3 and R-4 zones, as well as in the residential portions of mixed-use projects, parking
bays and garages shall be placed adjacent to non-residential uses or adjacent to noise
exposure areas to the extent possible to buffer sound impacts.
Page 5-18. Standard 5.6.2. Modify this standard as follows:
Each commercial, industrial loading, outdoor recycling or waste collection area shall be
located on the side of a building opposite from parcel lines or street frontages of any land
designated for residential use, or for mixed-use projects, separated or screened from the
residential portion of the project to the extent possible.
Page 5-38. Table 5-5. Add a footnote to Table 5-5 as follows:
Residential landscape design standards also apply to mixed -use projects within the
Service Commercial and Manufacturing land use categories.
Chapter 6—Circulation & Transportation
No changes proposed.
Page 137 of 214
Resolution No. PC-XXXX-25
Page 8
Chapter 7—Utilities & Services
No changes proposed.
Chapter 8—Public Facilities Financing
Page 8-15. Add a new Section 8.6.4 as follows:
8.6.4 Fiscal Neutrality
In order to support long-term fiscal solvency for the City General Fund while not over-
prescribing non-residential uses beyond market and financial feasibility, and while not
relying solely on future non-residential uses which are difficult to predict, mixed-use
projects will be required to achieve fiscal neutrality. It is recommended that the City
implement a Community Facilities District (CFD), similar to the mechanism used for the
Avila Ranch development project, that could be applied to the AASP. However, without
a CFD or another mechanism that can apply to the entire AASP, fiscal neutrality can also
be achieved on a project-by-project basis, through the implementation of Home Owners
Associations or similar mechanisms that use fees collected from homeowners to provide
public services.
Chapter 9—Implementation
Page 9-2. Section 9.4, Architectural Review. Modify this section as follows:
Consistent with required citywide procedures, commercial, industrial, institutional, mixed-
use and multi-family residential construction developments will be subject to architectural
review. For projects subject to architectural review, the “minor or incidental” procedure
should be used for those projects meeting this Specific Plan’s design standards.
Page 9-3. Section 9.8, Environmental Review. Add the following to the end of this section:
All individual development projects within the AASP that require discretionary approval
are subject to project-specific environmental review as applicable under the California
Environmental Quality Act (CEQA).
Page 138 of 214
Ta n k Farm
South Higuera Tank Farm
I n d u s t r i a l
Hoover
F i e r o
A e r o
Lo
n
g
Granada
Suburban
Va
c
h
e
l
l
Buckley Buckley
S a n ta F e
A e r o v is t a
PoinsettiaClarion
MM
M
M
M
C-SC-S C-S
C-S
M
M
C-S
C-S
C-S
C-SC-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
M
M
C-S C-S
C-S
C-SC-S
C-S
C-S
C-S
Airport Area Specific Plan (AASP)
Airport Safety Zones
µ
0 0.5 10.25 Miles
Airport Area Specific Plan
City Limit
Zoning
Service Commercial (C-S)
Manufacturing (M)
Airport Safety Zones
Zone 1: Runway Protection Zone
Zone 2: Inner Approach/Departure Zone
Zone 3: Inner Turning Zone
Zone 4: Outer Approach/Departure Zone
Zone 5: Sideline Zone
Zone 6: Traffic Pattern Zone SLOGIS
January 2025Page 139 of 214
Page 140 of 214
Airport Area Specific Plan (AASP)
Airport Noise Contours
SLOGIS
January 2025
Ta n k Farm
South Higuera Tank Farm
I n d u s t r i a l
Hoover
F i e r o
A e r o
Lon
g
Granada
Suburban
Va
c
h
e
l
l
Buckley Buckley
S a n ta F e
A e r o v is t a
PoinsettiaClarion
MM
M
M
M
C-SC-S C-S
C-S
M
M
C-S
C-S
C-S
C-SC-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
C-S C-S
C-S
C-SC-S
C-S
M
M
C-S C-S
C-S
C-SC-S
C-S
C-S
C-S
0 1 20.5 Miles
µ
Airport Area Specific Plan
City Limit
Zoning
Service Commercial (C-S)
Manufacturing (M)
Noise Contour Levels
60 dB CNEL
65 dB CNEL
70 dB CNEL
75 dB CNEL
Page 141 of 214
Page 142 of 214
SAN LUIS OBISPO COUNTY AIRPORT LAND USE COMMISSION
DATE: FEBRUARY 19, 2025
TO: AIRPORT LAND USE COMMISSION (ALUC)
FROM: ERIC TOLLE, STAFF ALUC LIAISON
COUNTY OF SLO DEPARTMENT OF PLANNING AND BUILDING
REFERRING AGENCY: CITY OF SAN LUIS OBISPO
PROJECT MANAGER: JOHN RICKENBACH
SUBJECT: A MANDATO R Y REFERRAL BY THE CITY OF SAN LUIS OBISPO
(CITY) FOR A DETERMINATION OF CONSISTENCY OR
INCONSI S TENCY WITH THE AIRPORT LAND USE PLAN (ALUP) FOR
THE SAN LUIS OBISPO COUNTY REGIONAL AIRPORT (AIRPORT) FOR A
PROPOSED AMENDMENT TO THE CITY’S AIRPORT AREA SPECIFIC PLAN
(AASP)
RECOMMENDATION
Staff recommends that the ALUC determine that the proposed AASP Amendment is consistent
with the ALUP based on the findings and subject to the conditions of consistency (Attachment
1).
BACKGROUND
City of San Luis Obispo AASP
In recent years, the demand for housing in general, and affordable housing in particular, has
risen dramatically in San Luis Obispo, as it has elsewhere. In response, the City’s 2014 General
Plan Land Use Element update reflects this increased demand, and includes several large areas
for increased residential development. At the same time, the City has tried to address these
issues by supporting mixed-use development, in Service Commercial (C-S) or Manufacturing
(M) designated land by right outside of specific plan areas.
The AASP provides a regulatory framework for planning future development on about 1,200
acres in the southern portion of the City near the San Luis Obispo County Regional Airport. The
AASP does not currently allow mixed-use development, because when it was adopted in 2005,
it was subject to the 2002 San Luis Obispo County Regional Airport’s ALUP that limited
residential and non-residential development. In 2021, the ALUP was amended to address new
technical information related to safety and noise, which resulted in a refinement of areas
subject to land use restrictions, including areas within the AASP. As a result, there is now
substantial area within the AASP where the land use restrictions have changed creating
opportunities for mixed-use developments.
The proposed action responds to the changes in the ALUP and increased housing demand in
an evolving market by amending the AASP to allow for mixed-use development (as defined in
the City’s Municipal Code) with a conditional use permit (CUP) within parcels zoned either
Service Commercial (C-S) or Manufacturing (M), subject to making certain findings described
later in this report.
Page 143 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
2
San Luis Obispo County Regional Airport ALUP
The ALUP for the Airport was initially adopted by the ALUC in December 1973. The plan was
subsequently amended and restated in June 2002, July 2004, and May 2005. The current ALUP,
amended and reinstated May 26, 2021, was recently updated by the ALUC to reflect current
state law and the guidance of the 2011 California Airport Land Use Planning Handbook
revisions, and to reflect updates since 2004 to the airport layout plan, aviation activity forecasts,
and noise contour maps.
DISCUSSION
County staff received the initial referral packet from the City on December 04, 2024. Under
Public Resources Code Section 21676(d), the ALUC must determine whether the Amendments
are consistent or inconsistent with the ALUP within sixty days after the date on which all
required information was received from the referring agency in order t o avoid a default
consistency determination (absent an extension or waiver of the statutory deadline by the
referring agency). The project and applicant appeared before the ALUC for a conceptual
discussion of the project on January 15, 2025. The City provided the additional information
requested by the ALUC and on January 28, 2025, staff determined that all required information
was included with the ALUP amendment application materials and the project was accepted
for processing by staff.
Figure 1: Existing Land Use Designations in the Airport Area Specific Plan
Page 144 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
3
AASP AMENDMENT COMPONENTS
The Project Area includes all parcels designated as Service Commercial (C -S) or Manufacturing
(M) within the 1,200-acre AASP planning area. Figure 1 above shows the location of C-S and M
designated parcels within the AASP.
A land use inventory was prepared in 2024 to determine the amount of C-S or M designated
lands within the AASP. Table 1 below summarizes the total acreage of vacant and developed
parcels in these two land use designations.
Table 1. Summary of Land Use Inventory
C-S and M Parcels in the AASP
Land Use Designation
Acreage
Developed
(or entitled) Vacant Total
Service Commercial (C-S) 140.4 85.6 226.0
Manufacturing (M) 94.7 20.4 115.1
Total 235.1 106.0 341.1
Attachment 2 provides a complete inventory of all parcels within the AASP that are in either
the C-S or M land use designations. Attachment 3 shows the ALUP safety zones as they overlay
the AASP, and specifically how they relate to the C-S and M zones. Attachment 4 shows how
the ALUP noise contours overlay the AASP.
PROPOSED AASP FINDINGS
The City is proposing to amend the AASP to allow mixed-use development within
Manufacturing (M) or Service Commercial (C-S) zoned parcels with the approval of a Conditional
Use Permit (CUP). No development would occur directly as a result of this action. No existing
zoning or land use designations are proposed to change. Instead, the resulting amendment
would allow mixed-use development, subject to specific findings, and consistent with the
requirements of the City’s Zoning Regulations, as they currently apply to C-S and M designated
lands in the remainder of the City.
The specific findings necessary for the City of San Luis Obispo’s Planning Commission to make
in order to approve a conditional use permit for an individual mixed-use project in the AASP
would be:
1. There is demonstrable water and sewer capacity to serve the project;
2. Any fiscal impact of the project to the City must be offset to achieve fiscal
neutrality;
3. There are no nearby uses that generate sufficient air emissions, noise, odors or
vibration to create an incompatibility with proposed mixed-use development;
4. Proposed mixed-use development is consistent with land use, safety or noise
restrictions set forth in the ALUP; and
5. There is adequate emergency response.
Page 145 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
4
Future development under the modified land use requirements could occur as a result of
individual project applications that must be approved by the City of San Luis Obispo through
its normal development and conditional use permit review processes, and subject to
environmental review under the California Environmental Quality Act (CEQA). However, the
magnitude and timing of such development is speculative at this time, and would be influenced
by a variety of issues, including market demand, property owner desire to develop, consistency
with the ALUP, and potential environmental constraints that may apply to specific parcels
where project development applications are under consideration.
PROPOSED AASP TEXT CHANGES
Proposed text modifications to the Airport Area Specific Plan are described below. The existing
AASP is included as Attachment 5 (link only, see Page 14).
Chapter 1—Introduction
Page 1-3. Environmental Review. Add short paragraph following the first paragraph on the
page describing the CEQA review that was conducted for this specific plan amendment.
Page 1-7. The Planning Process. Add a new paragraph at the end of this section that describes
the current planning effort, specifically that residential uses will be permitted as part of mixed
use projects in the Manufacturing (M) and Service Commercial (C-S) Zones subject to the design
and development conditions included in the policy framework of the AASP. The intent is to
recognize the greater extent of developable area and uses that would be allowed under the
updated 2021 Airport Land Use Plan (ALUP), subject to design and density requirements in the
ALUP.
Chapter 2—The Planning Area
No changes proposed.
Chapter 3—Conservation and Resource Management
Page 3-12. Aircraft Operations. Add the following to the end of this section:
“The Airport Land Use Commission adopted a major amendment to the Airport Land Use
Plan on May 26, 2021. The amended ALUP provides for noise contours that are tied to
aircraft and airport activity that is based on adopted federal Terminal Area Forecasts, and
on safety zones that are based on and consistent with those described in the Caltrans
Airport Land Use Planning Handbook. These revised safety areas and noise contours have the
general effect of opening certain areas to higher density development within portions of the
AASP.”
Page 146 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
5
Chapter 4—Land Use
Page 4-2. Land Use Background. Modify the third complete paragraph on Page 4-2 as follows:
“The land use plan was developed to ensure compatibility with airport operations. Uses that
have high concentrations of people or are sensitive to airport noise (e.g., low density
residential, schools, hospitals, etc.) are not included in the planning area. The designated
AASP land uses (Figure 4-1) are consistent with the airport safety areas in the San Luis Obispo
County Regional Airport Land Use Plan (ALUP), as amended in 2021. Generally, the critical
areas in line with the runway centerlines will be maintained as open space. Lower intensity
warehousing, manufacturing, service, business park and mixed-use development are
designated for the less sensitive zones to the sides of the runways, and further out from the
ends of the runways.”
Pages 4-2 and 4-3. Table 4-1, Airport Area Specific Plan Land Use Program and Development
Capacities. Remove Table 4-1 and all references to Table 4-1 in the text of the Specific Plan, as
it is currently out of date, reflects buildout potential based on assumptions made when the
specific plan was first adopted 20 years ago, does not aid in implementing the specific plan, and
with less interest in purely commercial development and the ability to pursue mixed-use
development, any estimate of potential buildout within the area is likely to be inaccurate.
Instead, add a note in this section that includes the following:
“Market factors, environmental constraints, and parcel size and configuration will ultimately
determine the mixed-use development potential (and timing of that development) within
areas where it is permitted with approval of a conditional use permit.”
Page 147 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
6
Table 4-1 as proposed for removal is shown below:
Page 148 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
7
Page 4-23. Table 4-3. Allowed Uses. Amend Table 4-3 to include a line item for Mixed-Use,
indicating that it is allowed with a Conditional Use Permit. Add the following note (# 9) at the
end of the table that refers to the development standards and findings for mixed -use
development within the C-S and M zones. Specific proposed changes to Table 4 -3 are shown
below as underlined text:
Table 4-3 – Allowed Uses
Key: A = Allowed D = Allowed by Administrative Use Permit PC = Allowed by Planning Commission
Use Permit
Land Use
Zoning District
PF C-S M BP
MIXED-USE (also see Footnote 9) PC PC
Footnote:
9. In order to approve a Conditional Use Permit (noted as PC in Table 4-3) for a mixed-use development
in the C-S and M zones, the Planning Commission shall find the project consistent with development
standards outlined in San Luis Obispo Municipal Code Section 17.70.130 (Mixed-use development) and
make the following findings:
1. There is demonstrable water and sewer capacity to serve the project;
2. Any fiscal impact of the project to the City must be offset to achieve fiscal neutrality;
3. There are no nearby uses that generate sufficient air emissions, noise, odors or vibration to
create an incompatibility with proposed mixed-use development;
4. Proposed mixed-use development is consistent with land use, safety or noise restrictions set
forth in the ALUP; and
5. There is adequate emergency response.
Page 4-28. Table 4-5. Building Intensity and Coverage Standards. Amend Table 4-5 to indicate
a maximum Floor Area Ratio (FAR) of 1.5 for the C-S and M zones for mixed use development
in those zones, in order to be consistent with the maximum FAR in C-S and M zones elsewhere
in the City. Specific changes are shown below in underline text.
Table 4-5
San Luis Obispo Airport Area Specific Plan
BUILDING INTENSITY AND COVERAGE STANDARDS
Also See Table 4-6. Limitations on employee and customer concentrations due to airport
safety are more restrictive than the standards provided below in most cases and may reduce
maximum potential FAR.
Design Standard Land Use Designation
Business Park Service
Commercial
Manufacturing
Maximum floor area ratio: mixed-use
development
n/a 1.5 1.5
Page 4-29. Table 4-7. Setback Standards. Add note to this table that setback standards for the
residential component of mixed-use projects in the C-S and M zones must be consistent with
the setback standards as set forth in Sections 17.36 or 17.40 of the Zoning Regulations,
depending on whether the site is in the C-S or M zone.
Page 149 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
8
Page 4-30. Table 4-8. Parking Standards. Add note to this table that parking standards for the
residential component of mixed-use projects in the C-S and M zones must be consistent with
the parking standards for residential uses as set forth in Section 17.72 of the Zoning
Regulations.
Page 4-30. Table 4-9. Building Heights. Add note to this table that building height standards
for the residential component of mixed-use projects in the C-S and M zones must be consistent
with the standards as set forth in Sections 17.36 or 17.40 of the Zoning Regulations, depending
on whether the site is in the C-S or M zone.
