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HomeMy WebLinkAboutE - OASP EIR Addendum Orcutt Area Specific Plan Area Parks Project Addendum to the Orcutt Area Specific Plan Environmental Impact Report SCH#2004011059 prepared by City of San Luis Obispo Public Works Department 919 Palm Street San Luis Obispo, California 93401 Contact: Erica Long, Project Manager prepared with the assistance of Rincon Consultants 1530 Monterey Street, Suite D San Luis Obispo, California 93401 March 2025 Table of Contents Addendum to the Orcutt Area Specific Plan Environmental Impact Report i Table of Contents 1 Introduction .................................................................................................................................... 1 1.1 Background and Purpose of the EIR Addendum ................................................................. 1 1.2 Basis for the Addendum ...................................................................................................... 6 2 Orcutt Area Specific Plan Parks Project Description ....................................................................... 8 2.1 Community Park Characteristics ......................................................................................... 8 2.2 Linear Park and Pocket Park Characteristics ....................................................................... 8 2.3 Retained Original Project Characteristics ........................................................................... 8 3 Impact Analysis ............................................................................................................................. 11 3.1 Final EIR Analysis Summary............................................................................................... 12 3.2 Environmental Impact Analysis of the OASP Parks Project .............................................. 13 3.3 Effects and Mitigation Measures ...................................................................................... 19 4 Conclusion..................................................................................................................................... 20 5 List of Preparers ............................................................................................................................ 21 Figures Figure 1 Orcutt Area Specific Plan Regional Location ....................................................................... 2 Figure 2 Orcutt Area Specific Plan Open Space and Parks Plan ........................................................ 4 Figure 3 Righetti Ranch and Jones Ranch residential development Vesting Tract Map .................. 5 Figure 4 Community Park Site Plan ................................................................................................... 9 Appendix Appendix A Mitigation Monitoring and Reporting Program City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project ii This page intentionally left blank. Introduction Addendum to the Orcutt Area Specific Plan Environmental Impact Report 1 1 Introduction This document has been prepared to serve as an addendum to the previously certified Final Environmental Impact Report (Final EIR) (State Clearinghouse [SCH] #2004011059) for the Orcutt Area Specific Plan (OASP). This addendum was prepared in accordance with the California Environmental Quality Act (CEQA) and the CEQA Guidelines. The City of San Luis Obispo was the lead agency for the adopted 2010 Final EIR and is the lead agency for the environmental review in this addendum. This addendum addresses the environmental effects of proposed modifications to the Orcutt Area Specific Plan required to support planned park improvements in the Orcutt Specific Plan Area. Section 15164 of the CEQA Guidelines requires an addendum under the following circumstances:  If some changes or additions are necessary but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred (Section 15164[a])  If only minor technical changes or additions are necessary or none of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred (Section 15164[b]) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section 15162, supported by substantial evidence, should be included in an addendum to an EIR, the lead agency's findings on the project, or elsewhere in the record (Section 15164[e]). This addendum includes this explanation and associated findings. 1.1 Background and Purpose of the EIR Addendum In March 2010 the San Luis Obispo City Council approved the Orcutt Area Specific Plan (OASP; City Council Resolution No. 10154 [2010 Series]) and certified the OASP Final Environmental Impact Report (2010 OASP Final EIR; SCH #2004011059). The OASP calls for a residential neighborhood and a variety of parks, recreational opportunities, and open space on 231 acres of land located at the southwestern edge of the city limits bounded by Orcutt Road, the Union Pacific Railroad, and Tank Farm Road, at the base of Righetti Hill. The regional location of the OASP is shown on Figure 1. The OASP includes a 7.6-acre neighborhood park with a variety of sports and recreation facilities and incorporation of the fringe of the adjacent Hansen/Barranca Creek corridor riparian area.. The 2010 OASP Final EIR programmatically evaluated the potential environmental impacts of the planned neighborhood park. The 2010 OASP Final EIR described the neighborhood park and linear park as follows: Neighborhood Park. The neighborhood park is to be located close to the residential neighborhoods and the mixed-use area in the central portion of the Plan Area. It would provide a variety of sports and recreation facilities and incorporates the fringe of the adjacent riparian area. Proposed facilities include a playground, ball fields for soccer and baseball, tennis courts, basketball courts, sand volleyball, picnic tables, and restrooms. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 2 Figure 1 Orcutt Area Specific Plan Regional Location Introduction Addendum to the Orcutt Area Specific Plan Environmental Impact Report 3 Linear Park. Along the western edge of the Plan Area, adjacent to the UPRR right-of-way, a linear park would be developed that would also provide stormwater detention. The linear park would have multiple uses, including paths for walking and bicycling, a floodable terrace system for stormwater detention, and a wetland habitat project. The Class I pedestrian/bicycle path would connect to the existing Class I bicycle path along the UPRR right-of-way and to the neighborhood park. The Linear Park would also have picnic tables, benches, viewpoints and educational signage about the wetland habitat project for the users of the park. There would be no night lighting in this facility. The Open Space and Parks Plan from the 2010 OASP Final EIR is shown on Figure 2. Subsequently, the planned parks were considered within the context of a residential development evaluated in the 2015 Final Initial Study-Mitigated Negative Declaration (2015 Final IS-MND; SCH #2015041039) for the Righetti Ranch and Jones Ranch residential development plans (GPA-SPA-ER- TR#3063/TR#3066). The Righetti Ranch/Jones Ranch Final IS-MND did not evaluate a specific project-level proposal for the parks. However, the Final IS-MND envisioned a neighborhood park that would occupy approximately 11.6 acres and would meet anticipated demand for park and recreational facilities, consistent with the assumptions about the park in the 2010 OASP Final EIR program-level analysis. The tract map for the Righetti Ranch and Jones Ranch residential developments that were evaluated in the 2015 Final IS-MND envisioned the neighborhood park in a similar location, but slightly further to the south, and approximately 4.0 acres larger than the 7.6- acre neighborhood park envisioned in the OASP. The linear park was envisioned in a similar location and scale as in the 2010 OASP Final EIR and 2015 Final IS-MND. The Righetti Ranch and Jones Ranch residential development Vesting Tract Maps are shown on Figure 3. The 2010 OASP Final EIR and the Righetti Ranch/Jones Ranch Final IS-MND identify potential impacts to special-status plant species and riparian habitat as a result of development of the parks. The 2010 OASP Final EIR includes specific design requirements and mitigation measures that apply to development of a neighborhood park and linear park within the OASP. However, because the 2015 Final IS-MND did not evaluate a project-level proposal for the parks, the 2015 Final IS-MND does not include specific mitigation in the proposed neighborhood park or linear park locations. Instead, the 2015 Final IS-MND states that park improvements would be overseen by the City, and “to that extent, future City plans for improvements to this site will require additional analysis and design- level mitigation measures to match the final park plans with appropriate special-status plant conditions.” Under current approvals, as a consultant to the City, RRM Design Group is preparing project-level plans and design details for a community park with similar amenities as the neighborhood park envisioned in the OASP and in a similar location to the neighborhood park envisioned in the Righetti Ranch and Jones Ranch residential development plans.1 In response to project-level detail now available for the community park, the City has identified the need for project-specific mitigation that effectively implements the design requirements and mitigation measures in the 2010 OASP Final EIR. The community park does not include substantial changes to the planned improvements envisioned for the original neighborhood park in these previous environmental documents. The proposed design of the community park is outside resource agency jurisdictional boundaries and is consistent with City policy regarding riparian habitat and buffer area setbacks. 1 The park description has been revised from neighborhood park to community Park because the park is envisioned to serve the entire city, in contrast to the neighborhood park described in the OASP, which was envisioned to primarily serve residents of single- and multi- family developments within the OASP. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 4 Figure 2 Orcutt Area Specific Plan Open Space and Parks Plan Introduction Addendum to the Orcutt Area Specific Plan Environmental Impact Report 5 Figure 3 Righetti Ranch and Jones Ranch residential development Vesting Tract Map City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 6 Due to the project-level detail now available for the community park and the need for project- specific mitigation that effectively implements the design requirements and mitigation measures in the 2010 OASP Final EIR for the community park as well as the linear park and pocket parks planned in the OASP area, the City has identified the need for an Addendum to the 2010 OASP Final EIR. Therefore, this Addendum to the 2010 OASP Final EIR describes differences between the proposed community park and neighborhood park described in the 2010 OASP Final EIR, describes the programmatic environmental review of the neighborhood park completed in the 2010 OASP Final EIR, and documents that none of the conditions requiring preparation of a Subsequent EIR or Negative Declaration described in CEQA Guidelines Section 15162 are met based on the design and components of the proposed OASP parks project. A detailed description of the project-level detail for the community park is provided in Section 2, Orcutt Area Specific Plan Parks Project Description. 1.2 Basis for the Addendum When a Final EIR has been adopted and a project is modified or otherwise changed after adoption, additional CEQA review may be necessary. The key considerations in determining the need for the appropriate type of additional CEQA review are outlined in Section 21166 of the Public Resources Code (CEQA) and Sections 15162 and 15164 of the CEQA Guidelines. Section 15162(a) of the CEQA Guidelines provides that a subsequent EIR is not required unless the following occurs: (1) Substantial changes are proposed in the project which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; (2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR or Negative Declaration 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, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the Negative Declaration was adopted, shows any of the following: (A) The project will have one or more significant effects not discussed in the previous EIR or negative declaration; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (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 proponents decline to adopt the mitigation measure or alternative; or (D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. Pursuant to Section 15164(a) of the CEQA Guidelines, an addendum to a previously certified Final EIR may be prepared if some changes or additions are necessary but none of the conditions described in Section 15162 have occurred that require preparation of a subsequent EIR. An Introduction Addendum to the Orcutt Area Specific Plan Environmental Impact Report 7 addendum should include a brief explanation of the agency’s decision not to prepare a subsequent EIR and be supported by substantial evidence in the record as a whole (Section 15164[e]). The addendum to a certified Final EIR need not be circulated for public review but it may be included in or attached to the Final EIR (Section 15164[c]). The decision-making body must consider the addendum with the Final EIR prior to making a decision on the project (Section 15164[d]). An addendum to the Final EIR is appropriate to address the OASP parks project, as well as the planned linear park and pocket parks in the OASP area, because the project-level details now available for the community park do not meet the conditions of Section 15162(a) for preparation of a subsequent EIR, and because the planned linear park and pocket parks in the OASP area are broadly consistent with park plans envisioned in the 2010 Final OASP EIR and 2015 Final IS-MND. As discussed in detail in Section 3, Impact Analysis, the project-level details for the community park would not result in new or more severe impacts related to: 1) substantial changes to the original project which requires major revisions to the Final EIR; 2) substantial changes to the circumstances under which the original project are being undertaken which will require major revisions to the Final EIR; or 3) new information of substantial importance showing significant effects not previously examined. The 2010 OASP Final EIR and this addendum serve as informational documents to inform decision- makers and the public of the potential environmental consequences of approving the OASP parks project. This addendum neither controls nor determines the ultimate decision for approval of the OASP parks project, described herein in Section 2, Orcutt Area Specific Plan Parks Project Description. The information presented in this addendum will be considered by the City of San Luis Obispo alongside the 2010 OASP Final EIR prior to bid authorization and issuing permits for grading and construction of the community park, linear park, and pocket parks in the OASP area. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 8 2 Orcutt Area Specific Plan Parks Project Description 2.1 Community Park Characteristics The community park would fulfill the vision of the neighborhood park originally envisioned in the OASP and Righetti Ranch and Jones Ranch residential development plans, providing approximately 11.6 acres of recreational and open space opportunities designed to serve residents of the entire city. The community park is proposed to be constructed in phases, as funding is available. Key features of the community park would include:  Grading and preparation of site, including removal of existing vegetation in improvement areas outside of creek limits.  Construction of the following amenities: basketball, tennis, bocce and pickleball courts, picnic areas, playground, soccer field, bike path, bike bump track, pump house, restrooms, and parking lots.  Construction of bioretention treatment areas and basins.  Installation of three pre-fabricated bridges and concrete abutments.  Installation of site utilities, including new potable and recycled water, sewer, and electrical infrastructure.  Installation of site furnishings, including benches, tables, waste receptacles, drinking fountain, and light poles.  Landscaping and irrigation improvements. The proposed community park site plan is depicted in in Figure 4. The community park location is generally consistent with the location of the neighborhood park envisioned in the OASP and would provide a similar range of public recreational amenities to those described in the 2010 OASP Final EIR. 2.2 Linear Park and Pocket Park Characteristics The linear park location is consistent with the size and location of the linear park envisioned in the OASP and would provide a similar range of public recreational amenities, stormwater retention, and trail connections as those described in the 2010 OASP Final EIR and 2015 Final IS-MND. The planned pocket parks envisioned in the OASP area would be located on lots of a residential size and scale (refer to Figure 3) and would provide similar amenities to the community park and linear park at a local neighborhood scale. 2.3 Retained Original Project Characteristics The community park, linear park, and pocket parks would be entirely within the OASP boundary evaluated in the 2010 OASP Final EIR. The 11.6-acre community park would disturb a somewhat larger area than the approximately 7.6-acre neighborhood park location envisioned in the 2010 Orcutt Area Specific Plan Parks Project Description Addendum to the Orcutt Area Specific Plan Environmental Impact Report 9 Figure 4 Community Park Site Plan City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 10 OASP Final EIR; however, this 4-acre increase in park area would correspondingly reduce the anticipated footprint of residential land use within the OASP. As a result, the community park would not increase the overall level of disturbance, grading, or construction activity relative to the assumptions established in the 2010 OASP Final EIR. The linear park would be consistent with the size and location of the linear park envisioned in the OASP Final EIR and 2015 Final IS-MND, and the pocket parks would be located on lots of a residential size and scale in locations identified for residential-scale development in the OASP Final EIR. With the exception of the design details and specific public recreational amenities for the community park, the OASP parks project would not otherwise modify the land use characteristics or other components of the OASP, and would involve similar infrastructural, roadway, parking, and utility improvements as anticipated in the 2010 OASP Final EIR. Therefore, this addendum to the 2010 OASP Final EIR applies only to the OASP parks project described herein. Prior certification of the 2010 OASP Final EIR and this addendum will be considered by the City Council when determining to approve authorization to advertise for construction bids. Grading and building permits required for the OASP parks project will be handled by the City as ministerial approvals. Impact Analysis Addendum to the Orcutt Area Specific Plan Environmental Impact Report 11 3 Impact Analysis As described under Section 0, Due to the project-level detail now available for the community park and the need for project-specific mitigation that effectively implements the design requirements and mitigation measures in the 2010 OASP Final EIR for the community park as well as the linear park and pocket parks planned in the OASP area, the City has identified the need for an Addendum to the 2010 OASP Final EIR. Therefore, this Addendum to the 2010 OASP Final EIR describes differences between the proposed community park and neighborhood park described in the 2010 OASP Final EIR, describes the programmatic environmental review of the neighborhood park completed in the 2010 OASP Final EIR, and documents that none of the conditions requiring preparation of a Subsequent EIR or Negative Declaration described in CEQA Guidelines Section 15162 are met based on the design and components of the proposed OASP parks project. A detailed description of the project-level detail for the community park is provided in Section 2, Orcutt Area Specific Plan Parks Project Description. Basis for the