HomeMy WebLinkAboutAttachment G - Section 15183 Consistency Checklist
Gas Works Mixed-Use Project
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183
prepared by
City of San Luis Obispo
Department of Community Development
919 Palm Street
San Luis Obispo, California 93401
Contact: Hannah Hanh, Associate Planner
prepared with the assistance of
Rincon Consultants, Inc.
1530 Monterey Street, Suite D
San Luis Obispo, California 93401
October 2025
ATTACHMENT G
ATTACHMENT G
Table of Contents
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 i
Table of Contents
Initial Study ............................................................................................................................................. 1
1. Project Title ......................................................................................................................... 1
2. Lead Agency Name and Address ......................................................................................... 1
3. Contact Person and Phone Number ................................................................................... 1
4. Project Sponsor’s Name and Address ................................................................................. 1
5. Project Location .................................................................................................................. 1
6. General Plan Land Use Designation .................................................................................... 4
7. Zoning.................................................................................................................................. 4
8. Surrounding Land Uses and Setting .................................................................................... 4
9. Description of the Project ................................................................................................... 6
10. Approvals Required ...........................................................................................................10
Determination ......................................................................................................................................11
Purview of the Environmental Checklist ..............................................................................................13
1 Aesthetics ..........................................................................................................................15
2 Agriculture and Forestry Resources ..................................................................................19
3 Air Quality .........................................................................................................................21
4 Biological Resources ..........................................................................................................27
5 Cultural Resources ............................................................................................................31
6 Energy ...............................................................................................................................36
7 Geology and Soils ..............................................................................................................38
8 Greenhouse Gas Emissions ...............................................................................................44
9 Hazards and Hazardous Materials ....................................................................................48
10 Hydrology and Water Quality ...........................................................................................52
11 Land Use and Planning ......................................................................................................58
12 Mineral Resources ............................................................................................................60
13 Noise .................................................................................................................................62
14 Population and Housing ....................................................................................................65
15 Public Services ...................................................................................................................67
16 Recreation .........................................................................................................................71
17 Transportation ..................................................................................................................73
18 Tribal Cultural Resources ..................................................................................................79
19 Utilities and Service Systems ............................................................................................83
20 Wildfire..............................................................................................................................87
21 Mandatory Findings of Significance ..................................................................................91
References ............................................................................................................................................95
Bibliography ..................................................................................................................................95
List of Preparers ............................................................................................................................98
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
ii
Tables
Table 1 Project Summary ................................................................................................................. 8
Table 2 Project Consistency with SLOAPCD Clean Air Plan ...........................................................22
Table 3 Construction Criteria Air Pollutant Emissions ...................................................................23
Table 4 Operational Criteria Air Pollutant Emissions ....................................................................23
Table 5 Project Consistency with the Climate Action Plan ............................................................45
Figures
Figure 1 Regional Location ................................................................................................................ 2
Figure 2 Project Site Location ........................................................................................................... 3
Figure 3 Project Site Plan .................................................................................................................. 9
Appendices
Appendix A Air Quality/Greenhouse Gas Modeling
Appendix B Historic Preservation Report
Appendix C Soils Engineering Report
Appendix D Phase I Environmental Site Assessment
Appendix E Phase II Environmental Site Assessment
Appendix F Stormwater Report
Appendix G Vapor Barrier Plan (Commercial)
Appendix H Vapor Barrier Plan (Residential)
Appendix I Noise and Vibration Calculations
ATTACHMENT G
Initial Study
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 1
Initial Study
1. Project Title
Gas Works Mixed-Use Project (EID-0178-2025)
2. Lead Agency Name and Address
City of San Luis Obispo
Planning Division, Community Development Department
919 Palm Street
San Luis Obispo, California 93401-3218
3. Contact Person and Phone Number
Hannah Hanh, Associate Planner
Community Development Department
City of San Luis Obispo
919 Palm Street
San Luis Obispo, California 93401-3218
805-781-7432
hhanh@slocity.org
4. Project Sponsor’s Name and Address
Alamo, LLC
1304 Garden Street
San Luis Obispo, California 93401
5. Project Location
The project site is comprised of three (3) legal lots located at 1390 Walker Street, 280 Pismo Street,
and 251 Pacific Street in the City of San Luis Obispo, San Luis Obispo County, California. The project
site is at the southern corner of the block between Pacific Street and Pismo Street and is bisected by
Pacific Pismo Alley (also referred to as Railroad Alley). The total area of the project site is
approximately 1.1 acres and consists of assessor parcels (APNs) 002-505-005 (0.33 acre), 002-505-006
(0.49 acre), and 002-505-001 (0.28 acre). Figure 1 shows the regional location of the project site and
Figure 2 shows the location of the project site in its immediate context.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
2
Figure 1 Regional Location
ATTACHMENT G
Initial Study
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 3
Figure 2 Project Site Location
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
4
6. General Plan Land Use Designation
The project site is in the Services and Manufacturing land use designation. The General Plan Land Use
Element defines the Services and Manufacturing designation as providing “for a wide range of service
and manufacturing uses to meet the needs of the city and some demands of the region” (General
Plan: Land Use Element 2014). Identified uses include, but are not limited to, business and
professional services, convenience restaurants, and residential uses as part of mixed-use projects.
7. Zoning
The project site includes a mix of zones with 1390 Walker Street and 280 Pismo Street (APNs 002-505-
005 and 002-505-006) zoned Service Commercial (C-S) and 251 Pacific Street (APN 002-505-001)
zoned for Service Commercial with a Mixed-Use Overlay (C-S-MU). Pursuant to San Luis Obispo
Municipal Code (SLOMC) Chapter 17.58, the MU Overlay requires a mix of residential and
nonresidential uses on the same site where mixed-use development would otherwise be at the
discretion of the property owner. This MU Overlay was established through the Mid-Higuera Street
Enhancement Plan (2001) to support the General Plan’s vision and goal of introducing a new mix of
uses in the Mid-Higuera Area (Mid-Higuera Street Enhancement Plan 2001). SLOMC Section 17.36.010
states that the purpose of the C-S zone is to “provide for a wide range of service and manufacturing
uses to meet local needs and some demands of the region, including services, limited retail, and other
business service uses that may be less appropriate in the City’s other commercial zones” (San Luis
Obispo Zoning Regulations 2022). SLOMC Section 17.10.020 describes the allowed uses for the C-S
zone. Mixed-use projects, which include both residential and commercial aspects, are allowed in C-S
zones. SLOMC Chapter 17.36 includes development standards and additional regulations for the C-S
zone such as minimum lot size, building coverage, site area per dwelling unit, building height limits
and required setbacks. Section 17.70.130 lists specific regulations and standards for mixed-use
projects.