Chapter 5—Community Design
Page 5-15. Goal 5.4, Guideline I. Modify as follows:
“In R-3 and R-4 zones, as well as in the residential portions of mixed-use projects, parking
bays and garages shall be placed adjacent to non-residential uses or adjacent to noise
exposure areas to the extent possible to buffer sound impacts.”
Page 5-18. Standard 5.6.2. Modify this standard as follows:
“Each commercial, industrial loading, outdoor recycling or waste collection area shall be
located on the side of a building opposite from parcel lines or street frontages of any land
designated for residential use, or for mixed-use projects, separated or screened from the
residential portion of the project to the extent possible.”
Page 5-38. Table 5-5. Modify the second column of the table to indicate that residential
landscape design standards also apply to mixed use projects.
Chapter 6—Circulation & Transportation
No changes proposed.
Chapter 7—Utilities & Services
No changes proposed.
Chapter 8—Public Facilities Financing
Add a section summarizing an areawide Community Facilities District (CFD) as a feasible
approach to achieving fiscal neutrality for future projects within the specific plan area. Note
that absent a CFD or similar mechanism, fiscal neutrality would need to be achieved on a
project-by-project basis.
Page 150 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
9
Chapter 9—Implementation
Page 9-2. Section 9.4, Architectural Review. Modify this section as follows:
“Consistent with required citywide procedures, commercial, industrial, institutional, mixed-
use and multi family residential construction developments will be subject to architectural
review. For projects subject to architectural review, the “minor or incidental” procedure should be
used for those projects meeting this Specific Plan’s design standards.”
Page 9-3. Section 9.8, Environmental Review. Add discussion to the end of this paragraph
that says that all mixed-use projects within the AASP are subject to project-specific
environmental review as applicable under the California Environmental Quality Act (CEQA).
AASP AIRPORT COMPATIBLE OPEN SPACE
• Policy 4.3.4 Airport Compatible Open Space: The City will work with property owners to
implement and maintain Airport Compatible Open Space (ACOS) within the Airport Area,
consistent with an approved ACOS plan, to ensure ongoing compatibility between Specific
Plan land uses and airport operations. After revision of the AASP, the ACOS shall be amended
to include the open space on Avila Ranch and the Reservation Space.
Analysis: To some extent, the ALUP bases its density standards on whether or not there is an
approved Airport Compatible Open Space (ACOS) plan. However, in the case of Safety Zone 6,
there are no differences in these standards for residential density, as described in Table 4-2 of
the ALUP, included on page 4-17 of that document. For population intensity, there is a limit of
1,200 persons per acre without an ACOS, but no limit with an approved ACOS. Notably, if a
project were built at the City’s maximum density of 24 density units per acre (48 total units that
are 500 square feet or less), and assuming 2.5 persons per unit, that suggests a maximum
residential intensity of about 120 persons per acre. It is unlikely that any non -residential
component of a mixed use project would include more than the remainder allowed without an
ACOS, which would be 1,140 persons per acre. The City will work with property owners to
maintain an ACOS as appropriate, which would ensure consistency with the ALUP’s standards
related to this issue.
ALUP POLICY CONSISTENCY ANALYSIS
The following discussion compares relevant aspects of the ALUP to the proposed amendments
of the City’s AASP, for the purpose of evaluating consistency. The analysis included below
responds to questions raised by the Airport Land Use Commission in its preliminary review of
the project in its January 15, 2025 meeting.
As described below, the proposed changes to the AASP are consistent with the ALUP.
Table 2 compares key standards related to development and density from the AASP to those
in the ALUP. As shown in the table, the maximum residential and population densities that
would be allowed as part of mixed use development within the C-S and M zones would be
substantially less intensive than what could be allowed in Safety Zone 6 under the ALUP, which
is the only safety zone where future mixed use development would be considered.
Page 151 of 214
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AASP AMENDMENT
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10
The City recognizes that the density restrictions within the Safety Zones 1 through 5 are such
that residential uses that are a part of mixed-use projects would not be allowed within these
areas. For this reason, Table 2 does not address the requirements of those safety zones.
Table 2. Comparison of Key Standards of the AASP to the ALUP
Zoning Regulations / AASP Regulations 2021 ALUP Safety Zone 6
Service
Commercial (C-S)
Manufacturing
(M)
Residential
Density
(dwelling units
/ acre)
Mixed Use
Intensity
(persons /
gross acre)
ALUP Land
Use
Compatibility
Table
(ALUP Table 4-
5, pg 4-28)
Density
24 density units per
acre = maximum of 48
front doors (500 SF
units) with an
occupancy of 2.5
people per unit that
would be 120 persons
per acre (in housing)
24 density units per
acre = maximum of 48
front doors (500 SF
units) with an
occupancy of 2.5 people
per unit that would be
120 persons per acre
(in housing)
No Limit with or
without
approved ACOS
(see ALUP Table
4-2, pg 4-17)
No limit with an
approved ACOS
(see ALUP Table
4-2, pg 4-17)
Compatible
uses include:
multi-family
dwellings, single
family, ADUs,
retail sales,
offices, bars,
taverns,
restaurants,
hotels, health
services (mixed-
use is not listed
**).
Coverage
(includes
buildings,
driveways
and parking)
90% (AASP Table 4-5) 90% (AASP Table 4-5)
100% (See ALUP
Table 4-5, pg 4-
28)
100%
Height
(occupied
portions of a
building)
36 feet (AASP Table 4-9) 36 feet (AASP Table 4-9)
409 feet mean
sea level (ALUP
pg 4-36)
409 feet mean
sea level (ALUP
pg 4-36)
Height (non-
occupied
architectural
features)
46 feet (AASP Table 4-9) 46 feet (AASP Table 4-9)
409 feet above
mean sea level
(ALUP pg 4-36) *
409 feet above
mean sea level
(ALUP pg 4-36) *
FAR 1.5 is proposed for
mixed use
1.5 is proposed for
mixed use
N/A N/A
* The typical surface elevation in the AASP ranges between 150 and 200 feet above sea level, so these policies would potentially allow
building heights that exceed 200 feet.
** Mixed use is defined on page 4-14 of the ALUP: Mixed-use development/ mixed-use land use – projects which consist of and will result
in establishment of structures intended and used both for commercial purposes, and for human habitation. A project which incl udes both
commercial and residential components will be considered as a mixed-use development or land use regardless of whether the commercial
and residential components are contained within single structures or are separated into individual structures.
Page 152 of 214
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ALUC FEBRUARY 19, 2025
11
ANALYSIS OF KEY RELEVANT ALUP POLICIES
General Land Use Policies
ALUP policies G-1 through G-4 establish the criteria related to land use to evaluate consistency
with the ALUP. This section evaluates the proposed AASP amendment’s consistency with each
policy, which “form the basis from which the ALUC will evaluate proposed land use actions
and airport-related actions.”
• Policy G-1: A proposed project or local action will be determined to be inconsistent with the
ALUP if the information required for review of the proposed action is not provided by the
referring agency.
Analysis: The City has provided all necessary documentation related to the proposed
amendment to the AASP.
• Policy G-2: A proposed project or local action will be determined to be inconsistent with the
ALUP if the ALUC finds that the action would present specific incompatibilities to the
continued economic vitality and efficient operation of the Airport with respect to safety, noise,
overflight or obstacle clearance.
Analysis: As proposed, the amendments to the AASP do not appear to present any
incompatibilities with the continued economic vitality and efficient operation of the
Airport with respect to safety, noise, overflight or obstacle clearance based on the
Airport’s current configuration or forecasts. However, the draft Airport Master Plan
pending FAA review includes a proposal to shift Runway 11-29 endpoints 740 feet to the
northwest. This could create a potential conflict in the future should development be
approved and constructed in the limited areas where a shift in the main runway would
cause a change in allowable density limitations and potential increase in incompatible
development. The ALUC may want to provide direction to City staff regarding whether
courtesy notice is requested for any future development that may be proposed in the
affected areas while the Airport Master Plan remains pending before the FAA. Additional
discussion is also provided below related to noise.
• Policy G-3: Except as provided in Policy G-4, a proposed project or local action will be
determined to be inconsistent with the ALUP if the proposal is not in conformance with all
applicable Specific Land Use Policies. In the event that the site affected by a proposed project
or local action is located in more than one noise exposure area or aviation safety area, the
standards for each such area will be applied separately to the land area lying within each
noise or safety zone.
Analysis: As proposed, the amendment to the AASP conforms with this policy. Crucially,
many affected parcels overlay more than one ALUP Safety Zone (see Attachment 3) or
noise contour (see Attachment 4). As clearly described in Policy G-3, “the standards for
each such area will be applied separately to the land area lying within each noise or safety
zone.” Thus, if part of a given parcel is overlaid by Safety Zone 6, with the remainder in
Safety Zone 4, a mixed-use project would have to apply differing standards to the
different portions of the parcel.
Page 153 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
12
• Policy G-4: When the site affected by a proposed project or legislative action is located in
more than one noise exposure area or aviation safety area, the ALUC may, at its sole
discretion, elect not to apply the requirements of Policy G-3 if:
i. The total gross area(s) within the more restrictive area(s) is two (2) acres or less, and
ii. The land area(s) within the more restrictive area(s) is less than 50% of the total gross
land area affected by the referred project or local action.
In such cases, the ALUC may elect to apply the least-restrictive land use or noise policies to
the entire site affected by the project or local action. The ALUC must adopt specific findings
that the proposed project or location, so considered would not result in the potential
development of land uses incompatible with current or future airport operations.
Analysis: The City is not requesting any deviation from the requirements of Policy G-3,
but instead is intending to abide by those requirements as individual development
projects are proposed. However, if ALUC is open to considering the flexible standards
set forth in Policy G-4 on a project-by-project basis, the City has indicated it would not
object.
Noise Policies
As shown in Attachment 4, the majority of the C-S and M zones where mixed use would be
allowed fall outside of the 60 CNEL noise contour shown in the ALUP Figure 4-1, and nearly all
of the area would be outside the 65 CNEL contour.
• Section 2.10.1: Limitation of the ALUP; Existing Land Use of the ALUP states:
Redevelopment of residential land uses shall not be precluded because of location with
respect to Airport CNEL noise contours, but such redevelopment may not increase the number
of residential units located inside the 60 dB CNEL noise contour and the desig n and
construction of all new dwelling shall be adequate to mitigate noise impacts in accordance
with Section 4.3.3 of this ALUP.
Analysis: ALUP Policies N-1 through N-5 provide the criteria related to noise exposure
for which development projects need to comply in order to be found consistent with the
ALUP. The City intends to comply with these policies in its review of subsequent and
applicable development projects, as they are also part of the City’s regulatory
framework. Any mitigation required to address identified noise impacts would be based
on direction set forth in Section 4.3.3 of the ALUP. In addition, as conditioned, mixed use
development would only be allowed within Safety Zone 6 which would result in all mixed
use development being located outside of the 60 dB CNEL noise contour.
Page 154 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
13
Safety Compatibility, Airspace Protection, and Overflight Protection Policies
The ALUP includes several related policies that address safety compatibility, airspace protection
and overflight protection.
• Section 4.4.5 of the ALUP includes safety-related policies intended to ensure land use
compatibility with ongoing airport operations, minimizing risk to both lives and
property. Policies S-1, S-2 and S-3 collectively set forth criteria for determining land use
compatibility, with specific references to Table 4-2 and 4-5 in the ALUP, which define
maximum densities within various Safety Zones, and type of land uses allowed in those
zones.
As described in Table 2 above, mixed-use development that would be allowed would
conform with ALUP density restrictions. Within Safety Zone 6, maximum allowed
densities far exceed those that would be allowed under the City’s mixed-use zoning
provisions. Within all other safety zones, the ALUP includes density requirements that
are more restrictive than what would be allowed under the City’s mixed -use zoning
policies. However, the City’s intent is to ensure consistency with the ALUP, and for that
reason it would not consider mixed-use development in any safety zone except Safety
Zone 6.
• Section 4.5.4 includes Policies A-1, A-2, A-3 and A-4, which collectively address specific
land use types or structures that could pose potential airspace incompatibility.
Specifically, these policies refer to new structures, landscaping, landfills, and wetland
creation. As described above, mixed-use development and associated
landscape/hardscape improvements would be consistent with land use requirements
within Safety Zone 6. The City’s proposed change to the AASP would not allow for the
development of landfills, nor does it contemplate wetland creation.
• Section 4.6.3 includes Policies O-1 and O-2, which collectively require that those
owning or living on properties within the airport area are informed of ongoing airport
operations, and that avigation easements be recorded on affected properties. Future
development pursuant to the City’s proposed change to the AASP would be subject to
those policies.
Analysis: The City is not requesting any deviation from the requirements of any safety,
airspace protection of overflight policies in the ALUP. As proposed, the amendments to
the AASP conform with these policies. Future development pursuant to the City’s
proposed change to the AASP would be subject to, and consistent with, those policies.
Page 155 of 214
CITY OF SAN LUIS OBISPO
AASP AMENDMENT
ALUC FEBRUARY 19, 2025
14
CEQA COMPLIANCE
The Final Programmatic EIR for the Airport Area and Margarita Area Specific Plans and Related
Facilities Master Plans (“Final EIR”, or “AASP Final EIR”) addressed future development within
the Airport Area Specific Plan. The Final EIR was certified in September 2003, and has provided
the basis for evaluating the impacts of future development within the AASP area. Subsequent
amendments to the AASP were subject to separate CEQA evaluations to address the potential
impacts stemming from those amendments.
Section 15164 of the State CEQA Guidelines allows a lead agency to prepare an addendum to a
Final EIR when only “minor technical changes or additions” are necessary to address the effects
of a minor change to the approved project since the Final EIR was certified. An Addendum to
the certified Final EIR has been prepared to address the proposed changes to the AASP, and is
included as Attachment 6. An Addendum need not be circulated for public review (CEQA
Guidelines 15164(c)).
The County of San Luis Obispo Airport Land Use Commission conducted an Initial Study and
prepared a Negative Declaration for the 2021 update of its Airport Land Use Plan (ALUP) (SCH:
2021030474). That environmental document was used to substantively inform the conclusions
contained in the Addendum.
Individual projects that may be proposed under the AASP as amended would be subject to
review under the California Environmental Quality Act (CEQA) as appropriate on a project -by-
project basis.
RECOMMENDATION
Staff recommends that the ALUC review all materials related to the proposed amendment to
the Airport Area Specific Plan in conjunction with the Airport Land Use Plan and provide a
determination of consistency.
ATTACHMENTS
Attachment 1: Findings and Conditions of Consistency
Attachment 2: Summary of Parcels Affected
Attachment 3: ALUP Safety Zones Overlaying the AASP
Attachment 4: ALUP Noise Contours Overlaying the AASP
Attachment 5: Airport Area Specific Plan (Existing)
Included by digital link only at:
https://www.slocity.org/home/showpublisheddocument/4294/637493456364330000
Attachment 6: Addendum to the Certified Final EIR
Page 156 of 214
FINDINGS AND CONDITIONS OF CONSISTENCY
CITY OF SLO AASP AMENDMENT
ALUC FEBRUARY 19, 2025
FINDINGS
1. The Amendments are consistent with General Land Use Policies G-1 through G-4
because: all information required for review of the Amendments was provided by the
City; the Amendments (as conditioned) would not result in any incompatibilities to
the continued economic vitality and efficient operation of the Airport with respect to
safety, noise, overflight or obstacle clearance; and since some of the lots affected by
the Amendments are located in more than one noise exposure area or Aviation Safety
Zone, the standards for each such area will be applied separately to the land area
lying within each noise counter or safety area unless the project is specifically
reviewed by the ALUC and it elects at its sole discretion not to apply the requirements
of the more restrictive zone in accordance with Policy G-4 of the ALUP;
2. The Amendments are consistent with the Noise Compatibility Policies N-1 through N-
5 because the area affected by the Amendments is located outside the 60 dB CNEL
contour and development of any extremely or moderately noise-sensitive uses are
allowable and shall meet the requirements of interior noise levels specified in Table
4-1 and Section 4.3.3 of the ALUP;
3. The Amendments are consistent with the Safety Compatibility Policies S-1 through S3
because the Amendments only modify allowable uses within Safety Zone 6 and would
not result in a density greater than that specified in Table 4-2; the Amendments would
not result in a greater building coverage than permitted by Table 4-3; and the
Amendments would not result in land uses other than specified in Table 4-5;
4. The Amendments are consistent with the Airspace Protection Policies A-1 through A-
4 because the Amendments (as conditioned), existing City regulations, and distance
from the Airport will ensure no structure, landscaping, apparatus, or other feature
will create an obstruction or hazard to air navigation, do not propose new landfill or
other disposal site, will ensure no structure, landscaping, apparatus, or other feature
will create a wildlife attractant, and does not propose the creation of new or restored
wetlands;
Attachment 1
Page 1 of 3
Page 157 of 214
5. The Amendments are consistent with the Overflight Protection Policies O-1 through
O-2 because the Amendments have been conditioned to require avigation easements
be recorded for each property developed within the Project site prior to the issuance
of any building permit or land use permit; and all owners, potential purchasers,
occupants (whether as owners or renters), and potential occupants (whether as
owners or renters) to receive full and accurate disclosure concerning the noise, safety,
or overflight impacts associated with Airport operations prior to entering any
contractual obligation to purchase, lease, rent, or otherwise occupy any property or
properties within the Airport Area;
CONDITIONS
1. The City shall ensure that all applicable ALUP policies and aviation related
development restrictions are enforced.