Addendum, when a Final EIR has been certified and a project is modified or otherwise changed after adoption, additional CEQA review may be necessary. In accordance with the CEQA Guidelines, the City of San Luis Obispo has determined that an addendum to the 2010 OASP Final EIR is the appropriate form of environmental review for the OASP parks project. This examination includes an analysis of the provisions of Section 21166 of CEQA and Sections 15162 to 15164 of the CEQA Guidelines and their applicability to the OASP parks project. As discussed in the impact analysis that follows, the OASP parks project would not introduce new significant environmental impacts beyond those which have already been identified and characterized in the Final EIR. None of the conditions described in CEQA Guidelines Section 15162 calling for preparation of a subsequent EIR have occurred or would occur as a result of the OASP parks project. This addendum will be considered by the City Council in making a decision on the OASP parks project. Appendix G of the CEQA Guidelines provides a checklist of 20 environmental issue areas that should be assessed in CEQA analyses. To provide a thorough analysis of potential impacts associated with the modified project, this addendum addresses all environmental issue areas described in the CEQA Guidelines. The key conclusions of the 2010 OASP Final EIR are summarized in Section 3.1. Because the existing environmental conditions in the project site and its surroundings remain substantially similar to the environmental conditions described in the 2010 OASP Final EIR, the potential environmental effects of the OASP parks project are similar to the original project for many of the environmental issue areas. Therefore, the OASP parks project’s potential environmental effects are discussed at the appropriate level of detail in Section 3.2, to determine whether the potential environmental impacts are consistent with the impact analysis provided in the 2010 OASP Final EIR, and whether any additional or modified mitigation would be necessary to minimize or avoid potentially significant environmental impacts. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 12 3.1 Final EIR Analysis Summary 2010 Orcutt Area Specific Plan Final EIR The 2010 OASP Final EIR evaluated a neighborhood park that would provide a variety of sports and recreation facilities and incorporate the fringe of the adjacent Hansen/Barranca Creek corridor riparian area. Planned facilities included a playground, ball fields for soccer and baseball, tennis courts, basketball courts, sand volleyball, picnic tables, and restrooms. The neighborhood park evaluated in the 2010 OASP Final EIR was envisioned to primarily serve residents of single- and multi-family developments within the OASP Area. The 2010 OASP Final EIR evaluated a linear park along the western edge of the OASP area that would provide basic recreational amenities (picnic tables, benches, viewpoints and educational signage), paths for walking and bicycling, a floodable terrace system for stormwater detention, and a wetland habitat project. While potential environmental impacts of the planned parks were evaluated programmatically, the 2010 OASP Final EIR also described the following policy-driven design requirements that apply specifically to parks/recreational facilities to minimize programmatic impacts identified in the 2010 OASP Final EIR:  Aesthetic Character. In response to the significant and unavoidable impact to the aesthetic character of the Specific Plan Area resulting from impeding views of Righetti Hill (Impact AES-2), the OASP requires the size and location of the neighborhood park to allow a view corridor from the center of the OASP Area to Righetti Hill.  Light and Glare. In response to the significant but mitigable impact to the nighttime sky due to lighting (Impact AES-3) the OASP requires compliance with Orcutt Area Lighting Standards (OASP Policy 4.4.3a) that include night lighting requirements for public areas, shielding of exterior lights within 100 feet of open space, and trail lighting standards.  Biological Resources. In response to the significant but mitigable impact to riparian woodland and wetland habitat, (Impact B-4), the OASP requires approximately 1.94 acres of wetland creation and 2.76 acres of riparian enhancement along the creek corridors in the neighborhood park and in the linear park to be implemented to improve the existing riparian habitat with no net loss to wetland and creek resources in the Orcutt Area (OASP Policy 2.2.3a).  Transportation. In response to the significant but mitigable impact associated with potential safety hazards to bicyclists, pedestrians, and transit patrons related to site access and internal circulation design (Impact T-3), the OASP requires neighborhood park frontage to include Class II bike lanes and separated sidewalks on both sides of the street, except at the commercial area (OASP Policy 5.2.3). These policy-level requirements for the neighborhood park (and other park/recreational facilities in the OASP area) are implemented through the design of parks facilities in the OASP area, rather than through specific mitigation requirements. In addition to these policy-level design requirements, the OASP Final EIR includes programmatic mitigation measures to address impacts to special-status plant species and riparian habitat. The primarily programmatic mitigation measures related to special-status plant species and riparian habitat from the 2010 OASP Final EIR that have a nexus to the proposed neighborhood park include: Impact Analysis Addendum to the Orcutt Area Specific Plan Environmental Impact Report 13  Measure B-2: A series of specific measures designed to reduce the significant program-level impact on special-status plant species and plant communities of special concern by requiring seasonally timed botanical surveys, special-status plant buffers, incidental take permits for removal of state-listed species, mitigation programs developed in consultation with CDFW for impacted species where total avoidance of the species is infeasible, annual monitoring to ensure successful establishment of all reintroduced or salvage plants, and creation of special-status plant species habitat at a minimum 2:1 ratio for habitat impacted by development.  Measure B-4: A series of specific measures designed to reduce the significant program-level impact on riparian woodland and wetland habitat by requiring trail setbacks from riparian habitat and buffer areas, development setbacks from riparian and wetland mitigation areas, and submittal of applicable permits and mitigation planning for permanent disturbance of wetland/riparian habitats. Therefore, the 2010 OASP Final EIR includes both project-level and program-level design requirements and mitigation measures that would apply to development of a community park, linear park, and pocket parks. 2015 Righetti Ranch/Jones Ranch Final IS-MND In addition to the 2010 OASP Final EIR that is the basis for this addendum, a neighborhood park was considered within the context of a residential development evaluated in the 2015 Final IS-MND for the Righetti Ranch and Jones Ranch residential development plans. The Righetti Ranch/Jones Ranch Final IS-MND did not evaluate a specific project-level proposal for the neighborhood park. However, the Final IS-MND envisioned a neighborhood park that would occupy approximately 11.6 acres and would meet anticipated demand for park and recreational facilities, consistent with the assumptions about the park in the 2010 OASP Final EIR program-level analysis. In the environmental analysis, the 2015 Final IS-MND identified the potential for a significant project-level impact to San Luis Obispo owl’s clover (Castilleja densiflora ssp. obispoensis) and associated project-level mitigation requirement for development of the residential development plans. However, because the Righetti Ranch/Jones Ranch project did not include a project-level proposal for the neighborhood park, the 2015 Final IS-MND did not include specific mitigation for potential impacts to this sensitive floral species in the neighborhood park location. Instead, the 2015 Final IS-MND stated that neighborhood park improvements would be overseen by the City, and “to that extent, future City plans for improvements to this site will require additional analysis and design-level mitigation measures to match the final park plans with appropriate special-status plant conditions.” As a result, the 2015 Final IS-MND offers an example of project-level implementation of mitigation from the 2010 OASP Final EIR that may be applied to future development of the neighborhood park, but does not include project-level mitigation applicable to development of a neighborhood park. 3.2 Environmental Impact Analysis of the OASP Parks Project With the exception of the design details and specific public recreational amenities for the community park, the OASP parks project described in Section 2, Orcutt Area Specific Plan Parks Project Description, would not otherwise modify the land use characteristics or other components of the OASP, and would involve similar infrastructural, roadway, parking, and utility improvements City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 14 as anticipated in the 2010 OASP Final EIR under Section 1.1, Background and Purpose of the EIR Addendum. Because the community park and linear park locations are generally consistent with the location of the neighborhood park and linear park envisioned in the OASP, the existing environmental conditions in the project site and its surroundings remain substantially similar to the environmental conditions described in the 2010 OASP Final EIR, and the project would provide a similar range of public recreational amenities to those described in the previously adopted and certified environmental documentation, the OASP parks project would not change any of the environmental conclusions from the 2010 OASP Final EIR, or otherwise result in any new or more substantial construction, project-level, or cumulative impacts related to the following environmental topics:  Aesthetics  Agriculture and Forestry Resources  Air Quality  Cultural Resources  Energy  Geology and