8. Surrounding Land Uses and Setting
As shown on Figure 2, the project site is surrounded by commercial and residential uses including an
auto shop and office buildings directly to the northeast, single family residences and commercial
building space across Pismo Street to the southeast, commercial and retail uses to the southwest, and
a restaurant across Pacific Street to the northwest. Less than 200 feet northeast along Pismo Street
are blocks of residential neighborhoods. Higuera Street diagonally intersects the corner of Pacific
Street and Walker Street, in the eastern corner of the project site. Across Higuera Street to the west
are more commercial buildings, including an auto shop and a motorsports dealership. U.S. Highway
101 (U.S. 101) is approximately 650 feet west of the project site, with the Marsh Street on- and off-
ramps to U.S. 101 located approximately 400 feet northwest of the project site.
The project site is relatively level and currently developed with a historic building, referred to as the
Old Gas Works, that was previously used by the Old Gas Works Company in the early 1900s. A historic
preservation report prepared for the project found the structure eligible for listing in the California
Register of Historical Resources. The structure is a unique example of the Mission Revival architectural
style in San Luis Obispo and is associated with E. S. Hoyt, a prominent figure in regional gas works
engineering and construction, who was pivotal in the selection and acquisition of the Pismo Street
ATTACHMENT G
Initial Study
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 5
site (Carr 2024; revised 2025). There are no other structures on the 1.1-acre site. The remaining vacant
portion of the project site is comprised of flattened dirt and loose gravel.
The project site as a whole had been contaminated due to historical gas plant activities that took place
on the site by the previous owner (Pacific Gas & Electric [PG&E]). Under the oversight of the
Department of Toxic Substances Control (DTSC), PG&E subsequently remediated the PG&E-related
contaminants to unrestricted use on the project site, except for the restricted soil area directly
underneath and immediately surrounding the Old Gas Works in order to protect the structural
integrity of the historic building. This overall remediation effort dates to 2007 and was certified to be
complete by DTSC in 2021. The restricted soil area remains protected from exposure by the existing
cap, which includes gravel cover, concrete footings, and foundation overlying soil within and
immediately surrounding the footprint of the historic building. As part of the investigation and
remediation work completed by PG&E, unrelated contamination from an offsite perchloroethylene
(PCE) plume was discovered1. To address both the residual PGE-related contamination located
directly underneath and immediately surrounding the Old Gas Works and discovered PCE
contamination from the offsite plume, DTSC placed land use covenants and required operation and
maintenance plans for all three (3) properties, which prohibited certain uses and activities2 unless
further evaluation by and written approval from DTSC is obtained and required ongoing maintenance
and annual cap inspection and groundwater reporting. In its entirety, the site remediation activities
included excavating and removing soils exceeding cleanup goals; offsite disposal of the contaminated
soils; and backfilling with clean imported fill and gravel cover. Post-remediation efforts include land
use covenants to ensure DTSC oversight in future development of the site and implementation of an
operation and maintenance plan to ensure ongoing compliance. DTSC may provide the applicant with
written approval to allow these prohibited uses and/or activities based on (a) further data; (b) risk
assessment of the data; and (c) engineering controls or other risk management measures.
A portion of the project site at 251 Pacific Street (APN 002-505-001) is located within the Mid-Higuera
Area, where goals and objectives of the Mid-Higuera Street Enhancement Plan include reducing or
mitigating flood hazards, implementing circulation and street improvements, preserving the area’s
historic resources and scenic viewshed, using the creek area as an amenity in the future use and
design of private developments, and encouraging compatible and appropriate mixed-uses, including
dwellings, within commercial areas (Mid-Higuera Street Enhancement Plan 2001). Data from the
Federal Emergency Management Agency indicates the project site is located within a 100-year flood
zone (AE Flood Zone) due to its proximity to San Luis Obispo Creek (FEMA’s National Flood Hazard
Layer 2024). The portion of the project site within the Mid-Higuera Street Enhancement Plan area is
subject to additional regulations and policies, including specific drainage and flood control measures,
which the project would be required to comply with. In addition, this portion of the project site is
adjacent to a planned closure of the Pacific-Higuera-Walker intersection that would be constructed
as part of the City’s Capital Improvement Project referred to as Higuera Complete Streets (State
Clearinghouse No. 2025071184).
1 PG&E did not cause and is not responsible for the PCE contamination. Accordingly, the PCE contamination is being addressed un der the
oversight of DTSC under a separate remediation effort (San Luis Obispo PCE Plume, State Clearinghouse No. 2024120528).
2 Prohibited uses include residences for human habitation, hospitals for humans, schools for people under 18 years of age, and daycares for
children. Prohibited activities include disturbance of the existing cap; drilling for water, oil, or gas; extraction of removal of groundwater;
and activities that may alter, interfere with, or affect the integrity or effectiveness of investigative, remedial, monitoring, operation or
maintenance system of activity for the property.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
6
9. Description of the Project
The project includes (a) a tentative parcel map for a common interest subdivision (i.e., condominium
project) with one lot containing commercial and residential units and (b) construction of a new 49-
unit, four-story residential building; two (2) parking lots; and the adaptive reuse of the existing Old
Gas Works building. Adaptive reuse of the historic Old Gas Works building includes tenant
improvements to accommodate a future restaurant, construction of an addition to the existing
structure to serve as the kitchen and restroom for the restaurant, reuse of the historic doors and
window as part of an interpretive panel on the interior, and establishment of outdoor seating areas.
The project also includes internal walkways, landscaping, stormwater management features,
common open space amenities, and a trash enclosure. The residential units include studios to two-
bedroom apartments with gross floor areas ranging from 465 square feet to 930 square feet. Most
units would have a private ground floor patio or private balcony and all would have access to the
shared stairways and an elevator. Shared indoor amenities for residents would include a
lounge/lobby, a fitness center, bike storage, and a roof deck within the residential building. Shared
outdoor amenities would include a courtyard, bike parking, raised planters, and decorative paver
walkways. Parking lots would be constructed at 251 Pacific Street (APN 002-505-001) with ingress and
egress via Pacific Street and Pismo Pacific Alley, and at 280 Pism o Street (APN 002-505-006) with
ingress and egress via Pismo Street and Pismo Pacific Alley.
In accordance with State Density Bonus Law, the project includes a 16 percent density bonus (eligible
for 20 percent but voluntarily forgoing the remaining four [4] percent) in exchange for dedicating five
percent of the base residential units to very low-income households. The project would include two
(2) one-bedroom units deed-restricted to very low-income households to satisfy affordability
requirements for the density bonus request. In order to construct the development at the proposed
density of 49 units, the density bonus request also includes a concession to reduce the number of
required parking spaces and various waivers and reductions to (a) allow ground-floor residential units
for the new residential building, (b) exceed maximum building height, and (c) reduce the
front/streetside building setback along Pismo Street.