2. Utilizing the ALUP’s California Building Code (CBC) calculation method (Figure 4-3), the
Amendments shall limit mixed use density/ intensity for applicable property within
the AASP planning area designated C-S and M as follows:
a. The maximum average density/ intensity shall be 300 persons per gross acre
(average across entire site); and
b. The maximum single acre density shall be 1,200 persons per gross acre
(maximum on any single acre).
3. The construction plans for proposed mixed use development that include structures
or other objects that exceed the height standards defined in Title 14 of the Code of
Federal Regulations (CFR) Part 77 as applied to the Airport, shall be submitted via FAA
Form 7460-1 to the Air Traffic Division of the FAA regional office having jurisdiction
over San Luis Obispo County at least 45 days before proposed construction or
application for a building permit, to determine compliance with the provisions of FAR
Part 77.
4. All future mixed-use development shall comply with all noise policies as required by
the ALUP.
5. No structure, landscaping, apparatus, or other feature, whether temporary or
permanent in nature shall constitute an obstruction to air navigation or a hazard to
air navigation, as defined by the ALUP.
Attachment 1
Page 2 of 3
Page 158 of 214
6. Any use is prohibited that may entail characteristics which would potentially interfere
with the takeoff, landing, or maneuvering of aircraft at the Airport, including:
• creation of electrical interference with navigation signals or radio communication
between the aircraft and airport;
• lighting which is difficult to distinguish from airport lighting;
• glare in the eyes of pilots using the airport;
• uses which attract birds and create bird strike hazards;
• uses which produce visually significant quantities of smoke; and
• uses which entail a risk of physical injury to operators or passengers of aircraft
(e.g., exterior laser light demonstrations or shows).
7. Avigation easements shall be recorded for each property developed within the Project
site prior to the issuance of any building permit or land use permit.
8. All owners, potential purchasers, occupants (whether as owners or renters), and
potential occupants (whether as owners or renters) shall receive full and accurate
disclosure concerning the noise, safety, or overflight impacts associated with Airport
operations prior to entering any contractual obligation to purchase, lease, rent, or
otherwise occupy any property or properties within the Airport area.
9. Any residential portion of a mixed-use development within the C-S and M land use
designation within the AASP shall be located wholly within Safety Zone 6.
Attachment 1
Page 3 of 3
Page 159 of 214
Parcels within the C-S or M Designations in the AASP
Site #Parcel Address Total Acres % in SZ 6 Eligible Acres Zoning ALUP Safety Zone Status
1 053-251-068 215 Meissner 10.28 100%10.28 C-S 6/2 vacant
2 053-251-074 237 Vanguard 1.12 100%1.12 C-S 6 vacant
3 053-251-075 229 Vanguard 1.12 100%1.12 C-S 6 vacant
4 053-251-076 250 Tank Farm 1.04 100%1.04 C-S 6 vacant
5 053-251-077 253 Vanguard 1.04 100%1.04 C-S 6 vacant
6 053-251-078 3880 Innovation 1.15 100%1.15 C-S 6 vacant
7 053-251-079 3820 Innovation 1.43 100%1.43 C-S 6 vacant
8 053-251-080 220 Vanguard 0.93 100%0.93 C-S 6/2 vacant
9 053-251-081 260 Vanguard 0.90 100%0.90 C-S 6/2 vacant
10 053-258-025 no address 7.29 100%7.29 M 6 vacant
11 053-258-045 4015 Earthwood 0.26 100%0.26 M 6 vacant
12 053-258-046 4045 Earthwood 0.28 100%0.28 M 6 vacant
13 053-258-049 4120 Earthwood 0.21 100%0.21 M 6 vacant
14 053-258-050 4130 Earthwood 0.21 100%0.21 M 6 vacant
15 053-258-051 4140 Earthwood 0.21 100%0.21 M 6 vacant
16 053-258-052 4150 Earthwood 0.21 100%0.21 M 6 vacant
17 053-258-053 4160 Earthwood 0.21 100%0.21 M 6 vacant
18 053-258-054 4170 Earthwood 0.21 100%0.21 M 6 vacant
19 053-258-055 4180 Earthwood 0.21 100%0.21 M 6 vacant
20 053-258-056 4190 Earthwood 0.21 100%0.21 M 6 vacant
21 053-258-057 4195 Earthwood 0.21 100%0.21 M 6 vacant
22 053-258-058 4185 Earthwood 0.21 100%0.21 M 6 vacant
23 053-258-059 4175 Earthwood 0.21 100%0.21 M 6 vacant
24 053-258-060 4165 Earthwood 0.21 100%0.21 M 6 vacant
25 053-258-061 4155 Earthwood 0.21 100%0.21 M 6 vacant
26 053-258-062 4145 Earthwood 0.21 100%0.21 M 6 vacant
27 053-258-063 4135 Earthwood 0.21 100%0.21 M 6 vacant
28 053-258-064 4125 Earthwood 0.22 100%0.22 M 6 vacant
29 053-259-013 120 Venture 9.20 100%9.20 M 6 vacant
30 053-412-025 1138 Farmhouse 2.53 100%2.53 C-S 6 vacant
31 053-412-026 1130 Farmhouse 2.10 100%2.10 C-S 6 vacant
32 053-412-029 no address 0.96 100%0.96 C-S 6 vacant
33 053-427-004 1095 Farmhouse 1.13 100%1.13 C-S 6 vacant
34 076-381-021 438 Tank Farm 59.93 20%11.99 C-S 1/2/3/6 undeveloped
35 053-257-024 191 Tank Farm 6.78 100%6.78 C-S 6 developed
36 053-257-037 196 Suburban 4.00 100%4.00 M 6 developed
37 053-258-004 131 Suburban 7.06 100%7.06 M 6 developed
38 053-258-005 no address 2.60 100%2.60 M 6 developed
39 053-258-006 117 Suburban 0.15 100%0.15 M 6 developed
40 053-258-007 1 Suburban 3.50 100%3.50 M 6 developed
41 053-258-009 4150 Vachell 4.46 100%4.46 M 6 developed
42 053-258-010 4180 Vachell 1.00 100%1.00 M 6 developed
43 053-258-012 219 Tank Farm 5.99 100%5.99 C-S, M 6 developed
44 053-258-014 240 Suburban 1.80 100%1.80 M 6 developed
45 053-258-015 260 Suburban 1.87 100%1.87 M 6 developed
46 053-258-017 4080 Horizon 3.28 100%3.28 M, C/OS 6 developed
47 053-258-018 225 Suburban 0.55 100%0.55 M 6 developed
48 053-258-023 4115 Horizon 2.08 100%2.08 M, C/OS 6 developed
49 053-258-027 165 Suburban 2.25 100%2.25 M 6 developed
50 053-264-002 4280 Vachell 10.53 100%10.53 C-S 6 developed
51 053-264-003 4313 S. Higuera 1.00 100%1.00 C-S 6 developed
52 053-264-004 4353 S. Higuera 9.11 100%9.11 C-S 6 developed
53 053-422-001 4027 Santa Fe 6.01 85%5.11 C-S, C/OS 6/3 developed
54 053-259-003 115 Venture 9.33 100%9.33 M 6 developed
55 053-264-008 4115 Vachell 0.45 100%0.45 C-S 6 developed
56 053-264-007 4251 S. Higuera 2.25 100%2.25 C-S 6 developed
57 053-258-008 4025 S. Higuera 2.64 100%2.64 C-S 6 developed
58 053-258-003 141 Suburban 2.06 100%2.06 M 6 developed
59 053-258-033 143 Suburban 2.67 100%2.67 M 6 developed
60 053-258-047 4085 Earthwood 0.26 100%0.26 M 6 developed
61 053-258-040 4070 Earthwood 0.32 100%0.32 M 6 developed
62 053-258-041 4090 Earthwood 0.28 100%0.28 M 6 developed
63 053-258-026 181 Suburban 6.17 100%6.17 M 6 developed
64 053-258-024 203 Suburban 7.29 100%7.29 M 6 developed
65 053-258-023 4125 Horizon 2.08 100%2.08 M 6 developed
66 053-258-017 4080 Horizon 3.28 100%3.28 M 6 developed
67 053-258-019 4096 Horizon 0.68 100%0.68 M 6 developed
68 053-258-020 4110 Horizon 0.56 100%0.56 M 6 developed
69 053-258-021 4120 Horizon 0.53 100%0.53 M 6 developed
70 053-258-022 4130 Horizon 0.51 100%0.51 M 6 developed
71 053-257-030 181 Tank Farm 0.87 100%0.87 C-S 6 developed
Attachment 2
Page 1 of 2
Page 160 of 214
72 053-257-040 179 Cross 1.03 100%1.03 C-S 6 developed
73 053-257-043 3981 Steel 0.47 100%0.47 C-S 6 developed
74 053-257-036 170 Suburban 0.45 100%0.45 C-S 6 developed
75 053-257-031 187 Tank Farm 0.90 100%0.90 C-S 6 developed
76 053-257-033 189 Cross 0.63 100%0.63 C-S 6 developed
77 053-257-041 3976 Steel 0.61 100%0.61 C-S 6 developed
78 053-257-042 3980 Steel 0.55 100%0.55 C-S 6 developed
79 053-257-035 174 Suburban 0.50 100%0.50 C-S 6 developed
80 053-257-034 178 Suburban 0.41 100%0.41 C-S 6 developed
81 053-257-024 191 Tank Farm 6.78 100%6.78 C-S 6 developed
82 053-257-039 211 Tank Farm 3.20 100%3.20 C-S 6 developed
83 053-258-011 200 Suburban 1.21 100%1.21 C-S 6 developed
84 053-258-029 253 Tank Farm 7.12 100%7.12 M 6 developed
85 053-258-030 281 Tank Farm 3.86 100%3.86 M 6 developed
86 053-258-031 305 Tank Farm 0.38 100%0.38 M 6 developed
87 053-251-067 202 Tank Farm 2.93 100%2.93 C-S 6 developed
88 053-251-057 202A Tank Farm 0.15 100%0.15 C-S 6 developed
89 053-251-066 202H Tank Farm 0.29 100%0.29 C-S 6 developed
90 053-251-065 202H Tank Farm 0.16 100%0.16 C-S 6 developed
91 053-251-060 202E Tank Farm 0.09 100%0.09 C-S 6 developed
92 053-251-058 202C Tank Farm 0.08 100%0.08 C-S 6 developed
93 053-251-059 202D Tank Farm 0.12 100%0.12 C-S 6 developed
94 053-251-063 202H Tank Farm 0.10 100%0.10 C-S 6 developed
95 053-251-061 202F Tank Farm 0.13 100%0.13 C-S 6 developed
96 053-251-062 202G Tank Farm 0.13 100%0.13 C-S 6 developed
97 053-251-072 224 Tank Farm 4.28 100%4.28 C-S 6 developed
98 053-421-006 600 Tank Farm 6.37 100%6.37 C-S 6 developed
99 053-421-002 600 Tank Farm 5.32 100%5.32 C-S 6 developed
100 053-421-005 650 Tank Farm 12.72 100%12.72 C-S 6 developed
101 053-422-001 4027 Santa Fe 6.01 80%4.81 C-S 6/3 developed
102 053-422-003 615 Tank Farm 2.64 100%2.64 C-S 6 developed
103 053-422-002 635 Tank Farm 2.65 100%2.65 C-S 6 developed
104 053-426-008 696 Clarion 0.88 100%0.88 C-S 6 developed
105 053-422-004 645 Tank Farm 4.89 100%4.89 C-S 6 developed
106 053-426-007 684 Clarion 0.53 100%0.53 C-S 6 developed
107 053-426-006 no address 0.31 100%0.31 C-S 6 developed
108 053-426-005 660 Clarion 0.28 100%0.28 C-S 6 developed
109 053-426-004 648 Clarion 0.32 100%0.32 C-S 6 developed
110 053-426-003 636 Clarion 0.34 60%0.20 C-S 6/5 developed
111 053-426-012 645 Clarion 0.25 50%0.13 C-S 6/5 developed
112 053-426-013 655 Clarion 0.25 100%0.25 C-S 6 developed
113 053-426-014 675 Clarion 0.25 100%0.25 C-S 6 developed
114 053-426-015 685 Clarion 0.24 100%0.24 C-S 6 developed
115 053-426-016 695 Clarion 0.41 100%0.41 C-S 6 developed
116 053-426-017 648 Clarion 4.40 60%2.64 C-S 6/5 developed
117 053-423-017 4075 Santa Fe 6.70 25%1.68 M 2/3/5/6 developed
118 053-412-024 1146 Farmhouse 5.08 100%5.08 C-S 6 developed
119 053-427-001 1025 Farmhouse 1.18 98%1.16 C-S 6/4 developed
120 053-427-002 1051 Farmhouse 1.07 100%1.07 C-S 6 developed
121 053-427-003 1075 Farmhouse 1.07 100%1.07 C-S 6 developed
122 053-427-005 1133 Farmhouse 1.19 100%1.19 C-S 6 developed
123 053-427-027 1167 Farmhouse 1.12 100%1.12 C-S 6 developed
124 053-427-026 1193 Farmhouse 1.33 100%1.33 C-S 6 developed
125 053-427-028 no address 1.36 50%0.68 C-S 6/4 developed
126 053-427-008 1250 Kendall 2.51 100%2.51 C-S 6 developed
127 053-427-014 1275 Prospect 1.79 100%1.79 C-S 6 developed
128 053-427-015 1251 Prospect 1.49 100%1.49 C-S 6 developed
129 053-427-009 1201 Prospect 2.24 98%2.20 C-S 6/4 developed
130 053-427-018 1255 Kendall 2.53 95%2.40 C-S 6/4 developed
131 053-427-017 1200 Prospect 1.32 90%1.19 C-S 6/4 developed
132 053-427-023 1220 Kendall 1.28 70%0.90 C-S 6/4 developed
Attachment 2
Page 2 of 2
Page 161 of 214
Ta n k Farm
South Higuera Tank Farm
I n d u s t r i a l
Hoover
F i e r o
A e r o
Lo
n
g
Granada
Suburban
Va
c
h
e
l
l
Buckley Buckley
S a n ta F e
A e r o v is t a
PoinsettiaClarion
MM
M
M
M
C-SC-S C-S
C-S
M
M
C-S
C-S
C-S
C-SC-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
M
M
C-S C-S
C-S
C-SC-S
C-S
C-S
C-S
Airport Area Specific Plan (AASP)
Airport Safety Zones
µ
0 0.5 10.25 Miles
Airport Area Specific Plan
City Limit
Zoning
Service Commercial (C-S)
Manufacturing (M)
Airport Safety Zones
Zone 1: Runway Protection Zone
Zone 2: Inner Approach/Departure Zone
Zone 3: Inner Turning Zone
Zone 4: Outer Approach/Departure Zone
Zone 5: Sideline Zone
Zone 6: Traffic Pattern Zone SLOGIS
January 2025
Attachment 3
Page 162 of 214
Airport Area Specific Plan (AASP)
Airport Noise Contours
SLOGIS
January 2025
Ta n k Farm
South Higuera Tank Farm
I n d u s t r i a l
Hoover
F i e r o
A e r o
Lon
g
Granada
Suburban
Va
c
h
e
l
l
Buckley Buckley
S a n ta F e
A e r o v is t a
PoinsettiaClarion
MM
M
M
M
C-SC-S C-S
C-S
M
M
C-S
C-S
C-S
C-SC-SC-S
C-S
C-S
C-S
C-S
C-SC-S
C-S
C-S C-S
C-S
C-SC-S
C-S
M
M
C-S C-S
C-S
C-SC-S
C-S
C-S
C-S
0 1 20.5 Miles
µ
Airport Area Specific Plan
City Limit
Zoning
Service Commercial (C-S)
Manufacturing (M)
Noise Contour Levels
60 dB CNEL
65 dB CNEL
70 dB CNEL
75 dB CNEL
Attachment 4
Page 163 of 214
1
Addendum to the Final Programmatic Environmental Impact Report for the
Airport Area and Margarita Area Specific Plans and Related Facilities
Master Plans
1. Project Title:
Airport Area Specific Plan Amendment to Allow Mixed-Use Development in the Service
Commercial (C-S) and Manufacturing (M) zones subject to the approval of a conditional
use permit
2. Lead Agency Name and Address:
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
3. Contact Person and Phone Number:
Rachel Cohen, Principal Planner
805-781-7574
4. Project Location:
Airport Area Specific Plan area, generally bounded by South Higuera Street to the west,
Meissner Lane to the north, Broad Street to the east, and Buckley Road to the south, in
San Luis Obispo, CA
5. Project Applicant and Representative Name and address:
City of San Luis Obispo
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401
6. General Plan Designation:
Services & Manufacturing
7. Zoning:
Service Commercial (C-S) and Manufacturing (M)
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8. Description of the Project:
The Airport Area Specific Plan (AASP) is a land use program with policies, goals,
guidelines and infrastructure financing strategies to guide future development to ensure
land use compatibility within the AASP planning area. The AASP was adopted in 2005
and has been amended several times since then in response to changing conditions or
opportunities unforeseen at the time of its adoption. The proposed project would amend
the AASP to allow for mixed-use development (as defined in the City’s Municipal Code)
with a conditional use permit within parcels designated as either Service Commercial (C-
S) or Manufacturing (M).