Soils  Greenhouse Gas Emissions  Hazards, Hazardous Materials, and Safety  Hydrology and Water Quality  Land Use and Planning  Mineral Resources  Noise  Population and Housing  Public Services  Tribal Cultural Resources  Utilities and Service Systems  Wildfire There is no new information indicating that the OASP parks project would have new significant impacts or substantially more severe significant impacts with respect to these environmental topics than were identified in the 2010 OASP Final EIR, since the OASP parks project would is generally consistent with the location of the neighborhood park envisioned in the OASP and would provide a similar range of public recreational amenities to those described in the 2010 OASP Final EIR. All mitigation measures from the 2010 OASP Final EIR applicable to parks and recreational development in the OASP, including mitigation for potential air quality, cultural resources, and noise impacts, would continue to apply to the OASP parks project and would ensure potential environmental impacts would be reduced below the applicable thresholds of significance for these environmental topics (refer to Appendix A for a complete list of applicable 2010 OASP Mitigation Measures). Cultural resource surveys were completed as part of the 2010 OASP Final EIR (refer to 2010 OASP Final EIR Figure 4.5-1), and no significant archaeological resources were identified in locations planned for parks and recreational development in the OASP. As a result, applicable mitigation from the 2010 OASP Final EIR for cultural resources is limited to Mitigation Measure CR- 1(d) Archaeological Resource Construction Monitoring (Appendix A). The OASP parks project is anticipated to require project-level mitigation requirements that implement the applicable programmatic mitigation in the 2010 OASP Final EIR to address anticipated impacts to special-status plant species and riparian habitat. In addition, the OASP parks project has the potential to result in new regional recreational resources that were not envisioned in the 2010 OASP Final EIR, and has the potential to result in different traffic and multimodal circulation characteristics than envisioned in the 2010 OASP Final EIR. As a result of these key project considerations, the following discussion focuses on the potential impacts of the OASP parks project on Construction Effects, Biological Resources, Recreation, Transportation, and Cumulative Effects. Impact Analysis Addendum to the Orcutt Area Specific Plan Environmental Impact Report 15 Existing Setting Locations within the OASP area planned for the community park, linear park, and pocket parks have been subject to grading and stockpiling activities associated with the greater regional development within the OASP approved through the original 2010 OASP Final EIR as well as the 2015 Final IS-MND for the Righetti Ranch/Jones Ranch project. Locations identified in the 2010 OASP EIR for open space have been enhanced through habitat improvements associated with compensatory mitigation activities completed through these environmental processes. In addition, locations planned for future development within the OASP Area have been subject to temporary impacts associated with ongoing construction activities in the OASP area, including increased noise, criteria pollutant emissions, vehicular and pedestrian traffic. As such, the existing conditions on the ground in these locations is currently more disturbed than at the time the 2010 OASP Final EIR was prepared. Construction Effects The 2010 OASP Final EIR evaluated the potential for construction activity in the OASP Area to result in temporary impacts related to: Air Quality, Biological Resources, Cultural Resources, Drainage and Water Quality, and Noise; and required implementation of mitigation measures to reduce temporary construction impacts below applicable thresholds of significance. The community park location is generally consistent with the location of the neighborhood park envisioned in the OASP and would provide a similar range of public recreational amenities to those described in the 2010 OASP Final EIR. The linear park would be in a similar location and scale as evaluated in the 2010 OASP Final EIR. The planned pocket parks would be located on lots of a residential size and scale and would provide similar amenities to the community park and linear park at a local neighborhood scale. As a result, the modified project would require a similar level of construction activity as anticipated in 2010 OASP Final EIR. The proposed 11.6-acre community park is somewhat larger than the 7.6-acre neighborhood park envisioned in 2010 OASP Final EIR; however, the larger area planned to be developed by the community park would have been developed with residential uses under the land use plan envisioned in the 2010 OASP EIR. Because residential development typically requires more substantial construction activity on a per-acre basis than constructing park and other recreational uses, the community park would result in a reduction in total construction activity compared to the assumptions underlying the 2010 OASP Final EIR. Because the community park would result in reduced construction activity and would be required to implement all required mitigation measures for temporary impacts from the 2010 OASP Final EIR, the OASP parks project would not have new significant impacts or substantially more severe significant impacts with respect to potential construction effects compared to those disclosed in the 2010 OASP Final EIR. Biological Resources The potential environmental impacts of the neighborhood park on biological resources were evaluated programmatically in the 2010 OASP Final EIR, which included design requirements/mitigation measures to address impacts to special-status plant species and riparian habitat. The primarily programmatic mitigation measures from the 2010 OASP Final EIR that have a nexus to the OASP parks project include:  B-2(a) Seasonally Timed Botanical Surveys. This mitigation measure requires the submittal of seasonally timed floral surveys to determine the presence or absence of special-status plant species. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 16  B-2(b) Special-Status Plant Buffer. This mitigation measure requires site development plans to incorporate a minimum 50-foot avoidance buffer where special-status plant species are found.  B-2(c) Incidental Take Permit. This mitigation measure requires submittal of an incidental take permit for removal of state-listed species prior to grading activities.  B-2(d) Special-Status Species CDFG-Approved Mitigation Plan. This mitigation measure requires development of a mitigation program, in consultation with CDFG, if total avoidance of the species is infeasible.  B-2(e) Special-Status Plant Monitoring Frequency. This mitigation measure requires annual monitoring for at least five years to ensure successful establishment of all reintroduced or salvage plants, and no net loss of special-status plant species or their habitats.  B-2(f) Special-Status Species Habitat Replacement. This mitigation measure requires creation of two acres of special-status plant species habitat for every one acre of habitat impacted by development. If resource agencies require a higher replacement ratio than 2:1, their requirements would prevail.  B-3(a) Construction Requirements. This mitigation measure requires development under the Specific Plan to abide by the requirements of the City Arborist for construction.  B-4(a) Trail Setbacks. This mitigation measure requires setbacks of trails out of riparian habitat and the buffer area, for a minimum distance of 20 feet from top of bank or the edge of riparian canopy, which is farther. For wetland habitat, trails shall be setback at a minimum distance of 30 feet and shall not be within the buffer. Native plant species shall be planted in the area between the trail and the wetland/riparian habitat.  B-4(b) Development Setbacks. This mitigation measure requires development setbacks of at least 20 feet, as well as fence/landscape buffers, for development that abuts riparian and wetland mitigation areas.  B-4(c) Riparian/Wetland Mitigation. This mitigation measure requires submittal of applicable permits and a Mitigation Plan for areas of disturbance to wetland/riparian habitat, if such habitat is proposed for removal.  B-5(a) Bird Pre-Construction Survey. This mitigation measure requires scheduling initial ground- disturbing activities and tree removal outside of the nesting season between September 15 and February 1, or conducting a pre-construction survey for active nests within the limits of grading no more than 30 days prior to the start of any construction activities.  B-5(b) Burrowing Owl Survey. This mitigation measure requires pre-construction surveys for burrowing owls during both the wintering and nesting seasons (unless the species is detected on the first survey) in potentially suitable habitats prior to construction.  B-5(c) Monarch Pre-Construction Survey. This mitigation measure requires scheduling ground- breaking activities outside of the monarch roosting season between October and March, or conducting a pre-construction survey for active monarch roost sites within the limits of grading two weeks prior to any construction activities.  B-5(d) VPFS Sampling Surveys. This mitigation measure requires USFWS protocol level sampling surveys prior to development in areas shown as potential VPFS habitat on Figure 4.4-2 of the 2010 Final OASP EIR.  