The project would utilize helical piers3 to support the foundation of the proposed structures near the
existing Old Gas Works building. This foundation type would eliminate the need for pile driving. Other
than the installation of helical piers, planned excavation during construction of the project is not
anticipated to exceed four feet below existing grade.
To facilitate the project in accordance with the underlying land use covenants, a Standard Voluntary
Agreement was signed by the applicant/property owner and DTSC on July 1, 2024, which detailed the
property owner’s desire to request a variance at 1390 Walker Street to allow residential development
and comply with the remaining provisions of the land use covenants. The scope of this agreement
includes parcels located at 251 Pacific Street, 1390 Walker Street, 280 Pismo Street, and any offsite
area to which the contamination may have migrated from the site. DTSC would provide oversight and
review documents related to engineering and geological work for the project, which are subject to
DTSC’s approval. As a result of this agreement, the project includes the installation of vapor intrusion
mitigation systems designed to avoid potential adverse impacts from contaminated soil underneath
the residential and commercial buildings. The systems would consist of a layer of permeable
aggregate material placed beneath an impermeable vapor mitigation membrane. This membrane
would be installed wherever the building comes into contact with the ground, excluding foundation
3 A helical pier is a steel foundation element resembling a large screw with helical plates, designed to be driven into the ground using a
hydraulic system.
ATTACHMENT G
Initial Study
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 7
footings and grade beams. The vapor barriers would be positioned between the soil and the concrete
slabs of the new structures to reduce the risk of vapor intrusion.
Off-Site Improvements
While the City plans to implement the planned Pacific-Higuera-Walker closure as part of the Higuera
Complete Streets Project prior to construction and occupancy of this development project, the project
will be conditioned to install this street closure if the work has not yet been completed by the City.
This closure is intended to improve traffic safety by reducing conflict points at this intersection as
recommended in the Mid-Higuera Street Enhancement Plan. The street closure would be designed in
accordance with applicable City and State engineering design standards, including minor widening of
a portion of the Pacific-Pismo Alley and on-street parking restrictions along Walker Street to
accommodate emergency vehicle access, and would be subject to the satisfaction of the City Fire
Department to ensure these improvements would not introduce features that would substantially
increase hazards.
Per SLOMC Section 12.16.050, frontage improvements (e.g., curb, gutter, sidewalk, driveway aprons,
curb ramps, and pavement) will be required based on the scale of the project.
Based on the City’s currently adopted sewer capacity constrained map, the project site is located
within a capacity constrained area, and the applicant would be required to complete (a) off-site sewer
lateral replacements or (b) an identified in-lieu project consisting of a 375-foot sewer main
replacement within Pismo Street between Walker Street and Higuera Street. The City is currently in
process of updating the sewer capacity constrained map, which may remove the project site from the
capacity constrained area and therefore eliminate the project’s offset requirement. Because the
sewer map update is tentatively scheduled for the City Council’s consideration in December 2025, the
analysis in this checklist assumes that the applicant will be required to complete an in-lieu project.
Table 1 summarizes the project characteristics and Figure 3 shows the proposed site plan.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
8
Table 1 Project Summary
Building Data
Interior Rear Setback 60 feet
Corner Lot—Front / Street Side Setback 15 feet (Walker Street side) and 0 feet (Pismo Street side)
Residential – First Floor 11,302 sf
Residential – Second Floor 10,915 sf
Residential – Third Floor 10,915 sf
Residential – Fourth Floor 10,915 sf
Commercial Building 2,190 sf (existing 1,420 sf building and 770 sf addition)
Total Floor Area 46,237 sf (96% floor area ratio)
Total Site Coverage 15,223 sf (28% site coverage)
Residential Building Height 56.6 ft (59.5 ft at the stair tower)
Commercial Building Height 23 ft
Residential Units
Studio 6 units (465 sf)
1-Bedroom (<600 sf) 28 units (595 sf)
1-Bedroom (>600 sf) 4 units (655 sf)
2-Bedroom 11 units (930 sf)
Total 49 units
Density Units Allowed4 31.68 Density Units
Density Units Proposed5 30.64 Density Units
Parking Stalls
Standard (8’ 7”x 16’) 25 stalls
Electric Vehicle (8’ 7”x 16’) 40 stalls
Motorcycle (4’ x 8’) 4 stalls
Total 65 stalls
Bicycle Parking
Long-term 100 stalls
Short-term 16 stalls
Total 116 stalls
Notes: sf = square feet
4 According to the San Luis Obispo Zoning Regulation (2022), the base density is calculated by multiplying the maximum allowable density
– 24 density units (DU) per acre – by the area of the property, which is 1.1 acres.
24 DU/acre × 1.1 acres = 26.40 DU
The project includes a 20% density bonus. Therefore, 20% of the base density—5.28 DU—is added to the allowable total:
26.40 DU × 20% = 5.28 DU
26.40 DU + 5.28 DU = 31.68 DU
5 Density units are calculated based on the net area of a property subject to thresholds established per zone. Different types of dwelling
units are assigned different density unit (DU) values. According to the San Luis Obispo Zoning Regulations (2022), studio and one-
bedroom units under 600 square feet are assigned a value of 0.50 DU. The proposed project includes 6 studio units and 28 one-bedroom
units under 600 square feet, each valued at 0.50 DU; 4 one-bedroom units over 600 square feet, each valued at 0.66 DU; and 11 two-
bedroom units, each valued at 1.00 DU. The total density unit calculation for the project is as follows:
(6 × 0.50) + (28 × 0.50) + (4 × 0.66) + (11 × 1.00) = 30.64 DU.
ATTACHMENT G
Initial Study
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 9
Figure 3 Project Site Plan
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
10
10. Approvals Required
The City of San Luis Obispo is the lead agency with responsibility for approving the project. The project
would require the following discretionary approvals from the City of San Luis Obispo:
▪ Moderate Development Review (ARCH-0451-2024)
▪ Minor Subdivision (SBDV-0450-2024)
▪ Affordable Housing Concession (AFFH-0810-2024)
Discretionary approval from other public agencies is not required. Per the underlying land use
covenants and Standard Voluntary Agreement with the applicant, DTSC would oversee the project as
it relates to the historical PG&E contamination underneath and immediately surrounding the Old Gas
Works building, onsite PCE contamination from the offsite plume, and any nearby offsite area to
which contamination has or may have migrated from the site. Recommendations from the prepared
Phase I and II Environmental Site Assessments for the project construction, including the designs of
the vapor intrusion mitigation systems to allow occupancy of the Old Gas Works and new residential
building, are subject to DTSC’s review and approval. Prior to issuance of any construction permits by
the City, the applicant will be required to provide evidence that all necessary approvals from DTSC
have been obtained.