The AASP does not currently allow mixed-use development. The underlying reason for
this was because of the area’s proximity to the San Luis Obispo County Airport, and the
established safety and noise areas that limited or prohibited noise sensitive residential
uses or high density residential development. The southern portion of the City at that time
was also viewed as the area most appropriate for industrial uses. In 2021, the San Luis
Obispo County Airport Land Use Commission (ALUC) amended and restated the Airport
Land Use Plan (ALUP) to address new technical information related to safety and noise,
which resulted in a refinement of areas subject to land use restrictions under the ALUP,
including areas within the AASP. As a result, there is now substantial area within the AASP
where the land use restrictions have changed related to airport safety and noise, and
creates opportunities for mixed-use developments.
No development would occur directly as a result of this action, which is simply a
modification of existing land use requirements under the AASP. Future development
under the modified land use requirements could occur as a result of individual project
applications that must be approved by the City of San Luis Obispo through its normal
development and conditional use permit review processes. However, the magnitude and
timing of such development is speculative at this time, and would be influenced by a
variety of issues, including market demand, property owner desire to develop,
consistency with the ALUP, and potential environmental constraints that may apply to
specific parcels where project development applications are under consideration.
The Project Area includes all parcels designated as Service Commercial (C-S) or
Manufacturing (M) within the 1,200-acre AASP planning area. Figure 1 shows the location
of C-S and M designated parcels within the AASP.
9. Project Entitlements Requested:
No project-level entitlements are requested or would occur as a result of this action.
Instead, the resulting amendment would allow mixed-use development, subject to specific
findings, with a conditional use permit in portions of the Airport Area Specific Plan
currently designated as Service Commercial (C-S) and Manufacturing (M), consistent with
the requirements of the City’s Zoning Regulations, as they currently apply to C-S and M
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designated lands in the remainder of the City. The reason this amendment is necessary
is because as currently written, the AASP does not allow mixed-use development.
Figure 1: Existing Land Use Designations in the Airport Area Specific Plan
Development under the modified land use requirements would result from individual
project applications that must be approved by the City of San Luis Obispo through its
normal development and conditional use permit review processes. Proposed
modifications to the Airport Area Specific Plan are described below in detail under the
heading “New Information and Updated Project Elements.”
10. Previous Environmental Review:
The Final Programmatic EIR for the Airport Area and Margarita Area Specific Plans and
Related Facilities Master Plans (“Final EIR”, or “AASP Final EIR”) addressed future
development within the Airport Area Specific Plan. The Final EIR was certified in
September 2003, and has provided the basis for evaluating the impacts of future
development within the AASP area. Subsequent amendments to the AASP were subject
to separate CEQA evaluations to address the potential impacts stemming from those
amendments. In a similar manner, the analysis in this Addendum tiers from the original
Final EIR.
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Individual projects that may be proposed under the AASP as amended would be subject
to review under the California Environmental Quality Act (CEQA) as appropriate on a
project-by-project basis.
The County of San Luis Obispo Airport Land Use Commission conducted an Initial Study
and prepared a Negative Declaration for the 2021 update of its Airport Land Use Plan
(ALUP) (SCH: 2021030474). That environmental document was used to inform the
conclusions contained in this addendum.
11. Purpose of the Addendum:
Section 15164 of the State CEQA Guidelines allows a lead agency to prepare an
addendum to a Final EIR when only “minor technical changes or additions” are necessary
to address the effects of a minor change to the approved project since the Final EIR was
certified. In addition, the lead agency is required to explain its decision not to prepare a
subsequent EIR pursuant to State CEQA Guidelines Section 15162, which requires
subsequent EIRs when proposed changes would require major revisions to the previous
EIR “due to the involvement of new significant environmental effects or a substantial
increase in the severity of previously identified significant effects.”
Subsequent to certification of the AASP Final EIR, additional information has been
identified which provides a more consistent Citywide approach to mixed-use
development, specifically as it is allowed in the C-S and M zones. In 2021, the San Luis
Obispo County Airport Land Use Commission (ALUC) updated its Airport Land Use Plan
(ALUP) to address new technical information related to safety and noise, which resulted
in a refinement of areas subject to land use restrictions under the ALUP and has created
opportunities for mixed-use developments within the AASP. The proposed action requires
an amendment to the AASP to allow for mixed-use in the C-S and M zones subject to a
Conditional Use Permit. This project is described in more detail in subsequent sections of
this EIR Addendum.
The purpose of this Addendum is to document the proposed change to the AASP, and to
confirm that this change would not result in any new or more severe significant
environmental effects not previously analyzed in the Final EIR, and would not modify any
existing mitigation requirements described in that document.
The evaluation below discusses the issue areas that are relevant to this Addendum and
covered by the previously approved Final EIR. The evaluation concludes that no new
environmental effects are created and that there is no increase in the severity of
previously identified significant effects.
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12. Addendum Requirements:
Pursuant to Section 21166 of CEQA and Section 15162 of the State CEQA Guidelines,
when a lead agency has adopted an EIR for a project, a subsequent EIR does not need
to be prepared for the project unless the lead agency determines that one or more of the
following conditions are met:
1. Substantial project changes are proposed that will require major revisions of the
previous EIR due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects;
2. Substantial changes would occur with respect to the circumstances under which the
project is undertaken that require major revisions to the previous EIR due to the
involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; or
3. New information of substantial importance that was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR
was adopted shows any of the following:
a. The project will have one or more significant effects not discussed in the
previous EIR; or
b. Significant effects previously examined will be substantially more severe than
identified in the previous EIR; or
c. Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects
of the project, but the project proponent declines to adopt the mitigation
measures or alternatives; or
d. Mitigation measures or alternatives that are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponent declines to adopt the
mitigation measures or alternatives.
Preparation of an Addendum to an EIR is appropriate when none of the conditions
specified in Section 15162 (above) are present and some minor technical changes to the
previously certified EIR are necessary to address minor changes to an approved project.
Because the new information would not result in any new or more severe significant
impacts, an Addendum is the appropriate CEQA document.
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CURRENT REGULATORY FRAMEWORK FOR C-S AND M ZONES
San Luis Obispo County Airport Land Use Plan
Mixed-use development was not originally allowed at the time of the AASP’s adoption in 2005
because of the area’s proximity to the San Luis Obispo County Airport, and the established
safety and noise areas that limited or prohibited noise sensitive residential uses or high density
residential development. The southern portion of the City at that time was also viewed as the
area most appropriate for industrial uses. In 2021, the San Luis Obispo County Airport Land
Use Commission (ALUC) updated its Airport Land Use Plan (ALUP) to address new technical
information related to safety and noise, which resulted in a refinement of areas subject to land
use restrictions under the ALUP, including areas within the AASP. As a result, there is now
substantial area within the AASP where the land use restrictions have changed related to airport
safety and noise and creates opportunities for mixed-use developments..
Current AASP Requirements
For the reasons described above related to the ALUP, the AASP does not currently allow mixed-
use development in either the Service Commercial (C-S) or Manufacturing (M) zones. As stated
in Section 4.2.2 of the AASP, “areas designated Service Commercial are generally for storage,
transportation, and wholesaling type uses, as well as certain retail sales and business services
that may be less appropriate in other commercial designations.” Similarly, Section 4.2.3
summarizes the intent of the Manufacturing designation as areas “for assembly, fabrication,
storage and distribution, and sales and service type uses that have little or no direct trade with
local consumers.”
Table 4-3 of the AASP shows the allowed uses within each land use designation. Mixed-use is
not allowed under either designation.
Other Relevant Regulatory Setting
There is an existing regulatory framework for allowing mixed-use in non-residential zones
Citywide. Mixed-use development is allowed in the C-S and M zones in all parts of the City
except within the AASP and other specific plan areas. Within both designations, the Zoning
Regulations allow for residential development up to 24 density units per acre (Municipal Code
Sections 17.36.020 and 17.40.020).
Final Environmental Impact Report
The 2003 Final EIR examined the policy framework and conceptual development under the
AASP at a programmatic level. That document did not include project-specific analysis of the
parcels potentially impacted by the proposed action. The FEIR impact analysis was general,
and any required mitigation for key issue areas was programmatic, in consideration of cumulative
development that might occur under the AASP. Please refer to the section below entitled
“Analysis Of The Proposed Project In The Context Of The Final EIR” for further discussion of
relevant issues and how they relate to the proposed Specific Plan Amendment
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NEW INFORMATION AND UPDATED PROJECT ELEMENTS
NEWLY DISCOVERED INFORMATION
In recent years, the demand for housing in general, and affordable housing in particular, has
risen dramatically in San Luis Obispo, as it has elsewhere. In response, the City’s 2014 General
Plan Land Use Element update reflects this increased demand, and includes several large areas
for increased residential development, projects that have since been approved and are in the
process of being completed. At the same time, the City has tried to address these issues by
supporting mixed-use development, in areas where demand for non-residential development in
Service Commercial or Manufacturing designated land has declined. The result is that the City
allows mixed-use by right in the C-S and M zones outside the AASP. However, the AASP does
not allow mixed-use development, because of previous safety and noise restrictions included in
the ALUP. As described above, the 2021 update of the ALUP removed those restrictions that
limited or prohibited mixed-use development.
The proposed project responds to the changes in the ALUP and increased housing demand in
an evolving market by allowing for mixed-use development in the C-S and M land use
designations in the AASP with the approval of a conditional use permit.
As discussed previously, the underlying reason why mixed-use development was not allowed in
the AASP is because of the area’s proximity to the San Luis Obispo County Airport, and safety
and noise conflicts that could arise if residential development were allowed. In 2021, the San
Luis Obispo County Airport Land Use Commission (ALUC) updated its Airport Land Use Plan
(ALUP) to address new technical information related to safety and noise, which resulted in a
refinement of areas subject to land use restrictions under the ALUP, including areas within the
AASP. As a result, there is substantial area where the land use restrictions have changed related
to airport safety and noise.
CHANGED BASELINE CONDITIONS AND UPDATED PROJECT ELEMENTS
The proposed project would amend the AASP, modifying various aspects of the plan in order to
facilitate mixed-use development with approval of a conditional use permit in the C-S and M land
use designations. It would not change any existing land use designation, nor would it result in
more or less land designated as either C-S or M. Instead, it would modify existing language and
tables in various parts of the existing AASP in order to facilitate mixed-use within these land use
designations.
A detailed land use inventory was prepared in 2024 to verify the amount of C-S or M designated
lands within the planning area. Table 1 below summarizes the results of the 2024 land use
inventory for each designation, showing the total acreage of vacant and developed parcels in
these two land use designations.
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Table 1. Summary of 2024 Land Use Inventory
C-S and M Parcels in the AASP
Land Use Designation
Acreage
Developed
(or entitled)
Vacant Total
Service Commercial (C-S) 140.4 85.6 226.0
Manufacturing (M) 94.7 20.4 115.1
Total 235.1 106.0 341.1
Portions of land designated as either C-S or M are constrained from considering mixed-use
development. Some of this constrained area remains within airport land use safety zones under
the ALUP that do not allow for residential uses. Other parcels are too small or configured in such
a way to make development challenging. Depending on the location, a variety of environmental
constraints could present other challenges, including drainage features, steep slopes, or the
potential for sensitive biological or cultural resources. Some parcels are adjacent to existing
industrial land uses that produce odors or noise, which could make them less attractive for mixed-
use development. Finally, many of these parcels are already developed with other uses, or are
entitled for development. It is likely that only a few of these more constrained parcels will
eventually support mixed-use development.
There is no specific mixed-use development project proposed at this time, but the amendment
would allow the City to process and potentially approve applications that propose such
development. However, the magnitude and timing of such development cannot be known at this
time, and would be influenced by a variety of issues, including market demand, property owner
desire to develop, and potential environmental constraints that may apply to specific parcels
where project development applications are under consideration. For these reasons, it is
speculative to determine what the residential buildout potential of this action is at this time, or
how it might alter the non-residential buildout assumptions made in the AASP.
If mixed-use development were to occur, it would be based on the maximum density currently
allowed under the Zoning Regulations, which is 24 density units per acre.
ANALYSIS OF THE PROPOSED PROJECT IN THE CONTEXT OF THE FINAL EIR
The updated project elements described above were not considered in the 2003 Final EIR, and
so are analyzed here. The 2003 Final EIR examined the policy framework and conceptual
development under the AASP at a programmatic level, which is also appropriate for the currently
proposed Specific Plan Amendment. The following analysis examines the proposed project
based on relevant issues from the 2003 Final EIR, with references to FEIR impact statements
as appropriate. Implementation of the proposed project would not change any of the conclusions
in the Final EIR, the level of significance or severity of any previously identified impact, or
introduce any new mitigation measures. No changes to the Final EIR are required.
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Land Use
The FEIR identifies the following land use impacts that are relevant to the proposed Specific
Plan Amendment. As discussed in Impact LU-3, the Final EIR found the AASP was consistent
with the ALUP in effect at the time of adoption of the AASP. No significant impacts were
identified, and no mitigation was required. The Specific Plan amendment would allow for mixed-
use development with approval of a conditional use permit, subject to potential constraints
contained in the 2021 ALUP update. The County’s environmental document for the 2021 update
(SCH 2021030474) concluded that there would be no land use impacts or hazards associated
with allowing more intensive development in the AASP, or mixed-use or residential projects in
the ALUP area if development regulations in the ALUP were complied with. Individual
development projects within the AASP would need to be consistent with any land use restrictions
set forth in the ALUP. No new impact would occur.
Impact LU-4 discussed compatibility with surrounding land uses. No conflicts with surrounding
uses were identified in the AASP, so impacts were less than significant, and no mitigation was
required. Individual development projects within the AASP would need to be compatible with
adjacent development, a determination that would be made through development and
conditional use permit review processes and project-specific CEQA analysis for any such future
action. No new programmatic impacts would occur.
Hydrology and Water Quality
Impact H-5 discussed exposure of people and/or property to flood hazards. The FEIR found that
the conversion of land to urban uses has the potential to increase flooding hazards if new
buildings were constructed within the 100-year flood hazard area. However, the specific plan
includes explicit requirements for flood channel improvements that will avoid flooding impacts by
providing enhanced control of floodwaters. This impact was considered less than significant.