B-5(e) FESA Consultation and Mitigation Regarding VPFS. This mitigation measure requires project design to identify setbacks from occupied VPFS habitat identified pursuant to Mitigation Measure B-5(d). Impact Analysis Addendum to the Orcutt Area Specific Plan Environmental Impact Report 17  B-6(c) Landscaping Plan Review. This mitigation measure requires final landscaping plans to be reviewed and approved by a qualified biologist, and lists plants that shall not be allowed as potential landscaping plants. The 2015 Final IS-MND for the Righetti Ranch/Jones Ranch project, located adjacent to the proposed OASP parks project location, did not include specific mitigation for potential impacts to this sensitive floral species in the neighborhood park location; however, this document provides an example of project-level implementation of mitigation from the 2010 OASP Final EIR for potential impacts to special-status plant species and riparian habitat that implements the programmatic mitigation from the 2010 OASP Final EIR. The proposed OASP parks project does not include substantial changes to the planned improvements envisioned in these previous environmental documents. The OASP parks project is outside resource agency jurisdictional boundaries, and is consistent with City policy regarding riparian habitat and buffer area setbacks and OASP Program 2.2.3a, which requires OASP development to provide wetland creation and riparian enhancement along the creek corridors in park area. City staff have coordinated with the project design team (RRM Design Group) and environmental contractors (Rincon Consultants, Inc. [Rincon]) to implement the mitigation measures related to special-status plant species and riparian habitat from the 2010 OASP Final EIR that are applicable to the OASP parks project (primarily those measures under Measure B-2 and Measure B-4). Appendix A to this report is a Mitigation Monitoring and Reporting Program table that describes each of the Mitigation Measures from the 2010 OASP Final EIR that apply to the OASP parks project, and describes the implementing actions that have been completed to date. Applicable measures related to biological resources that have yet to be implemented includes those related to construction requirements (Measure B-3), pre-construction wildlife surveys (Measure B-5), and landscaping plan review (Measure B-6). Implementation of all applicable mitigation for impacts to biological resources identified in the 2010 OASP Final EIR would ensure the OASP parks project would not result in new or substantially greater impacts to special-status plant species or riparian habitat in comparison to the conclusions of the 2010 OASP Final EIR. Transportation The potential environmental impacts of the neighborhood park on transportation were evaluated programmatically in the 2010 OASP Final EIR, which included goals, policies and programs intended to address safe and efficient site access and circulation within the OASP area, as well as design requirements/mitigation measures to address reduce impacts to roadway segments, intersections, and transit facilities to less than significant levels. However, none of the programmatic mitigation measures from the 2010 OASP Final EIR have a nexus to the OASP parks project, as the neighborhood park envisioned in the 2010 OASP Final EIR analysis did not substantially contribute to any of the identified transportation impacts. The proposed OASP parks project does not include substantial changes to the planned improvements envisioned in the 2010 OASP Final EIR. The OASP parks project design is consistent with the park-level design requirements from the 2010 OASP Final EIR for transportation, including OASP Program 5.2.3, which requires park frontage to include Class II bike lanes and separated sidewalks on both sides of the street (as shown in Figure 4, these multimodal transportation improvements have been implemented along Tiburon Way). City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 18 The 2010 OASP Final EIR notes that the neighborhood park was planned at the time to primarily serve the residents of the single and multi-family developments within the OASP area; however, the proposed OASP parks project has been designed as a regional-serving recreational resource. As a result, the OASP parks project has the potential to be a destination for users throughout the San Luis Obispo community, rather than only residents of the single and multi-family developments within the OASP area. This change may result in more recreational users coming to the proposed community park than would have been anticipated traveling to the neighborhood park in the 2010 OASP Final EIR. However, the community park would not generate new vehicle trips; rather, the community park would be a new potential destination for some vehicle trips that would otherwise be traveling to other parks or recreational facilities in the City. As a result, the proposed community park would not be expected to increase the number vehicle trips in the region. Therefore, the OASP parks project would not result in new or substantially greater transportation or circulation impacts in comparison to the conclusions of the 2010 OASP Final EIR. Recreation The potential environmental impacts of the neighborhood park on recreational resources were evaluated programmatically in the 2010 OASP Final EIR (in Section 1.5, Effects Found Not to be Significant), which concluded that the OASP designates land for the development of recreational facilities that will not have an adverse physical effect on the environment. The proposed OASP parks project does not include substantial changes to the planned improvements envisioned in the 2010 OASP Final EIR. The 2010 OASP Final EIR notes that the neighborhood park was planned at the time to primarily serve the residents of the single and multi- family developments within the OASP area; however, the proposed OASP parks project has been designed as a regional-serving recreational resource. As a result, the OASP parks project has the potential to result in new regional recreational resources that were not envisioned in the 2010 OASP Final EIR. This change would not result in a new or otherwise increased environmental impact to recreational resources in comparison to the conclusions of the 2010 OASP Final EIR. In contrast, this change may be interpreted as an environmental benefit, enhancing the City’s network of recreational resources and opportunities. Therefore, the OASP parks project would not result in potential impacts to recreational resources that would be greater than anticipated in the 2010 OASP Final EIR; this impact would remain less than significant. Cumulative Effects A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The 2010 OASP Final EIR determined that implementation of required mitigation measures would reduce all the project’s potentially significant cumulative impacts to a less than significant level, with the exception of cumulative aesthetics and air quality impacts, which were identified as significant and unavoidable. The neighborhood park component of the OASP was not identified as a substantial contributor to either of these significant cumulative impacts, and the proposed OASP parks project would not result in new or substantially more severe project-level of cumulative impacts to either aesthetics or air quality. Because the OASP parks project would be located in a similar area than anticipated for the neighborhood park envisioned in 2010 OASP Final EIR, would require in a similar level of construction activity as anticipated in the 2010 OASP Final EIR, and would implement all required Impact Analysis Addendum to the Orcutt Area Specific Plan Environmental Impact Report 19 mitigation measures for temporary impacts from the 2010 OASP Final EIR, the OASP parks project would not change any of the environmental conclusions from the 2010 OASP Final EIR, or otherwise result in any new or substantially more severe cumulative impacts compared to those disclosed in the 2010 OASP Final EIR. 3.3 Effects and Mitigation Measures The OASP parks project is consistent with the environmental analysis and conclusions in the certified 2010 OASP Final EIR and would not result in new or substantially more severe impacts beyond those identified in the 2010 OASP Final EIR. Mitigation measures for potential impacts to special-status plant species and riparian habitat identified in the 2010 OASP Final EIR remain applicable to the proposed OASP parks project, and no new mitigation measures are required to ensure the project’s potential environmental impacts would remain less than significant. City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 20 4 Conclusion As discussed in Section 3, Impact Analysis, there are no new or substantially more severe impacts associated with the modified project than those identified and mitigated for in the 2010 OASP Final EIR. Implementation of mitigation measures required in the 2010 OASP Final EIR continue to be required as part of the proposed OASP parks project. With the implementation of required mitigation, the modified project would not result in a new significant environmental effect, or a substantial increase in the severity of previously identified effects. The modified project does not involve any substantial changes that require major revisions to the 2010 OASP Final EIR. This conclusion is consistent with the environmental analysis and conclusions presented in the Final EIR. Therefore, the project is consistent with the requirements of Sections 15162 and 15164 of the CEQA Guidelines, and a subsequent EIR is not required, because no new impacts or impacts of substantially greater severity than previously described would occur as a result of the OASP parks project. Therefore, the following determinations have been made:  No further evaluation of environmental impacts is required for the OASP parks project;  No subsequent EIR is necessary per CEQA Guidelines Section 15162; and  This addendum is the appropriate level of environmental analysis and documentation for the OASP parks project in accordance with CEQA Guidelines Section 15164. Pursuant to CEQA Guidelines Section 15164(c), this addendum will be included in the public record for the 2010 OASP Final EIR. Documents related to this addendum will be available on the City of San Luis Obispo’s website at https://www.slocity.org/. List of Preparers Addendum to the Orcutt Area Specific Plan Environmental Impact Report 21 5 List of Preparers This addendum was prepared by Rincon Consultants, Inc. under contract to the City of San Luis Obispo. Persons and firms involved in data gathering, analysis, project management, and quality control include: City of San Luis Obispo Timothea Tway, Community Development Director Shawna Scott, Special Projects Manager, Public Utilities Department Erica Long, Project Manager Rincon Consultants, Inc. Megan Jones, MPP, Principal Colby Boggs, Principal Ecologist Chris Bersbach, MESM, Senior Supervising Environmental Planner Frances McKenchie, Biologist Paul Rigby, Geographic Information Systems Analyst Alvin Flores, Publishing Specialist City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 22 Appendix A Mitigation Monitoring and Reporting Program List of Preparers Addendum to the Orcutt Area Specific Plan Environmental Impact Report 23 Implementation of Applicable Mitigation from the 2010 OASP Final EIR Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments Air Quality AQ-3(a) Application of CBACT (Best Available Control Technology for construction related equipment) The following measures shall be implemented to reduce combustion emissions from construction equipment where a project will have an area of disturbance greater than 1 acre.  