ATTACHMENT G
Determination
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 11
Determination
Based on this initial evaluation:
■ I find that the proposed Project is consistent with a Community Plan or Zoning and WOULD
NOT result in: 1) a peculiar impact that was not identified as a significant impact under the
prior Environmental Impact Report (EIR); 2) a significant impact that was not analyzed as
significant in the prior EIR; 3) a potentially significant offsite impact or cumulative impact not
discussed in the prior EIR; or 4) a more severe impact due to substantial new information
that was not known at the time of the prior EIR. New effects would be substantially mitigated
under uniformly applicable development policies or standards. Pursuant to California
Environmental Quality Act (CEQA) Guidelines Section 15183, NO FURTHER REVIEW is
required.
□ I find that the proposed Project WOULD result in: 1) a peculiar impact that was not identified
as a significant impact under the prior EIR; 2) a significant impact that was not analyzed as
significant in the prior EIR; 3) a potentially significant offsite impact or cumulative impact not
discussed in the prior EIR; or 4) a more severe impact due to substantial new information
that was not known at the time of the prior EIR. I find that FURTHER ENVIRONMENTAL
REVIEW is necessary to analyze those effects that are subject to CEQA pursuant to CEQA
Guidelines Section 15183.
Signature Date
Printed Name Title
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
12
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 13
Purview of the Environmental Checklist
The consistency checklist follows a format that outlines the eligibility criteria for an exemption from
additional environmental review in accordance with CEQA Guidelines Section 15183 and California
Public Resources Code (PRC) Section 21083.3. To streamline the environmental review process and
reduce the need to prepare repetitive environmental studies, a lead agency may prepare this
consistency checklist for projects that are consistent with the development density6 established by
the existing zoning, community plan, or general plan for which an Environmental Impact Report (EIR)
was certified. If a project is eligible for the consistency checklist under CEQA Guidelines Section 15183,
the lead agency shall limit its review to project-specific environmental effects, which:
a. Are peculiar to the project or parcel on which the project would be located;
b. Were not analyzed as significant effects in a prior EIR for the zoning action, general plan, or
community plan, which the project is consistent;
c. Are potentially significant off-site impacts and cumulative impacts which were not discussed
in the prior EIR for the zoning action, general plan, or community plan, which the project is
consistent; or
d. Are previously identified significant effects which, as a result of substantial new information
which was not known at the time the EIR was certified, are determined to have a more severe
adverse impact than discussed in the prior EIR.
An effect of a project on the environment shall not be considered peculiar to the project or the parcel
for the purposes of this section if uniformly applied development policies or standards have been
previously adopted by the city or county with a finding that the development policies or standards
will substantially mitigate that environmental effect when applied to future projects, unless
substantial new information shows that the policies or standards will not substantially mitigate the
environmental effect.
If the project would result in new specific effects or more significant effects, and uniformly applicable
development policies or standards would not substantially mitigate such effects, those effects are
subject to CEQA. With respect to the effects that are subject to CEQA, the lead agency is to prepare a
Mitigated Negative Declaration or EIR if the written checklist shows the effects of the infill project
would be potentially significant.
The project has been evaluated in accordance with the City of San Luis Obispo’s 2014 Land Use and
Circulation Elements Update (LUCE) EIR (State Clearinghouse No. 2013121019). This CEQA Guidelines
Section 15183 Consistency Checklist has been prepared in accordance with PRC Section 21000 et seq.
and the CEQA Guidelines, California Code of Regulations Section 15000 et seq. and concludes that the
project would not have significant effects on the environment that either have not been analyzed in
a prior EIR or are more significant than previously analyzed, or that uniformly applicable development
policies would not substantially mitigate. Pursuant to PRC Section 21094.5, such effects are exempt
from further CEQA review.
6 Per Government Code Section 65915, the granting of a density bonus, including any associated incentive/concession or waiver/reduction,
shall not require or be interpreted, in and of itself, to require a general plan amendment, zoning change, or other discretionary approval.
Furthermore, various goals, policies, and programs in the Land Use Element and Housing Element of the General Plan contemplate and
encourage projects with density bonuses. These policies and programs are reflected and implemented through SLOMC Chapter 17.140,
which describes the process for evaluating projects with density bonuses.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
14
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Aesthetics
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 15
1 Aesthetics
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Except as provided in Public Resources
Code Section 21099, would the project:
a. Have a substantial adverse effect on a
scenic vista?
□ □ ■ ■
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway?
□ □ ■ ■
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project
is in an urbanized area, would the
project conflict with applicable zoning
and other regulations governing scenic
quality?
□ ■ □ ■
d. Create a new source of substantial light
or glare that would adversely affect
daytime or nighttime views in the area?
□ ■ □ ■
Analysis in Previous Environmental Document
Impacts related to aesthetics were analyzed in Section 4.1, Aesthetics, on pages 4-3 through 4-29 of
San Luis Obispo’s 2014 LUCE EIR. Impacts on aesthetics from implementation of the 2014 LUCE were
determined to be less than significant.
The following summarizes the applicable analysis from the 2014 LUCE EIR and provides a review to
determine if project-specific impacts would occur that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project have a substantial adverse effect on a scenic vista?
The project site is not located within a “cone of view” as illustrated on Figure 11: Scenic Roadways
and Vistas of the City’s Conservation and Open Space Element (General Plan: Open Space Element
2006). Scenic vistas are generally located on the outskirts of the City limits facing the mountains and
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
16
grassy hills located outside of the City. The project site is located in a highly developed area of the
City where there are no scenic vistas. Because the project site is not located within or near a scenic
vista, the project would have no impact on scenic vistas.
NO IMPACT
b. Would the project substantially damage scenic resources, including but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
The project site is located approximately 650 feet west of U.S. 101 with intervening buildings,
roadways, and vegetation. U.S. 101 is identified on the California State Scenic Highway System Map
as eligible for a scenic highway designation but is not currently deemed a scenic highway. Therefore,
the project site is not located along or near any designated scenic highways, and the project would
have no impact on scenic resources within a state scenic highway.
NO IMPACT
c. Would the project, in non-urbanized areas, substantially degrade the existing visual character or
quality of public views of the site and its surroundings? (Public views are those that are
experienced from a publicly accessible vantage point). If the project is in an urbanized area, would
the project conflict with applicable zoning and other regulations governing scenic quality?