Mixed-use development would be evaluated individually under CEQA, and would be required to
comply with existing regulations related to flood hazards and water quality. No new
programmatic impacts would occur, nor would there be an increase in severity of any existing
impact.
Traffic and Circulation
Since the time the AASP FEIR was prepared, CEQA analysis related to this issue has been
modified considerably. The focus of CEQA review is now based primarily on a study of Vehicle
Miles Traveled (VMT), which can have potential impacts on regional air quality and greenhouse
gas emissions. These issues were not examined in the Final EIR.
One purpose of mixed-use development is to reduce commute distances between residences
and work places. In some cases, mixed-use development could make it possible for some
residents to walk to work, which would potentially reduce VMT. In those instances, there would
be a net positive effect on greenhouse gas emissions and air quality relative to what would
otherwise happen under the AASP. Future individual development projects within the AASP
would be evaluated on a case by case basis through a project-specific CEQA analysis. No new
programmatic impacts related to these issues would occur.
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Other transportation issues that were studied in the FEIR related to roadway Levels of Service
(LOS), which is a metric no longer considered in CEQA documents. Instead, these are issues
that would be appropriately addressed through the development and conditional use permit
review processes, with recommendations for potential roadway improvement made through
engineering studies.
Air Quality
The FEIR identified impacts related to both short-term construction emissions and long-term
operations emissions. Short-term construction emissions were found to be significant but
mitigable at a programmatic level, with mitigation taking the form of following a variety of
standard construction management techniques and following the existing regulatory framework
set forth by the Air Pollution Control District (APCD). The impacts of specific development
projects would be analyzed and mitigated as needed on a case by case basis.
Similarly, long-term operational impacts were also found to be less than significant with
programmatic mitigation. The FEIR included the following relevant mitigation measure:
Mitigation Measure AIR-2.1. Implement Growth-Phasing Schedule. The City will
implement a growth-phasing schedule for the Airport area, to assure that nonresidential
development in the urban area does not exceed the pace of residential development.
The consideration of mixed-use development in the Airport Area is consistent with this mitigation
requirement, as it allows for greater flexibility and opportunities to approve residential
development in balance with non-residential development. Future individual development
projects within the AASP would be evaluated on a case by case basis through a project-specific
CEQA analysis. No new programmatic impacts related to this issue would occur.
Noise
The FEIR examined relevant programmatic impacts related to traffic and aircraft noise, but found
them to be less than significant. For aircraft noise, this was because future development under
the AASP was determined to be consistent with the ALUP. For traffic noise, it was determined
that the City’s General Plan Noise Element included sufficient implementation requirements and
strategies to ensure that noise would be mitigated on a project-by-project basis as appropriate,
through the recommendations of project-specific noise studies. Future individual development
projects within the AASP would be evaluated on a case by case basis through a project-specific
CEQA analysis. The County’s environmental document for the 2021 update (SCH 2021030474)
concluded that there would be no noise impacts or hazards associated with allowing more
intensive development in the AASP, including mixed-use or residential projects in the ALUP
area, if development regulations in the ALUP were complied with. No new programmatic
impacts related to this issue would occur.
Public Services and Utilities
The FEIR examined potential programmatic impacts related to the provision of water and
wastewater services from buildout under the AASP, but concluded these would be less than
significant because projects would be required to follow the regulatory provisions included in the
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General Plan, AASP and relevant utilities master plans. Similarly, programmatic impacts related
to storm drainage were considered less than significant because projects would be required to
follow the provisions of the Storm Drain Master Plan. Impacts related to solid waste disposal
were also considered less than significant, as projects would be required to follow regulatory
provisions included in the General Plan and AASP.
Impacts related to law enforcement were considered less than significant, as future staffing and
facilities would be addressed through fiscal studies as needed. Impacts to fire protection
services were also considered less than significant with the following mitigation measure:
PS-1. New Fire Protection Personnel. To mitigate the impacts associated with buildout of
the [AASP], a sufficient number of fire protection personnel should be hired to maintain a
ratio of one firefighter for every 1,000 residents.
Determining the appropriate level of public services staff is typically addressed in the City’s
annual budget cycles, with recommendations resulting from studies to service impacts that are
projected to occur based on reasonably foreseeable cumulative development. The proposed
project does not facilitate any specific development project, so the magnitude of potential long-
term impacts to public services is speculative, and would be addressed on a case-by-case basis
as development projects are proposed. No new programmatic impacts related to this issue
would occur.
Impacts to schools were found to be less than significant. Mitigation is limited to the payment of
statutory fees, and no additional school-related impact fees may be imposed above the limits
established in statute (Government Code Section 65595 et seq). No new programmatic impacts
related to this issue would occur.
Impacts to parks and recreation were found to be less than significant, as buildout of the AASP
would not increase demand over the established park service standard of 10 acres per 1,000
residents. The amount of residential development that might occur under the mixed-use
provisions of the project is speculative, and would be limited by a combination of market factors,
property owner desire, lot configuration, and environmental constraints. Impacts to parks and
recreation would be considered on a case by case basis as individual development projects are
proposed. No new programmatic impacts related to this issue would occur.
Other Issues
The proposed project would not introduce new development into areas that were not already
planned for urban uses. Therefore, for all other issues related to resource protection (biological
resources, cultural resources, agricultural resources, and the exposure to hazardous materials),
the potential impact of new development would not change, so the existing impact analysis for
each issue would also remain unchanged. No new programmatic impacts related to these issues
would occur.
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DETERMINATION
In accordance with Section 15164 of the State CEQA Guidelines, the City of San Luis Obispo
has determined that this Addendum to the certified Final EIR is necessary to document changes
or additions that have occurred since the Final EIR was originally certified. Based on the analysis
of the proposed project, no new changes to the Final EIR are required. The proposed project
would not result in any new significant environmental effects or a substantial increase in the
severity of previously identified significant effects. Additionally, no new information of substantial
importance that was not known and could not have been known with the exercise of reasonable
diligence at the time the previous Final EIR was adopted has been identified.
The preparation of a subsequent environmental document is not necessary because:
1. None of the circumstances included in Section 15162 of the CEQA Guidelines have
occurred which require a subsequent environmental document:
a. The project changes do not result in new or substantially more severe
environmental impacts.
b. The circumstances under which the project is undertaken will not require major
changes to the IS/MND.
c. The modified project does not require any substantive changes to previously
approved mitigation measures.
2. The changes are consistent with City General Plan goals and polices that promote
provision of additional housing, particularly affordable housing, within the City.
3. The changes are consistent with City goals related to mixed-use that would encourage
alternative forms of transportation and reduce Vehicle Miles Traveled (VMT), which
relates to reducing air emissions, including greenhouse gas emissions.
The City has reviewed and considered the information contained in this Addendum and finds
that the preparation of subsequent CEQA analysis that would require public circulation is not
necessary. This Addendum does not require circulation because it does not provide significant
new information that changes the adopted Final EIR in a way that deprives the public of a
meaningful opportunity to comment upon a substantial adverse environmental effect of the
project or a feasible way to mitigate or avoid such an effect. The City shall consider this
Addendum with the certified Final EIR as part of the basis for potential approval of the proposed
Specific Plan Amendment.
Attachment 6
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2301 Rosecrans Ave., Suite 4140
El Segundo, CA 90245
TEL: 424-297-1070 | URL: www.kosmont.com
CITY OF SAN LUIS OBISPO
AIRPORT AREA SPECIFIC PLAN (AASP)
FISCAL IMPACT SCENARIO ANALYSIS
AUGUST 2024
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KOSMONT COMPANIES | 2
BACKGROUND & PURPOSE
•The City of San Luis Obispo (“City”) Airport Area Specific Plan (“AASP” or “Specific Plan”) was originally
established to exclude housing development, due to Airport Safety Zone issues.
•In recent years, the County of San Luis Obispo (“County”) has redefined the Safety Zones, resulting in
almost 90% of the Commercial / Services / Manufacturing (“CSM”) zoning area in the AASP to be
considered safe for housing development.
•As a result, property owners have requested City approval for mixed-use housing at densities in the range
of 24 units per acre with nominal commercial development.
•The existing City/County tax sharing agreement specifies a formula for tax sharing within the AASP that is
determined by the zoning at the time of annexation. Importantly, most of the property in the AASP was
annexed as commercial and industrial. The agreement specifies that there will be no or limited property tax
sharing in favor of the City, in consideration of sales tax revenues that were previously shifted to the City
upon annexation, and in anticipation of future sales tax generation by future hypothetical commercial uses.
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KOSMONT COMPANIES | 3
BACKGROUND & PURPOSE (CONTINUED)
•The recently certified Housing Element modified City zoning restrictions to encourage more housing and
the City has expressed interest in understanding how a large portion of the future industrial / commercial
business base will be impacted by more housing in the future, and how this would impact the City’s
General Fund.
•It is important to note that prior zoning (e.g., 2014 Land Use and Circulation Element, or “LUCE”)
reflected assumptions about commercial and industrial land use development that may not reflect current
market and economic conditions.
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SUMMARY OF FINDINGS
•Kosmont has evaluated several different scenarios of land use development within the AASP, including
scenarios that reflect the original 2014 LUCE vision, and scenarios that reflect recent developer interest,
in order to estimate General Fund net fiscal impacts from potential future development.
•While the 2014 LUCE land use scenario (office, retail, industrial with no residential) would achieve an
annual fiscal “surplus” for the City’s General Fund, it is Kosmont’s opinion that the level of office and retail
land uses assumed does not reflect feasibility in consideration of current market and economic conditions
(additionally evidenced in lack of non-residential development over previous 10 years)
•On the other hand, if the remainder of developable land within the AASP is developed entirely consistent
with recent developer interest (higher-density residential with limited commercial components), this
analysis estimated a negative net fiscal impact for the General Fund, driven largely by the tax sharing
agreement that limits the City’s receipt of property tax revenue from new development in this area.
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SUMMARY OF FINDINGS (CONTINUED)
•Kosmont estimates that a likely future AASP land use development scenario would include a mix of uses,
including both “vertically” blended uses (e.g., housing over commercial), as well as “horizontally” blended
uses (e.g., commercial or hospitality behind or adjacent to housing).
•Kosmont’s estimation of a potential market-based, blended-use land use scenario was primarily based on a
combination of demonstrated developer interest within the City, Kosmont previous market supply and
demand analysis in the region, and broader real estate development trends across the State and nationally.
•Assumptions also reflect proposed and approved projects within the AASP, such as approved hotels (~218
rooms) and remaining residential units within Avila Ranch.
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EXAMPLE AASP LAND USE
AND FISCAL IMPACT SCENARIOS
Land Use Assumptions
LUCE 2014
Land Use
Market-Based
Blended Use
Residential - Market Rate 0 DU 2,650 DU
Affordable Housing 0 DU 230 DU
Hotel 0 rooms 218 rooms
Office 900,000 SF 30,000 SF
Commercial / Retail 616,983 SF 158,976 SF
Industrial 747,642 SF 95,000 SF
City of San Luis Obispo Fiscal Impacts
LUCE 2014
Land Use
Market-Based
Blended Use
Estimated Fiscal Revenues $5,352,100 $5,558,400
Estimated Fiscal Expenditures $2,146,800 $7,273,200
Estimated Net Fiscal Impact to City $3,205,300 ($1,714,800)
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FISCAL MITIGATION STRATEGIES
•In order to support long-term fiscal solvency for the City General Fund while not over-prescribing non-
residential uses beyond market and financial feasibility, and while not relying solely on future non-
residential uses which are difficult to predict, Kosmont suggests a fiscal mitigation strategy, including one
or more of the following components:
1.Maintenance / services Community Facilities District (“CFD”), similar to the mechanism utilized for
the Avila Ranch development project within the City (potentially most feasible strategy)
2.Renegotiation of the Property Tax Sharing Agreement with the County
3.Infrastructure Financing District negotiation with the County (as a backup to #2 above)
4.Minimum commercial use requirements for residential projects
•While Strategy #1 above (maintenance CFD) may be the most feasible to implement, advantages and
disadvantages of each strategy listed above are discussed on the following pages.
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KOSMONT COMPANIES | 8
1) MAINTENANCE / SERVICES CFD
•A CFD could be employed instead or in addition to other fiscal mitigation options, such as renegotiation
of the Property Tax Sharing Agreement or imposing commercial use requirements.
•Kosmont estimates that the range of CFD special tax required to achieve “fiscal neutrality” within a likely
future AASP land use development scenario ($600-$1,000 per residential unit per year) is within
acceptable ranges for the residential real estate market, consistent with CFD implementation elsewhere in
the State, and generally consistent with the existing Avila Ranch CFD within the City.
•Maintenance CFDs require 2/3 voter approval, and are sometimes arranged to be “annexable” in nature,
such that certain types of projects (e.g., residential or blended use) are conditioned to approve annexation
into the maintenance CFD.
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KOSMONT COMPANIES | 9
2) RENEGOTIATION OF THE PROPERTY TAX SHARING
AGREEMENT WITH THE COUNTY
•The City may be able to renegotiate the property tax sharing agreement with the County as it pertains to
certain types of development (e.g., residential), given the local, regional, and statewide policy pressures to
produce more housing.
•Approval of a revised sharing agreement would of course require approval by both the City and County,
hence a lessened certainty of implementation compared to a maintenance CFD. The County would need
to be motivated to renegotiate the existing agreement, which is anticipated to be difficult.
•Renegotiation of the tax sharing agreement could be done instead or in addition to a maintenance CFD
and/or minimum commercial use requirement.
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KOSMONT COMPANIES | 10
3) INFRASTRUCTURE FINANCING DISTRICT NEGOTIATION
WITH THE COUNTY
•Suggested only as a backup alternative to strategy #2 (renegotiation of tax sharing agreement), the City
and County may both consider formation of a tax increment financing (TIF) district such as an Enhanced
Infrastructure Financing District (EIFD).
•An EIFD would not create a new tax to property owners, but would entail the County allocating some
portion of its future property tax within the AASP area for a prescribed period of time (e.g., 10 to 50
years), with a restriction for certain eligible uses, such as infrastructure and affordable housing.
•An EIFD would not require voter approval, although property owners and residents within the financing
district boundary (e.g., AASP area) would have an opportunity to protest formation of the EIFD.
•EIFD formation could be done instead or in addition to a maintenance CFD and/or minimum commercial
use requirement.
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KOSMONT COMPANIES | 11
4) MINIMUM COMMERCIAL USE REQUIREMENTS FOR
RESIDENTIAL PROJECTS
•Instead or in addition to other fiscal mitigation options listed herein, the City could adopt a minimum
commercial use requirement for residential projects within the AASP, such as a certain amount of
commercial square footage.
•Advantages of this approach include direct promotion of land use mixes that include greater proportions
of non-residential uses. This approach would more directly reserve a greater amount of developable land
in the AASP area for commercial and manufacturing uses and promote jobs/housing balance.
•Disadvantages of this approach include the potential to limit any new development in the AASP area, as
the required amount of non-residential components may render new development projects financially
infeasible, and thus unable to proceed at all.
•This approach does not fully acknowledge current trends of “horizontal” blending of land uses versus
“vertical” blending of land uses. While each individual residential development may not contain a significant
non-residential component, the production of new “rooftops” within an area is still critical to support
development of new non-residential uses (and retention of existing non-residential uses) on other parcels.
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KOSMONT COMPANIES | 12
POTENTIAL NEXT STEPS
•Subject to City staff and City Council discussion and direction regarding land use and economic
development objectives for the AASP area, the City may proceed with one or more of the fiscal mitigation
strategies suggested herein.
•Kosmont is suggesting that Strategy #1 (maintenance CFD) may make sense to be prioritized based on
realistic implementation feasibility. Kosmont suggests that Strategy #2 (renegotiation of sharing agreement)
is worth at least an initial inquiry with County stakeholders.
•Ultimately, certain strategies may be implemented on a targeted basis, such as within the AASP area alone,
or Citywide (e.g., Citywide maintenance CFD), as has been implemented elsewhere within the State.
•Kosmont suggests transparent communication with both public sector and private sector stakeholders in
any scenario.