Specific Plan applicants shall submit for review by the Community Development Department and Air Pollution Control District (APCD) staff a grading plan showing the area to be disturbed and a description of construction equipment that will be used and pollution reduction measures that will be implemented. Upon confirmation by the Community Development Department and APCD, appropriate CBACT features shall be applied. The application of these features shall occur prior to Specific Plan construction.  Specific Plan applicants shall be required to ensure that all construction equipment and portable engines are properly maintained and tuned according to manufacturer’s specifications.  Specific Plan applicants shall be required to ensure that off-road and portable diesel-powered equipment, including but not limited to bulldozers, graders, cranes, loaders, scrapers, backhoes, generator sets, compressors, auxiliary power units, shall be fueled exclusively with CARB motor vehicle diesel fuel (non-taxed off-road diesel is acceptable).  Specific Plan applicants shall be required to install a diesel oxidation catalyst on each of the two pieces of equipment projected to generate the greatest emissions. Installations must be prepared according to manufacturer's specifications. These conditions shall be noted on all project grading and building plans. The applicant will also be required to secure necessary permits from the San Luis Obispo Air Pollution Control District before the onset of grading or demolition activities including, but not limited to additional dust control measures and evaluation for Naturally Occurring Asbestos. The applicant shall present evidence of a plan for complying with these requirements prior to issuance of a grading or building permit from the City. The applicant shall provide the City with the name and telephone number of the person responsible for ensuring compliance with these requirements. The Building Inspector and Public Works Inspectors shall conduct field monitoring. City of San Luis Obispo AQ-3(b) Dust Control The following measures shall be implemented to reduce PM10 emissions during all Specific Plan construction:  Reduce the amount of the disturbed area where possible.  Use water trucks or sprinkler systems in sufficient quantities to prevent airborne dust from leaving the site. Water shall be applied as soon as possible whenever wind speeds exceed 15 miles per hour. Reclaimed (non-potable) water should be used whenever possible.  All dirt-stock-pile areas shall be sprayed daily as needed.  Permanent dust control measures shall be identified in the approved Specific Plan re-vegetation and landscape plans and implemented as soon as possible following completion of any soil disturbing activities.  Exposed ground areas that are planned to be reworked at dates greater than one month after initial grading shall be sown with a fast-germinating native grass seed and watered until vegetation is established.  All disturbed soil areas not subject to re-vegetation shall be stabilized using approved chemical soil binders, jute netting, or other methods approved in advance by the APCD. These conditions shall be noted on all project grading and building plans. The applicant will also be required to secure necessary permits from the San Luis Obispo Air Pollution Control District before the onset of grading or demolition activities including, but not limited to additional dust control measures and evaluation for Naturally Occurring Asbestos. The applicant shall present evidence of a plan for complying with these requirements prior to issuance of a grading or building permit from the City. The applicant shall provide the City with the name and telephone number of the person responsible for ensuring compliance with these requirements. The Building Inspector and Public Works Inspectors shall conduct field monitoring. City of San Luis Obispo City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 24 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments  All roadways, driveways, sidewalks, etc., to be paved shall be completed as soon as possible. In addition, building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.  Vehicle speed for all construction vehicles shall not exceed 15 mph on any unpaved surface at the construction site.  All trucks hauling dirt, sand, soil or other loose materials shall be covered or shall maintain at least two feet of freeboard ( minimum vertical distance between top of load and top of trailer) in accordance with CVC Section 23114.  Install wheel washers where vehicles enter and exit unpaved roads onto streets, or wash off trucks and equipment leaving the site.  Sweep streets at the end of each day if visible soil material is carried onto adjacent paved roads. Water sweepers with reclaimed water shall be used where feasible. AQ-3(c) Cover Stockpiled Soils If importation, exportation, or stockpiling of fill material is involved, soil stockpiled for more than two days shall be covered, kept moist, or treated with soil binders to prevent dust generation. Trucks transporting material shall be tarped from the point of origin. These conditions shall be noted on all project grading and building plans. The applicant shall present evidence of a plan for complying with these requirements prior to issuance of a grading or building permit from the City. The applicant shall provide the City with the name and telephone number of the person responsible for ensuring compliance with these requirements. The Building Inspector and Public Works Inspectors shall conduct field monitoring. City of San Luis Obispo AQ-3(d) Dust Control Monitor On all projects with an area of disturbance greater than 1 acre, the contractor or builder shall designate a person or persons to monitor the dust control program and to order increased watering as necessary to prevent transport of dust off-site. These duties shall include holiday and weekend periods when work may not be in progress. These conditions shall be noted on all project grading and building plans. The applicant shall present evidence of a plan for complying with these requirements prior to issuance of a grading or building permit from the City. The applicant shall provide the City with the name and telephone number of the person responsible for ensuring compliance with these requirements. The Building Inspector and Public Works Inspectors shall conduct field monitoring. City of San Luis Obispo Biological Resources B-2(a) Seasonally Timed Botanical Surveys This mitigation measure requires the submittal of seasonally timed floral surveys to determine the presence or absence of special-status plant species. When an applicant requests entitlements from the City under the Specific Plan, the City shall require the submittal of seasonally timed directed floral surveys based on the target list of plant species to be completed in the spring and summer to determine the presence or absence of these species. The survey shall be conducted by a qualified biologist verified by the City. Up to three separate survey visits may be required to capture the flowering period of the target species. The location and extent of any rare plant occurrences observed on the site should be documented in a report and accurately mapped onto site-specific topographic maps and aerial photographs. If special-status plants are identified, the development pursuant to the Specific Plan shall submit written proof that the CDFG has been contacted. City of San Luis Obispo Rincon completed timed botanical surveys on the project site on March 26, April 30, and May 28, 2013, and on March 25, May 2, and June 11, 2014. B-2(b) Special-Status Plant Buffer This mitigation measure requires site development plans to incorporate a minimum 50-foot avoidance buffer where special-status plant species are found. Where special status plants are found, site development plans shall be modified to avoid such occurrences with a minimum buffer of 50 feet. The applicant seeking entitlement shall establish conservation easements for such preserved areas, prior to issuance of the first building permit for subsequent tracts. The Specific Plan shall be amended at that time to place these areas formally into open space, possibly as an overlay area. City of San Luis Obispo The community park project has been designed to incorporate avoidance buffers for special-status plant species identified during botanical surveys where feasible. Where avoidance of purple needlegrass grassland and San Luis Obispo owl’s-clover was determined by the City not to be feasible, impacts to these special-status plant species have been mitigated through implementation of B- List of Preparers Addendum to the Orcutt Area Specific Plan Environmental Impact Report 25 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments If total avoidance is economically or technologically infeasible then plants shall be salvaged and relocated under direction of an approved botanist, in accordance with Mitigation Measures B-2(c) through B-2(f). If total avoidance can be achieved, Mitigation Measures B-2(c) through B-2(f) would not be required. 