The City of San Luis Obispo defines Urban Uses as relatively intensive uses of land which normally
require City water and sewer services, including nearly all the types of development accommodated
in the following land use categories: low-, medium-, medium-high, and high-density residential;
neighborhood, tourist, and retail commercial; offices; services and manufacturing; business parks,
and most public buildings. The project site is located within the City’s urban reserve line; in a highly
developed, urbanized part of the City; and surrounded by retail commercial and medium to high
density residential uses (General Plan Glossary 2015). The 2014 LUCE EIR describes the visual
character of this area, the Mid and South Higuera Street area, as eclectic, inclusive of older buildings
closer to the downtown core and larger more modern offices to the south of the downtown core. The
project includes two separate buildings of different styles that would be consistent with the eclectic
nature of the neighborhood. The 2014 LUCE EIR identifies the historic Old Gas Works building as a
scenic feature of the City. The structure would remain visible from Pismo Street and its sidewalks and
would be open to the public. In accordance with State Density Bonus Law, the project includes a
request for a waiver to exceed the maximum allowed 35-foot height limitation and construct the
proposed residential building at 56.5 feet tall, which would be taller than most surrounding buildings.
This waiver to exceed the maximum building height is subject to review and approval by the final
review authority to ensure that findings per Density Bonus Law can be met. Furthermore, the project
is subject to review by the City’s Cultural Heritage Committee, which includes an evaluation to ensure
that the residential building is consistent with applicable historic preservation policies, guidelines, and
requirements. As proposed and with implementation of these City review processes, the project
would not conflict with applicable zoning and other regulations governing scenic quality and any
potential impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Aesthetics
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 17
d. Would the project create a new source of substantial light or glare that would adversely affect
daytime or nighttime views in the area?
The project site is located in the southern portion of the downtown core, surrounded by commercial
and residential uses that are existing sources of nighttime lighting and glare. Development of the
project site would result in an increase in ambient nighttime lighting through the addition of the
parking lot and security/safety lighting, and exterior fixtures associated with residential and
commercial structures. In addition, exterior building materials, windows, and surface paving materials
may cause glare that could affect the nearby commercial and residential uses.
The project would be required to conform to the City’s Lighting and Night Sky Preservation Ordinance
(SLOMC Section 17.70.100), which sets operational standards and requirements for lighting
installations. These include prohibitions on outdoor lighting that are misdirected, excessive, and/or
unnecessary, and minimum compliance requirements with the California Code of Regulations for
Outdoor Lighting and Signs (California Code of Regulations Title 24, Chapter 6). The project would also
be required to comply with applicable policies, programs, and guidelines pertaining to lighting, glare,
and spillover in the General Plan (Conservation and Open Space Policy 9.2.3 Outdoor Lighting) and
Community Design Guidelines (Section 6.1.C Lighting). Prior to site development, the developer would
be required to submit an overall lighting plan for review as part of the building permit application.
The lighting plan must demonstrate that the project complies with the requirements of SLOMC
Section 17.70.100, which prohibit lighting or illuminated devices that would create glare resulting in
a hazard or nuisance on other properties. As part of the building permit application, the lighting plan
would require review and approval by the Community Development Department prior to permit
issuance. Compliance with applicable City policies and regulations ensures the project would result in
a less than significant impact associated with the creation of new sources of exterior lighting and
glare.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant effects which are peculiar to the project or project site or
substantially more severe impacts related to aesthetics and visual resources, nor would there be
potentially significant off-site impacts, cumulative impacts, or previously identified significant effects
that were not discussed in the 2014 LUCE EIR. Furthermore, there are no previously identified
significant effects which, as a result of substantial new information not known at the time of the
previous environmental review, have been determined to have a more severe adverse impact than
those discussed in the previous environmental documents. Accordingly, additional environmental
review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
18
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Agriculture and Forestry Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 19
2 Agriculture and Forestry Resources
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Convert Prime Farmland, Unique
Farmland, Farmland of Statewide
Importance (Farmland), as shown on
maps prepared pursuant to the
Farmland Mapping and Monitoring
Program of the California Resources
Agency, to non-agricultural use?
□ □ ■ ■
b. Conflict with existing zoning for
agricultural use or a Williamson Act
contract?
□ □ ■ ■
c. Conflict with existing zoning for, or
cause rezoning of, forest land (as
defined in Public Resources Code
Section 12220(g)); timberland (as
defined by Public Resources Code
Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))?
□ □ ■ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use?
□ □ ■ ■
e. Involve other changes in the existing
environment which, due to their
location or nature, could result in
conversion of Farmland to non-
agricultural use or conversion of forest
land to non-forest use?
□ □ ■ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed agricultural impacts in Section 4.2, Agricultural and Forestry Resources,
on pages 4-31 through 4-49. Impacts to agricultural and forestry resources from implementation of
the 2014 LUCE were determined to be less than significant after mitigation.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
20
Project-Specific Impacts
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide
Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non-agricultural use?
b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
The project site is not located on or adjacent to property zoned for agriculture or under Williamson
Act Contract (California Williamson Act Enrollment Finder 2025b). The project site is categorized as
Urban and Built-Up Land, and is not adjacent to Prime Farmland, Unique Farmland, Farmland of
Statewide Importance (California Important Farmland Finder 2025a). Therefore, the project would
have no impact on Prime Farmland, Unique Farmland, Farmland of Statewide Importance, or existing
Williamson Act contracts.
NO IMPACT
c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined
in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code
Section 4526); or timberland zoned Timberland Production (as defined by Government Code
Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use?
The project site does not contain and is not adjacent to forest land or timberland. No impact would
occur.
NO IMPACT
e. Would the project involve other changes in the existing environment which, due to their location
or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest
land to non-forest use?
There is no forest or farmland on or adjacent to the project site. No impact would occur.
NO IMPACT
Conclusion
The project would have no new significant effects which are peculiar to the project or project site or
substantially more severe impacts related to agricultural and forestry resources, nor would there be
potentially significant off-site impacts, cumulative impacts, or previously identified significant effects
that were not discussed in the 2014 LUCE EIR. Furthermore, there are no previously identified
significant effects which, as a result of substantial new information not known at the time of the
previous environmental review, have been determined to have a more severe adverse impact than
those discussed in the previous environmental documents. Accordingly, additional environmental
review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Air Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 21
3 Air Quality
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Conflict with or obstruct implementation
of the applicable air quality plan?
□ □ ■ ■
b. Result in a cumulatively considerable net
increase of any criteria pollutant for
which the project region is non-
attainment under an applicable federal
or state ambient air quality standard?
□ ■ □ ■
c. Expose sensitive receptors to substantial
pollutant concentrations?
□ ■ □ ■
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed air quality impacts in Section 4.3, Air Quality, on pages 4-51 through 4-
59 and determined that odor-related impacts would be less than significant. Impacts associated with
short-term construction‐generated emissions were determined to be significant but mitigable. The
previous analysis concluded that long‐term air quality impacts could conflict with the applicable air
quality plan, violate or contribute substantially to an existing or projected air quality violation,
contribute a cumulatively considerable net increase of criteria air pollutants for which the region is
designated as non‐attainment, and/or expose sensitive receptors to substantial pollutant
concentrations. As a result, long‐term air quality impacts were considered significant and
unavoidable. This conclusion was based on the latest information at the time of analysis and does not
account for assumptions contained in the most recent version of the San Luis Obispo County Air
Pollution Control District (SLOAPCD) Clean Air Plan.