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KOSMONT COMPANIES | 13
APPENDIX:
FISCAL IMPACT ANALYSIS SCENARIO DETAIL
Page 189 of 214
Airport Area Specific Plan - Fiscal Impact Analysis
Overview of Fiscal Impacts
LUCE 2014
Market-Based
Blended Use
City of San Luis Obispo
Estimated Fiscal Revenues $5,352,100 $5,558,400
Estimated Fiscal Expenditures $2,146,800 $7,273,200
Estimated Net Fiscal Impact to City $3,205,300 ($1,714,800)
Land Use Assumptions for Reference LUCE 2014
Market-Based
Blended Use
Residential - Market Rate 0 DU 2,650 DU
Affordable Housing 0 DU 230 DU
Hotel 0 rooms 218 rooms
Office 900,000 SF 30,000 SF
Commercial / Retail 616,983 SF 158,976 SF
Industrial 747,642 SF 95,000 SF
Notes:
Impacts at buildout
Assumes installation of necessary public infrastructure
Values in 2024 dollars
8/13/2024 Page 1 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Summary of Estimated Fiscal Impacts to City
LUCE 2014
Market-Based
Blended Use
City of San Luis Obispo General Fund Revenues
Property Tax $0 $0
Property Tax In-Lieu of MVLF $359,300 $785,800
Property Transfer Tax $18,500 $40,500
Sales Tax - General - Direct $1,388,200 $357,700
Sales Tax - Measure G20 - Direct $2,082,300 $536,500
Use Tax as % of Sales Tax - Direct $200,600 $51,700
Sales Tax - Prop 172 as % of Sales Tax - Direct $30,500 $7,900
Sales Tax - General - Indirect $128,700 $425,800
Sales Tax - Measure G20 - Indirect $193,100 $638,700
Use Tax as % of Sales Tax - Indirect $18,600 $61,500
Sales Tax - Prop 172 as % of Sales Tax - Indirect $2,800 $9,400
Transient Occupancy Tax $0 $946,900
Utility Users Tax $184,000 $559,600
Franchise Fees $59,700 $181,700
Business Tax $473,500 $81,500
Cannabis Tax $45,400 $138,000
Police Revenue $19,100 $58,200
Fire Revenue $49,400 $150,100
Parks & Rec Revenue $0 $260,600
Business Licenses $66,800 $11,500
Other Revenue $31,600 $96,100
SB1 Road Repair $0 $158,700
Estimated Total Revenues $5,352,100 $5,558,400
City of San Luis Obispo General Fund Expenditures
Administration and IT $137,700 $418,800
City Attorney $18,700 $57,000
Finance & Non-Departmental $65,300 $198,500
Human Resources $28,100 $85,500
Fire $486,600 $1,480,100
Police $707,200 $2,151,100
Community Services Group Admin $12,200 $37,000
Community Development $60,200 $183,100
Parks and Recreation $0 $743,300
Public Works $573,400 $1,744,000
Solid Waste $10,900 $33,300
Transfers Out $46,500 $141,500
Estimated Total Expenditures $2,146,800 $7,273,200
Estimated Annual Net Fiscal Impact $3,205,300 ($1,714,800)
Revenue / Cost Ratio 2.49 0.76
Notes:
Assumes installation of necessary public infrastructure
Values in 2024 dollars
8/13/2024 Page 2 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Project Description
Project Component LUCE 2014
Market-Based
Blended Use
Residential - Market Rate 2,650 DU
Affordable Housing 230 DU
Hotel 218 rooms
Office 900,000 SF 30,000 SF
Commercial / Retail 616,983 SF 158,976 SF
Industrial 747,642 SF 95,000 SF
Annual Escalation Factor 1.00 1.00
Estimated A/V - Residential $495K Per Unit $0 $1,311,552,000
Estimated A/V - Affordable Housing $0K Per Unit $0 $0
Estimated A/V - Hotel $350K Per Room $0 $76,300,000
Estimated A/V - Office $350 PSF $315,000,000 $10,500,000
Estimated A/V - Commercial / Retail $350 PSF $215,944,050 $55,641,600
Estimated A/V - Industrial $190 PSF $142,051,980 $18,050,000
Total Estimated Assessed Value $672,996,030 $1,472,043,600
Notes:
Values in 2024 dollars
8/13/2024 Page 3 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Project Employment and Occupants
Project Component LUCE 2014
Market-Based
Blended Use
Residential - Market Rate 0 DU 2,650 DU
Affordable Housing 0 DU 230 DU
Hotel 0 Rooms 218 Rooms
Office 900,000 SF 30,000 SF
Commercial / Retail 616,983 SF 158,976 SF
Industrial 747,642 SF 95,000 SF
Estimated # Employees (FTE)
Residential - Market Rate 50 DU / emp 0 53
Affordable Housing 50 DU / emp 0 5
Hotel 1.5 room / emp 0 145
Office 400 SF / emp 2,250 75
Commercial / Retail 400 SF / emp 1,542 397
Industrial 1,500 SF / emp 498 63
Total Estimated # Employees (FTE)4,291 739
Occupied Dwelling Units 93%0 DU 2,678 DU
Residents 2.29 per DU 0 6,134
Occupied Hotel Rooms 70%0 rooms 153 rooms
Hotel Guests 1.5 per room 0 229
Employees Weighted at 50%50%2,145 369
Hotel Guests Weighted at 10%10%0 23
Total Service Population (Residents / Empl / Visitors)2,145 6,526
Notes:
Average household size reflects City average household size
Values in 2024 dollars
8/13/2024 Page 4 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Property Tax
LUCE 2014
Market-Based
Blended Use
Estimated Assessed Value - Residential $0 $1,311,552,000
Estimated Assessed Value - Non-Residential $672,996,030 $160,491,600
Total Estimated Assessed Value $672,996,030 $1,472,043,600
Total Secured Property Tax General Levy 1.00%$6,729,960 $14,720,436
Estimated Unsecured Property Tax as % of Secured Non-Residential Value 10.00%$672,996 $160,492
Total Estimated Secured + Unsecured Property Tax $7,402,956 $14,880,928
Distributions to Taxing Entities
Property Tax - City of San Luis Obispo (based on Property Tax Sharing Agreement)0.00%$0 $0
Net Property Tax to City 0.00%$0 $0
Notes:
When the proposed project site was annexed into the City of San Luis Obispo, it carried a nonresidential land use designation (M - Manufacturing). Under the terms of the
tax sharing agreement between the City and the County of San Luis Obispo, the County continues to receive all base year taxes plus any future incremental increase in property
taxes for property designated for nonresidential development. Therefore, under the agreement, the City will not receive a share of general levy property taxes from the AASP area.
Does not include property tax overrides above 1% general levy
Values in 2024 dollars
Source: San Luis Obispo County Auditor-Controller (2024)
8/13/2024 Page 5 of 13
Page 194 of 214
Airport Area Specific Plan - Fiscal Impact Analysis
Property Tax In-Lieu of Motor Vehicle License Fees (MVLF)
Total AV within CITY $11,770,822,169
Current Property Tax In-Lieu of MVLF $6,283,397
Prop Tax In-Lieu of MVLF per $1M of AV $534
LUCE 2014
Market-Based
Blended Use
Estimated Project Assessed Value $672,996,030 $1,472,043,600
Net Incremental Property Tax In-Lieu of MVLF to City $359,300 $785,800
Notes:
Values in 2024 dollars
Source: San Luis Obispo County Auditor-Controller, City Online Budget Portal (2024)
8/13/2024 Page 6 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Property Transfer Tax
LUCE 2014
Market-Based
Blended Use
Estimated Assessed Value - For-Sale Residential $0 $0
Estimated Property Turnover Rate 15.0%15.0%
Estimated Value of Property Transferred $0 $0
Estimated Assessed Value - Other Land Uses $672,996,030 $1,472,043,600
Estimated Property Turnover Rate 5.0%5.0%
Estimated Value of Property Transferred $33,649,802 $73,602,180
Estimated Total Value of Property Transferred $33,649,802 $73,602,180
Total Transfer Tax $1.10 per $1,000 $37,000 $81,000
Transfer Tax to City $0.55 per $1,000 $18,500 $40,500
Notes:
Values in 2024 dollars
Source: San Luis Obispo County Auditor-Controller (2024)
8/13/2024 Page 7 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Sales Tax - Direct / On-Site
Project Component LUCE 2014
Market-Based
Blended Use
Commercial / Retail 616,983 SF 158,976 SF
Portion of Comm / Retail Generating Local Taxable Sales 75%462,737 SF 119,232 SF
Estimated Taxable Sales $300 PSF $138,821,175 $35,769,600
Sales Tax - General - Direct 1.00%$1,388,200 $357,700
Sales Tax - Measure G20 - Direct 1.50%$2,082,300 $536,500
Use Tax as % of Sales Tax - Direct 14.45%$200,600 $51,700
Sales Tax - Prop 172 as % of Sales Tax - Direct 2.20%$30,500 $7,900
Notes:
Use tax and Prop 172 sales tax percentages based on historical average percentages
Values in 2024 dollars.
8/13/2024 Page 8 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Sales Tax - Indirect / Off-Site
LUCE 2014
Market-Based
Blended Use
Estimated # Employees 4,291 739
Estimated Annual Taxable Retail Spending / Empl. Near Work $6,000 $6,000
Estimated Employee Taxable Retail Spending Within City $25,745,313 $4,432,240
Estimated # Occupied Dwelling Units 0 DU 2,678 DU
Estimated Avg Annual Taxable Retail Spending / HH $30,977 $30,977
Estimated Resident Taxable Retail Spending $0 $82,970,125
Estimated Capture within City 50.0%$0 $41,485,063
Estimated # Occupied Hotel Rooms 0 rooms 153 rooms
Estimated Annual Taxable Retail Spending / Room $18,250 $18,250
Estimated Resident Taxable Retail Spending $0 $2,784,950
Estimated Capture within City 50.0%$0 $1,392,475
Total Estimated Indirect Taxable Sales $25,745,313 $47,309,778
Estimated Capture Within AASP Retail - Percentage (50%)(10%)
Estimated Capture Within AASP Retail - Dollar Amount ($12,872,657)($4,730,978)
Net Indirect Taxable Sales $12,872,657 $42,578,800
Sales Tax - General - Indirect 1.00%$128,700 $425,800
Sales Tax - Measure G20 - Indirect 1.50%$193,100 $638,700
Use Tax as % of Sales Tax - Indirect 14.45%$18,600 $61,500
Sales Tax - Prop 172 as % of Sales Tax - Indirect 2.20%$2,800 $9,400
Notes:
Employee spending estimates based on "Office Worker Retail Spending Patterns: A Downtown and Suburban Area Study," ICSC.
Household spending based on average houshold income within City.
Hotel guest spending estimated based on American Hotel and Lodging Association (AHLA) data.
Values in 2024 dollars.
8/13/2024 Page 9 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
Transient Occupancy Tax ("TOT")
LUCE 2014
Market-Based
Blended Use
Estimated # Hotel Rooms 0 rooms 218 rooms
Average Daily Room Rate (ADR)$170 $170
Average Occupancy Rate 70%70%
Annual Hotel Room Receipts $0 $9,468,830
TOT to City 10.0%$0 $946,900
Notes:
Values in 2024 dollars.
8/13/2024 Page 10 of 13
Page 199 of 214
Airport Area Specific Plan - Fiscal Impact Analysis
City Service Population
City Population 48,684
City Employee Population 30,061
Employee Weighting for Service Population 0.5
Weighted # Employees 15,031
Visitor Population Equiv - Weighted at 10% of Resident 4,868
Total City Service Population 68,583
Source: CA Department of Finance, U.S. Census Bureau Center for Economic Studies (2023-2024)
8/13/2024 Page 11 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
City Multipler Revenue and Expenditure Factors
Budget Category
Adopted City
Budget Allocation Basis
Relevant City
Population
Percent Fixed
Costs
Per Capita
Factor
General Fund Revenues
Sales Tax - General $23,166,049 N/A - Estimated Separately via Case Study Method -----------------------------
Sales Tax - Prop 172 $508,968 N/A - Estimated Separately via Case Study Method -----------------------------
Sales Tax - Local Revenue Measure $30,897,602 N/A - Estimated Separately via Case Study Method -----------------------------
Property Tax $15,982,628 N/A - Estimated Separately via Case Study Method -----------------------------
Property Tax in Lieu of MVLF $6,669,367 N/A - Estimated Separately via Case Study Method -----------------------------
Transient Occupancy Tax $10,918,080 N/A - Estimated Separately via Case Study Method -----------------------------
Utility Users Tax $5,881,630 Service Population 68,583 0%$85.76
Franchise Fees $1,910,000 Service Population 68,583 0%$27.85
Business Tax $3,317,338 Employment Base 30,061 0%$110.35
Cannabis Tax $1,450,000 Service Population 68,583 0%$21.14
Police Revenue $611,917 Service Population 68,583 0%$8.92
Fire Revenue $1,577,836 Service Population 68,583 0%$23.01
Development Review $6,585,331 N/A - Non-Recurring Revenue ------------------------------------------------------------
Parks & Rec Revenue $2,068,693 Residents 48,684 0%$42.49
Business Licenses $468,000 Employment Base 30,061 0%$15.57
Cannabis Fee Revenue $232,600 N/A - Prior Obligations ----------------------------------------------------------------------
Other Revenue $1,010,016 Service Population 68,583 0%$14.73
SB1 Road Repair $1,259,276 Residents 48,684 0%$25.87
Grants and Subventions $682,279 N/A - Non-Recurring Revenue ------------------------------------------------------------
Storm Reimbursement $4,208,000 N/A - Non-Recurring Revenue ------------------------------------------------------------
Total General Fund Revenues $119,405,610
General Fund Expenditures
Administration and IT $11,003,659 Service Population 68,583 60%$64.18
City Attorney $1,497,103 Service Population 68,583 60%$8.73
Finance & Non-Departmental $5,216,654 Service Population 68,583 60%$30.43
Human Resources $2,246,535 Service Population 68,583 60%$13.10
Fire $15,554,762 Service Population 68,583 0%$226.80
Police $22,607,072 Service Population 68,583 0%$329.63
Community Services Group Admin $778,730 Service Population 68,583 50%$5.68
Community Development $8,510,146 Service Population 68,583 77%$28.07
Parks and Recreation $5,899,998 Residents 48,684 0%$121.19
Public Works $18,328,375 Service Population 68,583 0%$267.24
Solid Waste $349,657 Service Population 68,583 0%$5.10
Debt Service $1,769,000 N/A - Prior Obligations ----------------------------------------------------------------------
Capital $27,269,000 N/A - Non-Recurring --------------------------------------------------------------------------
Transfers Out $1,487,000 Service Population 68,583 0%$21.68
Total General Fund Expenditures $122,517,691
Notes:
Community Development adustments based on services paid by Development Review Fees (also deducted from Revenues)
Values in 2024 dollars.
Source: City of San Luis Obispo 2023-2025 Financial Plan (2024-2025 Budget)
8/13/2024 Page 12 of 13
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Airport Area Specific Plan - Fiscal Impact Analysis
City Multipler Revenues and Expenditures
LUCE 2014
Market-Based
Blended Use
Estimated # Residents 0 6,134
Estimated # Employees 4,291 739
Estimated # Visitors 0 229
Total Project Service Population 2,145 6,526
Budget Category LUCE 2014
Market-Based
Blended Use
General Fund Revenues
Utility Users Tax $184,000 $559,600
Franchise Fees $59,700 $181,700
Business Tax $473,500 $81,500
Cannabis Tax $45,400 $138,000
Police Revenue $19,100 $58,200
Fire Revenue $49,400 $150,100
Development Review N/A N/A
Parks & Rec Revenue $0 $260,600
Business Licenses $66,800 $11,500
Cannabis Fee Revenue N/A N/A
Other Revenue $31,600 $96,100
SB1 Road Repair $0 $158,700
Grants and Subventions N/A N/A
Storm Reimbursement N/A N/A
Total Multiplier Revenues $929,500 $1,696,000
General Fund Expenditures
Administration and IT $137,700 $418,800
City Attorney $18,700 $57,000
Finance & Non-Departmental $65,300 $198,500
Human Resources $28,100 $85,500
Fire $486,600 $1,480,100
Police $707,200 $2,151,100
Community Services Group Admin $12,200 $37,000
Community Development $60,200 $183,100
Parks and Recreation $0 $743,300
Public Works $573,400 $1,744,000
Solid Waste $10,900 $33,300
Debt Service N/A N/A
Capital N/A N/A
Transfers Out $46,500 $141,500
Total Multiplier Expenditures $2,146,800 $7,273,200
Notes:
Major case study revenues not shown include property tax, sales tax, transient occupancy tax
Values in 2024 dollars.