2(d) Special-Status Species CDFG-Approved Mitigation Plan and B-2(f) Special- Status Species Habitat Replacement. B-2(c) Incidental Take Permit This mitigation measure requires submittal of an incidental take permit for removal of state-listed species prior to grading activities. In the event that state listed species are discovered, the applicant seeking entitlements shall submit to the City signed copies of an incidental take permit and enacting agreements from the CDFG regarding those species as necessary under Section 2081 of the California Fish and Game Code prior to the initiation of grading. If a plant species that is listed under the federal Endangered Species Act is discovered, the applicant seeking entitlements shall provide proof of compliance with the federal Endangered Species Act, inclusive as necessary of signed copies of incidental take permit and associated enacting agreements, to the City prior to the initiation of grading City of San Luis Obispo No state-listed plant species were observed during seasonally-timed botanical surveys conducted in 2013 and 2014; as such, no Incidental Take Permit was required. B-2(d) Special-Status Species CDFG-Approved Mitigation Plan This mitigation measure requires development of a mitigation program, in consultation with CDFG, if total avoidance of the species is infeasible. If total avoidance of the species occurrences is economically or technologically infeasible, a mitigation program shall be developed by the City in consultation with CDFG as appropriate. A research study to determine the best mitigation approach for each particular species to be salvaged shall be conducted. City of San Luis Obispo Rincon prepared the Special Status Plant and Natural Community Mitigation and Monitoring Plan to compensate for impacts to purple needlegrass grassland and San Luis Obispo owl’s-clover in August 2016. B-2(e) Special-Status Plant Monitoring Frequency This mitigation measure requires annual monitoring for at least five years to ensure successful establishment of all reintroduced or salvage plants, and no net loss of special-status plant species or their habitats. Monitoring shall occur annually and shall last at least five years to ensure successful establishment of all reintroduced or salvaged plants and no-net-loss of the species or its habitat. In the case of annual plants it is difficult to determine if there has been a net loss or gain in a five year period. Therefore an important component of the mitigation and monitoring plan shall be adaptive management. The adaptive management program shall address both foreseen and unforeseen circumstances relating to the preservation and mitigation programs. The plan shall include follow up surveys every five years in perpetuity or until a qualified biologist can demonstrate that the target special-status species has not experienced a net loss. It shall also include remedial measures to address negative impacts to the special- status plant species and their habitats (i.e.: removal of weeds, addition of seeding/planting efforts) if the species is suffering a net loss at the time of the follow up surveys. City of San Luis Obispo Special status plant monitoring for San Luis Obispo owl’s clover began in March 2025 and is expected to be completed by 2029. B-2(f) Special-Status Species Habitat Replacement This mitigation measure requires creation of two acres of special-status plant species habitat for every one acre of habitat impacted by development. If resource agencies require a higher replacement ratio than 2:1, their requirements would prevail. The primary goal of the mitigation and monitoring plan is to ensure a viable population and no-net-loss of special-status species habitat within the project site. To ensure the no-net-loss of a species, the applicant shall create two acres of occupied special-status species habitat for every one acre of habitat impacted by project development. If resource agencies require a higher replacement ratio than 2:1, their requirements would prevail. The creation of habitat can occur in conjunction with the mitigation/relocation of wildflower field habitat if the research study indicates that the wildflower field and specific special-status plant species can be relocated and cohabitate. City of San Luis Obispo Mitigation installation for purple needlegrass grassland/San Luis Obispo owl’s clover habitat was completed in December 2024. Successful reestablishment will be considered complete when at least 2.42 acres of grassland habitat container San Luis Obispo owl’s clover is mapped on-site, consistent with the monitoring requirements established by B-2(e) Special-Status Plant Monitoring Frequency. B-3(a) Construction Requirements Development under the Specific Plan shall abide by the requirements of the City Arborist for construction. Requirements shall include but not be limited to:  The protection of trees with construction setbacks from trees;  Construction fencing around trees; Compliance with mitigation measures will be reviewed with landscaping plans as part of the architectural review submittal and ultimately shown on improvement plans and construction drawings. This program shall be approved prior to site grading and overseen by the Natural Resources Manager. City of San Luis Obispo City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 26 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments  Grading limits around the base of trees as required; and  A replacement plan for trees removed including replacement at a minimum 1:1 ratio. B-4(a) Trail Setbacks This mitigation measure requires setbacks of trails out of riparian habitat and the buffer area, for a minimum distance of 20 feet from top of bank or the edge of riparian canopy, which is farther. For wetland habitat, trails shall be setback at a minimum distance of 30 feet and shall not be within the buffer. Native plant species shall be planted in the area between the trail and the wetland/riparian habitat. Trails shall be setback out of riparian habitat and out of the buffer area. The trail shall be a minimum distance of 20 feet from top of bank or from the edge of riparian canopy, whichever is farther. Trails shall be setback from wetland habitat at a minimum distance of 30 feet and shall not be within the buffer. Native plant species that will deter human disturbance shall be planted in the area between the trail and the wetland/riparian habitat including plants such as California rose (Rosa californica) and California blackberry (Rubus ursinus). No passive recreational use shall be allowed in the riparian or wetland habitats or drainage corridors. City of San Luis Obispo Rincon reviewed the community park development plans prepared by RRM Design Group in 2023 and confirmed to the satisfaction of City staff that trail setbacks are implemented in the community park design. B-4(b) Development Setbacks This mitigation measure requires development setbacks of at least 20 feet, as well as fence/landscape buffers, for development that abuts riparian and wetland mitigation areas. Development that abuts riparian and wetland mitigation areas shall also be setback at least 20 feet, and be buffered by an appropriately-sized fence and/or plants that deter human entry listed in B-4(a). City of San Luis Obispo Rincon reviewed the community park development plans prepared by RRM Design Group in in 2023 and confirmed to the satisfaction of City staff that development setbacks are implemented in the community park design. B-4(c) Riparian/Wetland Mitigation This mitigation measure requires submittal of applicable permits and a Mitigation Plan for areas of disturbance to wetland/riparian habitat, if such habitat is proposed for removal. If riparian and/or wetland habitat are proposed for removal pursuant to development under the Specific Plan, such development shall apply for all applicable permits and submit a Mitigation Plan for areas of disturbance to wetlands and/or riparian habitat. The plan shall be prepared by a biologist familiar with restoration and mitigation techniques. Compensatory mitigation shall occur on-site using regionally collected native plant material at a minimum ratio of 2:1 (habitat created to habitat impacted) in areas shown on figure 4.4-2 as directed by a biologist. The resource agencies may require a higher mitigation ratio. If the Orcutt Regional Basin is necessary as a mitigation site for waters of the U.S. and State it shall be designed as directed by a biologist taking into consideration hydrology, soils, and erosion control and using the final mitigation guidelines and monitoring requirements (U.S. Army Corps of Engineers, 2004). As noted above, the trail shall be setback out of the buffer area for riparian and wetland habitat. City of San Luis Obispo Rincon prepared the Wetlands, Waters, and Riparian Habitat Mitigation and Monitoring Plan to compensate for impacts to wetlands, waters, and riparian habitat in August 2014 and prepared a revised version that was approved by City staff in January 2017. Rincon also provided an addendum to the Wetlands, Waters, and Riparian Habitat Mitigation and Monitoring Plan in January 2022. Mitigation areas are planned to be installed concurrently with the phase during which corresponding impacts occur, or earlier, to minimize any potential temporal impacts. B-5(a) Bird Pre-Construction Survey This mitigation measure requires scheduling initial ground-disturbing activities and tree removal outside of the nesting season between September 15 and February 1, or conducting a pre-construction survey for active nests within the limits of grading no more than 30 days prior to the start of any construction activities (for ground- nesting burrowing owl see Mitigation Measure B-5[b]). To avoid impacts to nesting special-status bird species and raptors, all initial ground- disturbing activities and tree removal shall be limited to the time period between September 15 and February 1. If initial site disturbance, grading, and tree removal cannot be conducted during this time period, a pre-construction survey for active nests within the limits of grading shall be conducted by a qualified biologist at the site no more than 30 days prior to the start of any construction activities. If active nests are located, all construction work must be conducted outside a buffer zone of 250 feet to 500 feet from the nests as determined in consultation with the CDFG. No direct disturbance to nests shall occur until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and young have fledged the nest