The following describes the applicable analysis in the 2014 LUCE EIR and provides a review to
determine if project-specific impacts would occur that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project conflict with or obstruct implementation of the applicable air quality plan?
The project site is located in the South Central Coast Air Basin (SCCAB) which covers San Luis Obispo,
Santa Barbara, and Ventura counties (Emissions by Air Basin 2025a). SLOAPCD monitors and regulates
the local air quality in San Luis Obispo County. SLOAPCD is required to monitor air pollutant levels to
ensure that National Ambient Air Quality Standards and California Ambient Air Quality Standards are
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
22
met and, if they are not met, to develop strategies to meet the standards. The SCCAB is currently in
nonattainment for the federal standards for ozone (eastern San Luis Obispo County only) and the
state standards for ozone, and state standards for particulate matter less than 10 microns in diameter
(PM10) (San Luis Obispo County Attainment Status 2025). Because the SCCAB is currently designated
nonattainment for federal and State standards for ozone and State standards for PM10, SLOAPCD is
required to implement strategies that would reduce pollutant levels to recognize acceptable
standards. SLOAPCD adopted the Clean Air Plan in 2001 which evaluates long-term emissions and
establishes programs to reach acceptable air quality levels (SLOAPCD 2001). The SLOAPCD Clean Air
Plan is the applicable air quality management plan for the project site.
Based on SLOAPCD’s CEQA Air Quality Handbook (2023), if a project is consistent with the land use
and transportation control measures in the Clean Air Plan, the project would be consistent with the
Clean Air Plan (Clean Air Plan 2023). The project’s consistency with applicable land use and
transportation control measures within the Clean Air Plan is described in Table 2. As shown in Table 2,
the project would be consistent with applicable land use and transportation control measures within
the Clean Air Plan. Therefore, the project would not conflict with the Clean Air Plan, and no impact
would occur.
Table 2 Project Consistency with SLOAPCD Clean Air Plan
Control Measure Consistency
Transportation
T-3 Bicycling and Bikeway
Enhancements
Consistent. The project provides bicycle parking on-site, thereby providing bicycle
infrastructure to promote the use of bicycles.
Land Use
L-1 Planning Compact
Communities
Consistent. The project is a mixed-use development that would provide both residential
and commercial uses on-site which would provide a balance of housing and jobs, in a
centralized downtown location that would facilitate occupants’ use of non-vehicular
modes of transportation. The combination of uses onsite, with the proximity to
downtown San Luis Obispo, would reduce vehicle trips for residents to utilize commercial
areas. Consistent with the Clean Air Plan, the proposed urban development is adjacent
to an existing bus stop which provides transit access and surrounding streets contain
sidewalks for pedestrian travel.
L-2 Providing for Mixed Land
Use
Consistent. The project is a mixed use development that would include residential and
commercial uses on-site.
L-4 Circulation Management Consistent. The project provides bicycle parking to promote alternative transportation.
In addition, the project site is adjacent to an existing bus stop which provides transit
access and surrounding streets contain sidewalks for pedestrian travel. The proposed
parking lots provide the minimum number of parking spaces necessary to remain
consistent with the City’s parking requirements. The minimal parking would promote the
use of alternative transportation modes.
Source: SLOAPCD 2001
NO IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Air Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 23
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for
which the project region is non-attainment under an applicable federal or state ambient air
quality standard?
The California Emissions Estimator Model (CalEEMod), version 2022.1.1.29, was used to estimate the
project’s air pollution emissions. CalEEMod uses project-specific information, including a project’s
land uses, construction equipment parameters, operational vehicle trips and energy use, and location,
to model a project’s construction emissions. CalEEMod modeling outputs are included in Appendix A.
Table 3 and Table 4 show the project’s estimated criteria air pollutant emissions from construction
and operation, respectively, and compare the project’s estimated emissions to SLOAPCD’s adopted
emissions thresholds. As shown in Table 3 and Table 4, the project is not expected to result in criteria
pollutant emissions that would exceed SLOAPCD construction thresholds and would not result in a
cumulatively considerable net increase of any criteria pollutant for which the SCCAB is in
nonattainment. Therefore, this impact would be less than significant.
Table 3 Construction Criteria Air Pollutant Emissions
Estimated Emissions
ROG NOx CO SO2 PM10 PM2.5
Construction Emissions (pounds per day) 83.9 13.2 14.5 0.02 3.46 1.9
Construction Emissions (tons per quarter) 0.14 0.24 0.30 <0.01 0.02 0.01
SLOAPCD Construction Thresholds (Daily) 137 pounds per day
(combined ROG
and NOx)
N/A N/A N/A 7 pounds
per day
SLOAPCD Construction Thresholds
(Quarterly)
2.5 tons
(combined ROG
and NOx)
N/A N/A 2.5 tons 0.13 tons
Thresholds Exceeded? No N/A N/A No No
ROG = reactive organic gases; NOX = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = particulate matter 10
microns or less in diameter; PM2.5 = particulate matter 2.5 microns or less in diameter
Source: SLOAPCD 2023; Appendix A
Table 4 Operational Criteria Air Pollutant Emissions
Estimated Emissions
ROG NOx CO SO2
PM10
Dust PM2.5
Operational Emissions (pounds per day) 2.5 0.9 7.0 0.01 0.7 0.2
Operational Emissions (annual) 0.5 0.2 1.2 <0.01 0.1 0.03
SLOAPCD Operational Thresholds (Daily) 25 pounds per day
(combined ROG
and NOx)
550
pounds
per day
N/A 25
pounds
per day
1.25
pounds
per day
SLOAPCD Operational Thresholds
(Annual)
25 tons
(combined ROG
and NOx)
N/A N/A 25 tons N/A
Thresholds Exceeded? No N/A N/A No No
ROG = reactive organic gases; NOX = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM10 = particulate matter 10
microns or less in diameter; PM2.5 = particulate matter 2.5 microns or less in diameter
Source: SLOAPCD 2023; Appendix A
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
24
c. Would the project expose sensitive receptors to substantial pollutant concentrations?
The nearest sensitive receptors to the project site are residential receptors located on Pismo Street
approximately 50 feet southeast of the project site. This analysis discusses the potential of the project
to expose these receptors to substantial pollutant concentrations.
Fugitive Dust
Fugitive dust would be generated during construction activities such as grading through the use of
construction equipment and disturbance of soil. As described in checklist question 3(b), the project
would not result in particulate matter emissions in excess of SLOAPCD’s regional thresholds for PM10
or PM2.5. SLOAPCD guidelines require projects within 1,000 feet of sensitive receptors to implement
standard mitigation measures to minimize fugitive dust emissions (CEQA Air Quality Handbook 2023).