Source: City of San Luis Obispo 2023-2025 Financial Plan (2024-2025 Budget)
8/13/2024 Page 13 of 13
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1
Addendum to the Final Programmatic Environmental Impact Report for the
Airport Area and Margarita Area Specific Plans and Related Facilities
Master Plans
1. Project Title:
Airport Area Specific Plan Amendment to Allow Mixed-Use Development in the Service
Commercial (C-S) and Manufacturing (M) zones subject to the approval of a conditional
use permit
2. Lead Agency Name and Address:
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA 93401
3. Contact Person and Phone Number:
Rachel Cohen, Principal Planner
805-781-7574
4. Project Location:
Airport Area Specific Plan area, generally bounded by South Higuera Street to the west,
Meissner Lane to the north, Broad Street to the east, and Buckley Road to the south, in
San Luis Obispo, CA
5. Project Applicant and Representative Name and address:
City of San Luis Obispo
Community Development Department
919 Palm Street
San Luis Obispo, CA 93401
6. General Plan Designation:
Services & Manufacturing
7. Zoning:
Service Commercial (C-S) and Manufacturing (M)
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2
8. Description of the Project:
The Airport Area Specific Plan (AASP) is a land use program with policies, goals,
guidelines and infrastructure financing strategies to guide future development to ensure
land use compatibility within the AASP planning area. The AASP was adopted in 2005
and has been amended several times since then in response to changing conditions or
opportunities unforeseen at the time of its adoption. The proposed project would amend
the AASP to allow for mixed-use development (as defined in the City’s Municipal Code)
with a conditional use permit within parcels designated as either Service Commercial (C-
S) or Manufacturing (M).
The AASP does not currently allow mixed-use development. The underlying reason for
this was because of the area’s proximity to the San Luis Obispo County Airport, and the
established safety and noise areas that limited or prohibited noise sensitive reside ntial
uses or high density residential development. The southern portion of the City at that time
was also viewed as the area most appropriate for industrial uses. In 2021, the San Luis
Obispo County Airport Land Use Commission (ALUC) amended and restated the Airport
Land Use Plan (ALUP) to address new technical information related to safety and noise,
which resulted in a refinement of areas subject to land use restrictions under the ALUP,
including areas within the AASP. As a result, there is now substantial area within the AASP
where the land use restrictions have changed related to airport safety and noise, and
creates opportunities for mixed-use developments.
No development would occur directly as a result of this action, which is simply a
modification of existing land use requirements under the AASP. Future development
under the modified land use requirements could occur as a result of individual project
applications that must be approved by the City of San Luis Obispo through its normal
development and conditional use permit review processes. However, the magnitude and
timing of such development is speculative at this time, and would be influenced by a
variety of issues, including market demand, property owner desire to develop,
consistency with the ALUP, and potential environmental constraints that may apply to
specific parcels where project development applications are under consideration.
The Project Area includes all parcels designated as Service Commercial (C-S) or
Manufacturing (M) within the 1,200-acre AASP planning area. Figure 1 shows the location
of C-S and M designated parcels within the AASP.
9. Project Entitlements Requested:
No project-level entitlements are requested or would occur as a result of this action.
Instead, the resulting amendment would allow mixed-use development, subject to specific
findings, with a conditional use permit in portions of the Airport Area Specific Plan
currently designated as Service Commercial (C-S) and Manufacturing (M), consistent with
the requirements of the City’s Zoning Regulations, as they currently apply to C-S and M
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3
designated lands in the remainder of the City. The reason this amendment is necessary
is because as currently written, the AASP does not allow mixed-use development.
Figure 1: Existing Land Use Designations in the Airport Area Specific Plan
Development under the modified land use requirements would result from individual
project applications that must be approved by the City of San Luis Obispo through its
normal development and conditional use permit review processes. Proposed
modifications to the Airport Area Specific Plan are described below in detail under the
heading “New Information and Updated Project Elements.”
10. Previous Environmental Review:
The Final Programmatic EIR for the Airport Area and Margarita Area Specific Plans and
Related Facilities Master Plans (“Final EIR”, or “AASP Final EIR”) addressed future
development within the Airport Area Specific Plan. The Final EIR was certified in
September 2003, and has provided the basis for evaluating the impacts of future
development within the AASP area. Subsequent amendments to the AASP were subject
to separate CEQA evaluations to address the potential impacts stemming from those
amendments. In a similar manner, the analysis in this Addendum tiers from the original
Final EIR.
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4
Individual projects that may be proposed under the AASP as amended would be subject
to review under the California Environmental Quality Act (CEQA) as appropriate on a
project-by-project basis.
The County of San Luis Obispo Airport Land Use Commission conducted an Initial Study
and prepared a Negative Declaration for the 2021 update of its Airport Land Use Plan
(ALUP) (SCH: 2021030474). That environmental document was used to inform the
conclusions contained in this addendum.
11. Purpose of the Addendum:
Section 15164 of the State CEQA Guidelines allows a lead agency to prepare an
addendum to a Final EIR when only “minor technical changes or additions” are necessary
to address the effects of a minor change to the approved project since the Final EIR was
certified. In addition, the lead agency is required to explain its decision not to prepare a
subsequent EIR pursuant to State CEQA Guidelines Section 15162, which requires
subsequent EIRs when proposed changes would require major revisions to the previous
EIR “due to the involvement of new significant environmental effects or a substantial
increase in the severity of previously identified significant effects.”
Subsequent to certification of the AASP Final EIR, additional information has been
identified which provides a more consistent Citywide approach to mixed -use
development, specifically as it is allowed in the C-S and M zones. In 2021, the San Luis
Obispo County Airport Land Use Commission (ALUC) updated its Airport Land Use Plan
(ALUP) to address new technical information related to safety and noise, which resulted
in a refinement of areas subject to land use restrictions under the ALUP and has created
opportunities for mixed-use developments within the AASP. The proposed action requires
an amendment to the AASP to allow for mixed-use in the C-S and M zones subject to a
Conditional Use Permit. This project is described in more detail in subsequent sections of
this EIR Addendum.
The purpose of this Addendum is to document the proposed change to the AASP, and to
confirm that this change would not result in any new or more severe significant
environmental effects not previously analyzed in the Final EIR, and would not modify any
existing mitigation requirements described in that document.
The evaluation below discusses the issue areas that are relevant to this Addendum and
covered by the previously approved Final EIR. The evaluation concludes that no new
environmental effects are created and that there is no increase in the severity of
previously identified significant effects.
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5
12. Addendum Requirements:
Pursuant to Section 21166 of CEQA and Section 15162 of the State CEQA Guideli nes,
when a lead agency has adopted an EIR for a project, a subsequent EIR does not need
to be prepared for the project unless the lead agency determines that one or more of the
following conditions are met:
1. Substantial project changes are proposed that will require major revisions of the
previous EIR due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects;
2. Substantial changes would occur with respect to the circumstances under which the
project is undertaken that require major revisions to the previous EIR due to the
involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; or
3. New information of substantial importance that was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR
was adopted shows any of the following:
a. The project will have one or more significant effects not discussed in the
previous EIR; or
b. Significant effects previously examined will be substantially more severe than
identified in the previous EIR; or
c. Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects
of the project, but the project proponent declines to adopt the mitigation
measures or alternatives; or
d. Mitigation measures or alternatives that are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponent declines to adopt the
mitigation measures or alternatives.
Preparation of an Addendum to an EIR is appropriate when none of the conditions
specified in Section 15162 (above) are present and some minor technical changes to the
previously certified EIR are necessary to address minor changes to an approved project.
Because the new information would not result in any new or more severe significant
impacts, an Addendum is the appropriate CEQA document.
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CURRENT REGULATORY FRAMEWORK FOR C-S AND M ZONES
San Luis Obispo County Airport Land Use Plan
Mixed-use development was not originally allowed at the time of the AASP’s adoption in 2005
because of the area’s proximity to the San Luis Obispo County Airport, and the established
safety and noise areas that limited or prohibited noise sensitive residential uses or high density
residential development. The southern portion of the City at that time was also viewed as the
area most appropriate for industrial uses. In 2021, the San Luis Obispo County Airport Land
Use Commission (ALUC) updated its Airport Land Use Plan (ALUP) to address new technical
information related to safety and noise, which resulted in a refinement of areas subject to land
use restrictions under the ALUP, including areas within the AASP. As a result, there is now
substantial area within the AASP where the land use restrictions have changed related to airport
safety and noise and creates opportunities for mixed -use developments..
Current AASP Requirements
For the reasons described above related to the ALUP, the AASP does not currently allow mixed -
use development in either the Service Commercial (C-S) or Manufacturing (M) zones. As stated
in Section 4.2.2 of the AASP, “areas designated Service Commercial are generally for storage,
transportation, and wholesaling type uses, as well as certain retail sales and business services
that may be less appropriate in othe r commercial designations.” Similarly, Section 4.2.3
summarizes the intent of the Manufacturing designation as areas “for assembly, fabrication,
storage and distribution, and sales and service type uses that have little or no direct trade with
local consumers.”
Table 4-3 of the AASP shows the allowed uses within each land use designation. Mixed-use is
not allowed under either designation.
Other Relevant Regulatory Setting
There is an existing regulatory framework for allowing mixed-use in non-residential zones
Citywide. Mixed-use development is allowed in the C-S and M zones in all parts of the City
except within the AASP and other specific plan areas. Within both designations, the Zoning
Regulations allow for residential development up to 24 density units per acre (Municipal Code
Sections 17.36.020 and 17.40.020).
Final Environmental Impact Report
The 2003 Final EIR examined the policy framework and conceptual development under the
AASP at a programmatic level. That document did not include project-specific analysis of the
parcels potentially impacted by the proposed action. The FEIR impact analysis was general,
and any required mitigation for key issue areas was programmatic, in consideration of cumulative
development that might occur under the AASP. Please refer to the section below entitled
“Analysis Of The Proposed Project In The Context Of The Final EIR ” for further discussion of
relevant issues and how they relate to the proposed Specific Plan Amendment
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7
NEW INFORMATION AND UPDATED PROJECT ELEMENTS
NEWLY DISCOVERED INFORMATION
In recent years, the demand for housing in general, and affordable housing in particular, has
risen dramatically in San Luis Obispo, as it has elsewhere. In response, the City’s 2014 General
Plan Land Use Element update reflects this increased demand, and includes several large areas
for increased residential development, projects that have since been approved and are in the
process of being completed. At the same time, the City has tried to address these issues by
supporting mixed-use development, in areas where demand for non-residential development in
Service Commercial or Manufacturing designated land has declined. The result is that the City
allows mixed-use by right in the C-S and M zones outside the AASP. However, the AASP does
not allow mixed-use development, because of previous safety and noise restrictions included in
the ALUP. As described above, the 2021 update of the ALUP removed those restrictions that
limited or prohibited mixed-use development.
The proposed project responds to the changes in the ALUP and increased housing demand in
an evolving market by allowing for mixed-use development in the C-S and M land use
designations in the AASP with the approval of a conditional use permit.
As discussed previously, the underlying reason why mixed-use development was not allowed in
the AASP is because of the area’s proximity to the San Luis Obispo County Airport, and safety
and noise conflicts that could arise if residential development were allowed. In 2021, the San
Luis Obispo County Airport Land Use Commission (ALUC) updated its Airport Land Use Plan
(ALUP) to address new technical information related to safety and noise, which resulted in a
refinement of areas subject to land use restrictions under the ALUP, including areas within the
AASP. As a result, there is substantial area where the land use restrictions have changed related
to airport safety and noise.
CHANGED BASELINE CONDITIONS AND UPDATED PROJECT ELEMENTS
The proposed project would amend the AASP, modifying various aspects of the plan in order to
facilitate mixed-use development with approval of a conditional use permit in the C-S and M land
use designations. It would not change any existing land use designation, nor would it result in
more or less land designated as either C-S or M. Instead, it would modify existing language and
tables in various parts of the existing AASP in order to facilitate mixed-use within these land use
designations.
A detailed land use inventory was prepared in 2024 to verify the amount of C-S or M designated
lands within the planning area. Table 1 below summarizes the results of the 2024 land use
inventory for each designation, showing the total acreage of vacant and developed parcels in
these two land use designations.
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8
Table 1. Summary of 2024 Land Use Inventory
C-S and M Parcels in the AASP
Land Use Designation
Acreage
Developed
(or entitled)
Vacant Total
Service Commercial (C-S) 140.4 85.6 226.0
Manufacturing (M) 94.7 20.4 115.1
Total 235.1 106.0 341.1
Portions of land designated as either C-S or M are constrained from considering mixed-use
development. Some of this constrained area remains within airport land use safety zones under
the ALUP that do not allow for residential uses. Other parcels are too small or configured in such
a way to make development challenging. Depending on the location, a variety of environmental
constraints could present other challenges, including drainage features, steep slopes, or the
potential for sensitive biological or cultural resources. Some parcels are adjacent to existing
industrial land uses that produce odors or noise, which could make them less attractive for mixed-
use development. Finally, many of these parcels are already developed with other uses, or are
entitled for development. It is likely that only a few of these more constrained parcels will
eventually support mixed-use development.
There is no specific mixed-use development project proposed at this time, but the amendment
would allow the City to process and potentially approve applications that propose such
development. However, the magnitude and timing of such development cannot be known at this
time, and would be influenced by a variety of issues, including market demand, property owner
desire to develop, and potential environmental constraints that may apply to specific parcels
where project development applications are under consideration. For these reasons, it is
speculative to determine what the residential buildout potential of this action is at this time, or
how it might alter the non-residential buildout assumptions made in the AASP.
If mixed-use development were to occur, it would be based on the maximum density currently
allowed under the Zoning Regulations, which is 24 density units per acre.
ANALYSIS OF THE PROPOSED PROJECT IN THE CONTEXT OF THE FINAL EIR
The updated project elements described above were not considered in the 2003 Final EIR, and
so are analyzed here. The 2003 Final EIR examined the policy framework and conceptual
development under the AASP at a programmatic level, which is also appropriate for the currently
proposed Specific Plan Amendment. The following analysis examines the proposed project
based on relevant issues from the 2003 Final EIR, with references to FEIR impact statements
as appropriate. Implementation of the proposed project would not change any of the conclusions
in the Final EIR, the level of significance or severity of any previously identified impact, or
introduce any new mitigation measures. No changes to the Final EIR are required.
Land Use
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The FEIR identifies the following land use impacts that are relevant to the proposed Specific
Plan Amendment. As discussed in Impact LU-3, the Final EIR found the AASP was consistent
with the ALUP in effect at the time of adoption of the AASP. No significant impacts were
identified, and no mitigation was required. The Specific Plan amendment would allow for mixed-
use development with approval of a conditional use permit, subject to potential constraints
contained in the 2021 ALUP update. The County’s environmental document for the 2021 update
(SCH 2021030474) concluded that there would be no land use impacts or hazards associated
with allowing more intensive development in the AASP, or mixed-use or residential projects in
the ALUP area if development regulations in the ALUP were complied with. Individual
development projects within the AASP would need to be consistent with any land use restrictions
set forth in the ALUP. No new impact would occur.
Impact LU-4 discussed compatibility with surrounding land uses. No conflicts with surrounding
uses were identified in the AASP, so impacts were less than significant, and no mitigation was
required. Individual development projects within the AASP would need to be compatible with
adjacent development, a determination that would be made through development and
conditional use permit review processes and project-specific CEQA analysis for any such future
action. No new programmatic impacts would occur.
Hydrology and Water Quality
Impact H-5 discussed exposure of people and/or property to flood hazards. The FEIR found that
the conversion of land to urban uses has the potential to increase flooding hazards if new
buildings were constructed within the 100-year flood hazard area. However, the specific plan
includes explicit requirements for flood channel improvements that will avoid flooding impacts by
providing enhanced control of floodwaters. This impact was considered less than significant.
Mixed-use development would be evaluated individually under CEQA, and would be required to
comply with existing regulations related to flood hazards and water quality. No new
programmatic impacts would occur, nor would there be an increase in severity of a ny existing
impact.