prior to the start of construction. City of San Luis Obispo B-5(b) Burrowing Owl Survey This mitigation measure requires pre-construction surveys for burrowing owls during both the wintering and nesting seasons (unless the species is detected on the first When an applicant requests entitlements from the City under the Specific Plan a qualified biologist shall conduct surveys for burrowing owls during both the wintering and nesting seasons (unless the species is detected on the first survey) in City of San Luis Obispo List of Preparers Addendum to the Orcutt Area Specific Plan Environmental Impact Report 27 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments survey) in potentially suitable habitats prior to construction in accordance with the guidelines described in the CDFG Staff Report on Burrowing Owl Mitigation (1995). potentially suitable habitats prior to construction in accordance with the guidelines described in the CDFG Staff Report on Burrowing Owl Mitigation (1995). Winter surveys shall be conducted on the entire project site between December 1 and February 1, and the nesting season survey shall be conducted between April 15 and July 15. If burrowing owls are detected within the proposed disturbance area, CDFG shall be contacted immediately to develop and implement a mitigation plan to protect owls and their nest sites. B-5(c) Monarch Pre-Construction Survey This mitigation measure requires scheduling ground-breaking activities outside of the monarch roosting season between October and March, or conducting a pre- construction survey for active monarch roost sites within the limits of grading two weeks prior to any construction activities. If initial ground-breaking is to occur between the months of October and March a pre-construction survey for active monarch roost sites within the limits of grading shall be conducted by a qualified biologist at the site two weeks prior to any construction activities. If active roost sites are located no ground-disturbing activities shall occur within 50 feet of the perimeter of the habitat. Construction shall not resume within the setback until a qualified biologist has determined that the monarch butterfly has vacated the site. City of San Luis Obispo B-5(d) VPFS Sampling Surveys This mitigation measure requires USFWS protocol level sampling surveys prior to development in areas shown as potential VPFS habitat on Figure 4.4-2 of the 2010 Final OASP EIR. Prior to development in areas shown as potential VPFS habitat on Figure 4.4-2 of the 2010 Final OASP EIR, current USFWS protocol level sampling surveys shall be conducted in all such areas. A report consistent with current Federal, State, and local reporting guidelines shall be prepared to document the methods and results of surveys. If VPFS are found, the report shall include a map that identifies the VPFS locations. Should the presence of additional special-status wildlife species be determined including California linderiella, a map identifying locations in which these species were found shall be prepared and included in the report. City of San Luis Obispo B-5(e) FESA Consultation and Mitigation Regarding VPFS This mitigation measure requires project design to identify setbacks from occupied VPFS habitat identified pursuant to Mitigation Measure B-5(d). If complete avoidance is not economically or technically feasible, then this mitigation measure requires Section 10 or Section 7 of the Federal Endangered Species Act (FESA) be used to authorize incidental take (depending on whether a Federal agency is involved in the project. If any VPFS individuals are located onsite pursuant to Mitigation Measure B-5(d), substantial setbacks from their identified habitat shall be implemented to avoid take of a Federally listed species. If complete avoidance is not economically or technically feasible, then Section 10 of the Federal Endangered Species Act (FESA) shall be used to authorize incidental take when no other Federal agency such as the Corps is involved. This process includes development of a Habitat Conservation Plan for protecting and enhancing the Federally listed species at a specific location in perpetuity. Species take can also be authorized under Section 7 of the FESA if a Federal agency is involved in the project (e.g., Corps Section 404 permitting for impacts to waters of the U.S. and/or Federal funding) and agrees to be the lead agency requesting Section 7 consultation. This consultation process takes at a minimum 135 days from the official request by the Federal lead agency. The compensatory mitigation ratio shall be determined by the appropriate resource agencies. Suitable replacement habitat shall be constructed either within the site boundaries or offsite. Figure 4.4-2 identifies areas that could be appropriate for onsite VPFS mitigation. Figure 4.4-2 is not intended to preclude development but shall be used as a starting point for incorporating VPFS mitigation sites into the development plan. VPFS mitigation areas shall be approved by a biologist familiar with VPFS habitat “creation” techniques. Enhancement of the onsite seasonal City of San Luis Obispo City of San Luis Obispo Orcutt Area Specific Plan Area Parks Project 28 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments freshwater wetland habitat that is undisturbed by project activities may also be a part of the mitigation program. It is important to note that VPFS habitat mitigation is still considered experimental. VPFS habitat mitigation is ambitious as it is costly, labor intensive, and difficult to ensure success. Habitat may be “created” only in an existing vernal pool landscape that provides suitable soils and a number of other specific ecological factors (USFWS, 2004). An alternative to onsite mitigation is the purchase of mitigation bank credits. Credits can be purchase by the acre as suitable mitigation for VPFS. There is currently no known mitigation bank with VPFS habitat occurring within San Luis Obispo County, however, mitigation banks may be available in the future. B-6(c) Landscaping Plan Review To ensure that project landscaping does not introduce invasive non-native plant and tree species to the region of the site, the final landscaping plan shall be reviewed and approved by a qualified biologist. The California Invasive Plant Council (Cal-IPC) maintains several lists of the most important invasive plants to avoid. The lists shall be used when creating a plant palette for landscaping to ensure that plants on the lists are not used. The following plants shall not be allowed as part of potential landscaping plans pursuant to development under the Specific Plan:  African sumac (Rhus lancea)  Australian saltbush (Atriplex semibaccata)  Black locust (Robinia pseudoacacia)  California pepper (Schinus molle) and Brazilian pepper (S. terebinthifolius)  Cape weed (Arctotheca calendula)  Cotoneaster (Cotoneaster pannosus), (C. lacteus)  Edible fig (Ficus carica)  Fountain grass (Pennisetum setaceum)  French broom (Genista monspessulana)  Ice plant, sea fig (Carpobrotus edulis)  Leafy spurge (Euphorbia esula)  Myoporum (Myoporum spp.)  Olive (Olea europaea)  Pampas grass (Cortaderia selloana), and Andean pampas grass (C. jubata)  Russian olive (Elaeagnus angusticifolia)  Scotch broom (Cytisus scoparius) and striated broom (C. striatus)  Spanish broom (Spartium junceum)  Tamarix, salt cedar (Tamarix chinensis), (T. gallica), (T. parviflora), (T. ramosissima)  Blue gum (Eucalyptus globulus)  Athel tamarisk (Tamarix aphylla) Compliance with mitigation measures will be reviewed with landscaping plans as part of the architectural review submittal and ultimately shown on improvement plans and construction drawings. City of San Luis Obispo Cultural Resources List of Preparers Addendum to the Orcutt Area Specific Plan Environmental Impact Report 29 Mitigation Measure Plan Requirements and Timing/Monitoring Responsible Agency or Party Compliance Verification Initial Date Comments CR-1(d) Archaeological Resource Construction Monitoring At the commencement of project construction, an orientation meeting shall be conducted by an archaeologist for construction workers associated with earth disturbing procedures. The orientation meeting shall describe the possibility of exposing unexpected archaeological resources and directions as to what steps are to be taken if such a find is encountered. An archaeologist shall monitor construction vegetation removal and initial rough grading. In the event that prehistoric or historic archaeological resources are exposed during this early phase of project construction, all earth disturbing work must be temporarily suspended or redirected until an archaeologist has evaluated the nature and significance of the find. After the find has been appropriately mitigated ( e.g., curation, preservation in place, etc.), work in the area may resume. The City should consider retaining a Chumash representative to monitor any field work associated with Native American cultural material. If human remains are exposed, State Health and Safety Code Section 7050.5 requires that no further disturbance shall occur until the County Coroner has made the necessary findings as to origin and disposition pursuant to Public Resources Code Section 5097.98. Requirements for cultural resource mitigation shall be clearly noted on all plans for project grading and construction. City of San Luis Obispo Noise N-1(a) Compliance with City Noise Ordinance Construction hours and noise levels shall be compliant with the City Noise Ordinance [ Municipal Code Chapter 9.12, Section 9.12.050(6)]. Methods to reduce construction noise can include, but are not limited to, the following:  Equipment Shielding. Stationary construction equipment that generates noise can be shielded with a barrier.  Diesel Equipment. All diesel equipment can be operated with closed engine doors and equipped with factory-recommended mufflers.  Electrical Power. Whenever feasible, electrical power can be used to run air compressors and similar power tools.  Sound Blankets. The use of sound blankets on noise generating equipment. Requirements for construction noise mitigation shall be clearly noted on all plans for project grading and construction. City of San Luis Obispo