For project construction activities at all sites, the City’s Special Provisions and specifications would
require the contractor implement applicable SLOAPCD fugitive dust measures as best management
practices to minimize localized fugitive dust emissions during construction. These measures include,
but are not limited to, watering to prevent airborne dust, stabilization of soils, limiting vehicle speeds
on the project site, and use of devices to prevent sand or dirt from falling out of trucks during
transport (CEQA Air Quality Handbook 2023). Operation of the project would not include activities
that could generate substantial fugitive dust. With the inclusion and implementation of SLOAPCD’s
standard mitigation measures for fugitive dust emissions reduction, the project’s potential to expose
nearby residences to substantial fugitive dust emissions would be less than significant.
Naturally Occurring Asbestos
Naturally occurring asbestos (NOA) has been identified by the California Air Resources Board (CARB)
as a toxic air contaminant. Serpentinite and ultramafic rocks are common throughout San Luis Obispo
and may contain naturally occurring asbestos (SLO APCD NOA Screening 2018). Under CARB’s Air Toxic
Control Measures related to construction and grading, a geologic evaluation is required to determine
of NOA is present prior to any grading activities at the project site. If NOA is identified at the site
during ground-disturbing activities, requirements outlined in CARB’s Air Toxic Control Measures
would be enforced, in addition to requirements stipulated in the National Emission Standard for
Hazardous Air Pollutants (40 Code of Federal Regulations Section 61, Subpart M -Asbestos). These
requirements include notifying SLOAPCD at least 10 days prior to commencing construction,
preparing an asbestos survey conducted by a Certified Asbestos Consultant, and implementation of
removal and disposal protocol and requirements for identified NOA. A SLOAPCD Permit to Operate
for Excavation of Contaminated Soils is included in the City’s Standard Specifications and Engineering
Standards. This Permit states that NOA and National Emission Standards for Hazardous Air Pollutants
requirements have been met, and monitoring, recordkeeping, and SLOAPCD notification procedures
are in place. With adherence to the SLOAPCD permit and State requirements for NOA abatement, the
project’s potential to expose nearby residences to NOA would be less than significant.
Toxic Air Contaminants
Toxic air contaminants are a diverse group of air pollutants that may cause or contribute to an
increase in deaths or serious illness, or that may pose a present or potential hazard to human health.
The primary Toxic air contaminants emitted by project implementation would be diesel particulate
matter (DPM) generated by heavy-duty equipment and diesel-fueled delivery and haul trucks during
construction activities. Due to its size, DPM is a subset of PM2.5 (Overview: Diesel Exhaust and Health
2025b). Generation of DPM from construction projects typically occurs in a single area for a short
ATTACHMENT G
Purview of the Environmental Checklist
Air Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 25
period. Dose is positively correlated with time, meaning a longer exposure period would result in a
higher exposure level for sensitive receptors. The risks estimated for a sensitive receptor are higher if
a fixed exposure occurs over a longer period of time.
Based on SLOAPCD’s CEQA Air Quality Handbook (2023), a project with a construction schedule
exceeding four months, and which would emit more than 0.13 tons of PM2.5 per quarter could
potentially expose sensitive receptors to substantial pollutant concentrations during construction. As
stated in checklist question 3(b), the maximum PM2.5 emissions during construction would be
approximately 0.01 tons per quarter which is below the 0.13 tons per quarter threshold (Appendix A).
Accordingly, construction would not result in substantial DPM emissions proximate to sensitive
receptors. In addition, construction personnel would be required to adhere to California Code of
Regulations Title 13 Section 2485, which prohibits idling of diesel-powered vehicles for over five
minutes to minimize DPM emissions.
Based on SLOAPCD’s CEQA Air Quality Handbook (2023), if project operation would result in greater
than 1.25 pounds per day of DPM emissions, a project could potentially expose sensitive receptors to
substantial pollutant concentrations during operation. As stated in the response to checklist question
3(b), the maximum PM2.5 emissions during construction would be approximately 0.2 pounds per day
which is below the 1.25 pounds per day threshold (Appendix A). Accordingly, project operation would
not result in substantial DPM emissions proximate to sensitive receptors.
Based on the discussions of fugitive dust, NOA, and toxic air contaminants above, the project’s
emissions would not expose sensitive receptors to substantial pollutant concentrations, and this
impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a
substantial number of people?
During construction activities, heavy equipment and vehicles would emit odors associated with
vehicle and engine exhaust. These odors would be localized to the immediate vicinity of the project
site and restricted to the duration of equipment use, which would be temporary and infrequent. In
addition, these odors would cease upon completion of project construction. Construction personnel
would be required to adhere to idling restrictions for on- and off-road vehicles and equipment which
would minimize diesel odors. Given the temporary and minimal nature of construction odors,
construction activity on the project site would not result in substantial odors adversely affecting a
substantial number of people.
SLOAPCD’s CEQA Air Quality Handbook (2023) identifies types of projects that would result in
potential long-term odor impacts, including asphalt batch plants, auto body shops, coffee roasters,
food processing facilities, sanitary landfills, and wastewater treatment plants. The project would not
involve the operation of facilities identified by SLOAPCD that could result in substantial odors.
Accordingly, project operation would not result in emissions such as odors adversely affecting a
substantial number of people, and this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
26
Conclusion
The project would have no new significant effects which are peculiar to the project or project site or
substantially more severe impacts related to air quality, nor would there be potentially significant off-
site impacts, cumulative impacts, or previously identified significant impacts that were not discussed
in the 2014 LUCE EIR. Furthermore, there are no previously identified significant effects which, as a
result of substantial new information not known at the time of the previous environmental review,
have been determined to have a more severe adverse impact than those discussed in the previous
environmental documents. Accordingly, additional environmental review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Biological Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 27
4 Biological Resources
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special-status species in local
or regional plans, policies, or regulations,
or by the California Department of Fish
and Wildlife or U.S. Fish and Wildlife
Service?
□ ■ □ ■
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service?
□ □ ■ ■
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal,
filling, hydrological interruption, or other
means?
□ □ ■ ■
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites?
□ □ ■ ■
e. Conflict with any local policies or
ordinances protecting biological
resources, such as a tree preservation
policy or ordinance?
□ □ ■ ■
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan?
□ □ ■ ■
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
28
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed biological resources impacts in Section 4.4, Biological Resources, on
pages 4-61 through 4-99. Impacts on biological resources from implementation of the 2014 LUCE
were determined to be less than significant after mitigation.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a. Would the project have a substantial adverse effect, either directly or through habitat
modifications, on any species identified as a candidate, sensitive, or special status species in local
or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service?