Traffic and Circulation
Since the time the AASP FEIR was prepared, CEQA analysis related to this issue has been
modified considerably. The focus of CEQA review is now based primarily on a study of Vehicle
Miles Traveled (VMT), which can have potential impacts on regional air quality and greenhouse
gas emissions. These issues were not examined in the Final EIR.
One purpose of mixed-use development is to reduce commute distances between residences
and work places. In some cases, mixed-use development could make it possible for some
residents to walk to work, which would potentially reduce VMT. In those instances, there would
be a net positive effect on greenhouse gas emissions and air quality relative to what would
otherwise happen under the AASP. Future individual development projects within the AASP
would be evaluated on a case by case basis through a project-specific CEQA analysis. No new
programmatic impacts related to these issues would occur.
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10
Other transportation issues that were studied in the FEIR related to roadway Levels of Service
(LOS), which is a metric no longer considered in CEQA documents. Instead, these are issues
that would be appropriately addressed through the development and conditiona l use permit
review processes, with recommendations for potential roadway improvement made through
engineering studies.
Air Quality
The FEIR identified impacts related to both short -term construction emissions and long-term
operations emissions. Short-term construction emissions were found to be significant but
mitigable at a programmatic level, with mitigation taking the form of following a variety of
standard construction management techniques and following the existing regulatory framework
set forth by the Air Pollution Control District (APCD). The impacts of specific development
projects would be analyzed and mitigated as needed on a case by case basis.
Similarly, long-term operational impacts were also found to be less than significant with
programmatic mitigation. The FEIR included the following relevant mitigation measure:
Mitigation Measure AIR-2.1. Implement Growth-Phasing Schedule. The City will
implement a growth-phasing schedule for the Airport area, to assure that nonresidential
development in the urban area does not exceed the pace of residential development.
The consideration of mixed-use development in the Airport Area is consistent with this mitigation
requirement, as it allows for greater flexibility and opportunities to approve residen tial
development in balance with non-residential development. Future individual development
projects within the AASP would be evaluated on a case by case basis through a project-specific
CEQA analysis. No new programmatic impacts related to this issue would occur.
Noise
The FEIR examined relevant programmatic impacts related to traffic and aircraft noise, but found
them to be less than significant. For aircraft noise, this was because future development under
the AASP was determined to be consistent with the ALUP. For traffic noise, it was determined
that the City’s General Plan Noise Element included sufficient implementation requirements and
strategies to ensure that noise would be mitigated on a project-by-project basis as appropriate,
through the recommendations of project-specific noise studies. Future individual development
projects within the AASP would be evaluated on a case by case basis through a project-specific
CEQA analysis. The County’s environmental document for the 2021 update (SCH 2021030474)
concluded that there would be no noise impacts or hazards associated with allowing more
intensive development in the AASP, including mixed-use or residential projects in the ALUP
area, if development regulations in the ALUP were complied with . No new programmatic
impacts related to this issue would occur.
Public Services and Utilities
The FEIR examined potential programmatic impacts related to the provision of water and
wastewater services from buildout under the AASP, but concluded these wou ld be less than
significant because projects would be required to follow the regulatory provisions included in the
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11
General Plan, AASP and relevant utilities master plans. Similarly, programmatic impacts related
to storm drainage were considered less than significant because projects would be required to
follow the provisions of the Storm Drain Master Plan. Impacts related to solid waste disposal
were also considered less than significant, as projects would be required to follow regulatory
provisions included in the General Plan and AASP.
Impacts related to law enforcement were considered less than significant, as future staffing and
facilities would be addressed through fiscal studies as needed. Impacts to fire protection
services were also considered less than significant with the following mitigation measure:
PS-1. New Fire Protection Personnel. To mitigate the impacts associated with buildout of
the [AASP], a sufficient number of fire protection personnel should be hired to maintain a
ratio of one firefighter for every 1,000 residents.
Determining the appropriate level of public services staff is typically addressed in the City’s
annual budget cycles, with recommendations resulting from studies to service impacts that are
projected to occur based on reasonably foreseeable cumulative development. The proposed
project does not facilitate any specific development project, so the magnitude of potential long-
term impacts to public services is speculative, and would be addressed on a case-by-case basis
as development projects are proposed. No new programmatic impacts related to this issue
would occur.
Impacts to schools were found to be less than significant. Mitigation is limited to the payment of
statutory fees, and no additional school-related impact fees may be imposed above the limits
established in statute (Government Code Section 65595 et seq). No new programmatic impacts
related to this issue would occur.
Impacts to parks and recreation were found to be less than significant, as buildout of the AASP
would not increase demand over the established park service standard of 10 acres per 1,000
residents. The amount of residential development that might occur under the mixed-use
provisions of the project is speculative, and would be limited by a combination of market factors,
property owner desire, lot configuration, and environmental constraints. Impacts to parks and
recreation would be considered on a case by case basis as individual development projects are
proposed. No new programmatic impacts related to this issue would occur.
Other Issues
The proposed project would not introduce new development into areas that were not already
planned for urban uses. Therefore, for all other issues related to resource protection (biological
resources, cultural resources, agricultural resources, and the exposure to hazardous materials),
the potential impact of new development would not change, so the existing impact analysis for
each issue would also remain unchanged. No new programmatic impacts related to these issues
would occur.
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12
DETERMINATION
In accordance with Section 15164 of the State CEQA Guidelines, the City of San Luis Obispo
has determined that this Addendum to the certified Final EIR is necessary to document changes
or additions that have occurred since the Final EIR was originally certified. Based on the analysis
of the proposed project, no new changes to the Final EIR are required. The proposed project
would not result in any new significant environmental effects or a substantial inc rease in the
severity of previously identified significant effects. Additionally, no new information of substantial
importance that was not known and could not have been known with the exercise of reasonable
diligence at the time the previous Final EIR was adopted has been identified.
The preparation of a subsequent environmental document is not necessary because:
1. None of the circumstances included in Section 15162 of the CEQA Guidelines have
occurred which require a subsequent environmental document:
a. The project changes do not result in new or substantially more severe
environmental impacts.
b. The circumstances under which the project is undertaken will not require major
changes to the IS/MND.
c. The modified project does not require any substantive changes to previously
approved mitigation measures.
2. The changes are consistent with City General Plan goals and polices that promote
provision of additional housing, particularly affordable housing, within the City.
3. The changes are consistent with City goals related to mixed-use that would encourage
alternative forms of transportation and reduce Vehicle Miles Traveled (VMT), which
relates to reducing air emissions, including greenhouse gas emissions.
The City has reviewed and considered the information contained in this Addendum and finds
that the preparation of subsequent CEQA analysis that would require public circulation is not
necessary. This Addendum does not require circulation because it does not provide significant
new information that changes the adopted Fi nal EIR in a way that deprives the public of a
meaningful opportunity to comment upon a substantial adverse environmental effect of the
project or a feasible way to mitigate or avoid such an effect. The City shall consider this
Addendum with the certified Final EIR as part of the basis for potential approval of the proposed
Specific Plan Amendment.
Page 214 of 214
REVIEW OF AMENDMENTS TO THE AIRPORT AREA SPECIFIC PLAN TO ALLOW MIXED-USE RESIDENTIAL DEVELOPMENT WITHIN THE SERVICE COMMERCIAL (C-S) AND MANUFACTURING (M) ZONES SUBJECT TO A CONDITIONAL USE PERMIT WHERE APPROPRIATE AND CONSISTENT WITH THE AIRPORT LAND USE PLAN. AN ADDENDUM TO A PREVIOUSLY ADOPTED EIR HAS BEEN PREPARED IN ACCORDANCE WITH CEQA
February 26, 2025
Planning Commission Review
Recommendation
Adopt a Draft Resolution recommending approval to the
City Council to introduce an Ordinance to amend the
Airport Area Specific Plan to allow for mixed-use residential
development in the Service Commercial (C-S) and
Manufacturing (M) zones subject to a conditional use
permit, and to approve an Addendum to the Final EIR for
the Airport Area and Margarita Area Specific Plans.
2
Background: Airport Area Specific Plan (AASP)
Adopted in 2005
Plans for about 1,200 acres in the southern portion of
San Luis Obispo
The AASP allowed uses and development standards that
were guided by the 2002 ALUP
ALUP included several safety zones and noise contours
that limited or prohibited residential and non-residential
development
AASP does not currently allow for mixed-use
development
3
Background: Housing Element & Regulations
Update
2020: the City adopted the Housing Element and included
Program 5.5 to allow mixed-use within C-S and M zones
without a use permit.
2021: the City Council adopted an update to the Zoning
Regulations removing CUP requirements and allowed mixed-
use by right in the C-S and M zones.
An update could not be made to the AASP because of the
existing 2002 ALUP safety zone and noise contour limitations.
4
Background: ALUP
2021: ALUC updated the ALUP, including revisions to the
safety zones and noise contours.
The ALUP revisions removed the limitation on residential
density within Safety Zone 6, the General Traffic Pattern Zone
and narrowed noise contour areas closer to the runways.
The removal of these restrictions to residential development
provides an opportunity to consider mixed-use residential
projects within the AASP.
5
Background: AASP Proposed Amendments
Based on the updated ALUP and Major City Goal of Housing
and Homelessness, City Council included a work program in
the 2023-25 Financial Plan to initiate an update to the AASP to
allow mixed-use residential development, where appropriate
and consistent with the ALUP.
The City is proposing to amend the AASP to allow mixed-use
development within parcels zoned either C-S or M in ALUP
Safety Zone 6 subject to a CUP.
6
Commission’s Purview
The Planning Commission’s role is to review the proposed
AASP amendments for consistency with the City’s General
Plan, AASP, and applicable Zoning Regulations, and to make a
recommendation to the City Council.
7
Project Description
The Project Area includes all property within ALUP Safety
Zone 6 and designated as C-S or M within the 1,200-acre
AASP planning area.
The proposed amendments would allow for mixed-use
development in C-S and M zones of the AASP with the
approval of a CUP subject to specific findings and
development standards outlined in the City’s Zoning
Regulations.
No new development is proposed with this application.
No existing zoning designations are proposed to change.
8
AASP – C-S and M zoned areas that are in
Safety Zone 6
9
AASP – Existing C-S and M Zones
10
Of this total, 236.4 acres are fully within Safety Zone 6, while the
remaining 104.7 acres are at least partially within that safety zone.
AASP– Proposed Amendment
To approve a CUP for a mixed-use development in the C-S and M zones, the PC
shall find the project consistent with development standards outlined in SLOMC
Section 17.70.130 and make the following findings:
1)There is demonstrable water and sewer capacity to serve the project;
2)Any fiscal impact of the project to the City must be offset to achieve fiscal
neutrality;
3)There are no nearby uses that generate sufficient air emissions, noise,
odors or vibration to create an incompatibility with proposed residential
development;
4)Proposed residential uses are consistent with land use, safety or noise
restrictions set forth in the ALUP, and any residential portion of a mixed-use
development shall be wholly located within Safety Zone 6; and
5)There is adequate emergency response.
11
AASP– Proposed Amendment (Amended)
To approve a CUP for a mixed-use development in the C-S and M zones, the PC
shall find the project consistent with development standards outlined in SLOMC
Section 17.70.130 and make the following findings:
1)There is demonstrable water and sewer capacity to serve the project;
2)Any fiscal impact of the project to the City must be offset to achieve fiscal
neutrality;
3)There are no nearby uses that generate sufficient air emissions, noise,
odors or vibration to create an incompatibility with proposed residential
development;
4)Proposed residential uses are consistent with land use, safety or noise
restrictions set forth in the ALUP, and any residential portion of a mixed-use
development shall be wholly located within Safety Zone 6; and
5)There is adequate emergency response consistent with the Climate
Adaptation and Safety Element (CASE).
12
AASP– Proposed Amendment
Eliminate Table 4-1 that shows land use inventory and buildout
potential within the AASP.
The reasons for its removal are:
It is out of date,
Reflects buildout potential based on assumptions made
when the specific plan was first adopted 20 years ago, and
Any estimate of potential buildout within the area is likely to
be inaccurate because there is less interest in purely
commercial development.
13
Airport Land Use Commission (ALUC) Review
January 15, 2025. Preliminary Review of AASP
February 19, 2025. ALUC finds the proposed AASP
Amendment consistent with the Airport Land Use Plan (ALUP),
subject to conditions.
Key condition: Residential development to be wholly
located within Safety Zone 6.
If a parcel is in two safety zones, a mixed-use project
would apply different standards to the different portions of
the parcel.
14
Policy Consistency
Major City Goals
Housing and Homelessness. Support additional housing options
Work Program 3.1.c. Update AASP to include mixed use
Housing Element
Program 5.5. Update zoning regs to allow mixed use in C-S and M zones
Program 6.13. Consider GPA or rezone to allow more mixed use
Land Use Element
Policy 3.8.5. Encourage mixed use in commercial areas
15
Fiscal Impacts – Conclusions
Kosmont study examined two scenarios for AASP:
Development without mixed use. Fiscal surplus, but there
is not the demand for non-residential uses, so unrealistic
outcome.
Likely development with mixed use. Negative fiscal
impact, driven largely by tax sharing agreement with
County that limits property tax revenue in this portion of
the City.
16
Fiscal Impacts – Recommendations
Proposed AASP Amendment requires that any development
project must offset its fiscal impacts to be fiscally neutral.
Kosmont Recommendations:
Community Facilities District (CFD). Similar to the
mechanism used for Avila Ranch to offset the cost of
services, to be applied AASP-wide.
If no CFD in place, development would need to offset fiscal
impacts on a project-by-project basis.
Other options (not recommended): 1) renegotiate tax
sharing agreement with County; 2) Infrastructure Financing
District negotiation with County; 3) minimum commercial
use requirements in mixed-use projects.
17
CEQA Compliance
AASP/MASP Final EIR certified in 2003
Addendum to the Final EIR has been prepared for
the proposed AASP amendment
Individual developments in the AASP subject to
project-specific CEQA review
18
Next Steps
May 6, 2025: City Council Review
19
Recommendation
Adopt a Draft Resolution recommending approval to the
City Council to introduce an Ordinance to amend the
Airport Area Specific Plan to allow for mixed-use residential
development in the Service Commercial (C-S) and
Manufacturing (M) zones subject to a conditional use
permit, and to approve an Addendum to the Final EIR for
the Airport Area and Margarita Area Specific Plans.
20
Questions and Comments
21
Airport Area Specific Plan – ALUP Noise Contours
22
Policy Consistency: Major City Goal
Housing and Homelessness. Support the expansion of
housing options for all, and continue to facilitate the production
of housing, including the necessary supporting infrastructure,
with an emphasis on affordable and workforce housing as well
as accessibly connected development. Collaborate with local
non-profit partners, non-governmental agencies, the county, the
state, and federal governments to advocate for increased
funding and implementation of comprehensive and effective
strategies to prevent and reduce homelessness.
Consistent. By allowing mixed-use in the AASP, the proposed
project directly addresses this major city goal by creating a new
means of providing additional housing in the City.
23
Policy Consistency: Major City Goal
Work Program Item #3.1.c. Initiate an update to the
Airport Area Specific Plan to allow mixed-use residential
development, where appropriate and consistent with the County
Airport Land Use Plan.
Consistent. The proposed update to the AASP would fulfill
MCG work program item 3.1.c to allow additional residential
development as part of a mixed-use project consistent with the
Airport Land Use Plan (ALUP).
24
Policy Consistency: General Plan
Housing Element Program 5.5. Update the Zoning
Regulations to allow mixed-use development within Service
Commercial (C-S) and Manufacturing (M) zones without a use
permit within one year of the adoption of the Housing Element.
Housing Element Program 6.13. Consider General
Plan amendments, as projects are proposed, to rezone
commercial, manufacturing, or public facility zoned areas for
higher-density, infill or mixed-use housing, where compatible
with surrounding development…
Land Use Element Policy 3.8.5. Mixed Uses. The
City encourages compatible mixed uses in commercial districts.
25
Policy Consistency: Zoning Regulations
Mixed-Use in AASP consistent with what is already
allowed in C-S and M zones elsewhere in the City,
although a CUP would be required in AASP
Maximum density (24 density units/acre) in AASP
would be consistent with density allowed in C-S and
M zones elsewhere in City
26