The project site is in an urbanized area and does not contain special-status species habitat (USFWS
Information for Planning and Consultation 2025a). Additionally, according to Figure 7: Habitat Types
of the City’s Conservation and Open Space Element, the project site is considered developed and does
not contain habitat for species identified as a candidate, sensitive, or special-status species (General
Plan: Conservation and Open Space 2006). The nearest environmentally sensitive habitat is the San
Luis Obispo Creek, approximately 300 feet west of the project site. Existing development, including
Higuera Street and commercial buildings, obstruct the direct path between the project site and
sensitive habitat. The creek provides habitat for the threatened South-Central Coastal California
Steelhead trout (Creeks and Watersheds 2025). As discussed in Environmental Checklist Section 10,
Hydrology and Water Quality, the project applicant would be required to develop a Stormwater
Control Plan which would describe site-specific design requirements to address the collection of
stormwater and the direction of run-off flow to on and off-site drainages. In addition, the applicant
would be required to develop and implement a Storm Water Pollution Prevention Plan (SWPPP),
which would describe best management practices to minimize on- and off-site erosion and sediment
run-off during construction. Therefore, the potential for run-off into the creek to adversely impact
candidate, sensitive, or special status species would be less than significant.
As the creek does not run through the project site and impacts to the creek due to run-off are not
anticipated, potential impacts to the creek habitat and steelhead trout specifically would be less than
significant. Based on the developed nature of the project site and vicinity, and the lack of
environmentally sensitive habitat onsite, potential impacts to federal-or state-listed endangered,
threatened, rare, or otherwise sensitive flora or fauna, or habitats identified by the California
Department of Fish and Wildlife or U.S. Fish and Wildlife Service as sensitive or special status, would
be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Biological Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 29
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive
natural community identified in local or regional plans, policies, or regulations, or by the
California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
c. Would the project have a substantial adverse effect on state or federally protected wetlands
(including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
The project site is in an urbanized area and has been previously disturbed, as evident by the existing
development and general absence of vegetation. No riparian habitats, sensitive natural communities,
or wetlands are located on or adjacent to the project site (Information for Planning and Consultation
2024a; National Wetlands Inventory 2024b). Therefore, the project would have no impact on riparian
habitats, other sensitive natural communities, or protected wetlands.
NO IMPACT
d. Would the project interfere substantially with the movement of any native resident or migratory
fish or wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
Wildlife corridors are pathways or habitat linkages that connect discrete areas of natural open space
otherwise separated or fragmented by topography, changes in vegetation, other natural obstacles, or
manmade obstacles such as urban development and roadways. The project site is vacant and
disturbed, surrounded by development, and does not connect areas of natural open space. The
project site is not part of a wildlife movement corridor, and construction of the project would not
impede the use of native wildlife nursery sites (General Plan: Conservation and Open Space 2006).
Therefore, the project would have no impact on wildlife movement or native wildlife nursery sites.
NO IMPACT
e. Would the project conflict with any local policies or ordinances protecting biological resources,
such as a tree preservation policy or ordinance?
The City has specific policies in its Conservation and Open Space Element aimed at protecting
biological resources (General Plan: Conservation and Open Space Element 2006). Due to the lack of
biological resources onsite, the project would comply with these policies as it avoids all potential
significant impacts to sensitive habitats and species. Therefore, the project would not conflict with
any local policies or ordinances that protect biological resources. No impact would occur.
NO IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat conservation
plan?
The project site is not located in an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat conservation plan (Natural
Community Conservation Planning 2025). Therefore, the project would not conflict with such a plan.
No impact would occur.
NO IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
30
Conclusion
Due to the lack of biological resources onsite, the project would have no new significant or
substantially more severe or peculiar impacts to biological resources, nor are there potentially
significant off-site impacts, cumulative impacts, or previously identified significant effects, which were
not discussed in the prior environmental document. Also, there are no previously identified significant
effects which, because of substantial new information that was not known at the time of the previous
environmental review, are determined to have a more severe adverse impact than discussed in the
previous environmental documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Cultural Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 31
5 Cultural Resources
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Cause a substantial adverse change in
the significance of a historical
resource as defined in Section
15064.5?
□ ■ □ ■
b. Cause a substantial adverse change in
the significance of an archaeological
resource as defined in Section
15064.5?
□ ■ □ ■
c. Disturb any human remains,
including those interred outside of
formal cemeteries?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed cultural resources in Section 4.5, Cultural Resources, on pages 4-101
through 4-118. Impacts to sites of local importance, overall historic setting, and previously
undiscovered archaeological resources were found to be less than significant after mitigation.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a. Would the project cause a substantial adverse change in the significance of a historical resource
pursuant to §15064.5?
Under CEQA Guidelines Section 15064.5, a historical resource is defined as any property listed or
eligible for listing in the California Register of Historical Resources (CRHR), included in a local register,
or determined significant by a lead agency. Due to its documented architectural and cultural
significance, the Old Gas Works building is listed in the local register and therefore qualifies as a
historic resource under CEQA Guidelines Section 15064.5.
To assess potential impacts of the project, SWCA Environmental Consultants prepared a Historic
Preservation Report (Appendix B), which (a) identifies the building’s character-defining features and
historical significance and (b) evaluates the project’s compliance with the City’s Historic Preservation
Ordinance and Historic Preservation Program Guidelines and the Secretary of Interior’s Standards.
The Historic Preservation Report combines historical research from city records, newspaper archives,
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
32
gas plant documentation, and Sanborn Fire Insurance maps. Current photographic documentation
was also provided through a site visit on August 2, 2024.
Review of archival materials confirmed that the Old Gas Works property has been previously reviewed
by the City’s Cultural Heritage Committee. The Historic Preservation Report prepared for this project
is the first to systematically identify the character-defining features and historical significance of the
Old Gas Works building. While physical attributes like style, materials, and craftsmanship contribute
to its importance, the Old Gas Works building’s true significance as a historical resource is understood
within its historical context. The Historic Preservation Report describes the historical development of
manufactured gas plants in San Luis Obispo from the 1870s to 1910s, alongside advancements in gas
works engineering and the impact of consumer-oriented marketing on the city during that era. The
Historic Preservation Report determines that the Old Gas Works building is historically significant
under California Register criteria, as follows:
▪ Criterion 1 (Events): The building played a key role in the city’s industrial modernization, providing
street lighting and manufactured gas to businesses and residences, contributing to urban growth
and commercial marketing of domestic appliances.
▪ Criterion 2 (Persons): It is associated with E. S. Hoyt, a notable gas works engineer responsible
for the site’s selection, gas production relocation, specialized equipment procurement, and use
of distinctive yellow building stone.
▪ Criterion 3 (Architecture): The structure is an exceptional local example of the Mission Revival
style, particularly for an industrial building, and is uniquely constructed from Los Berros stone
masonry.
▪ Criterion 4 (Information Potential): The building does not have significance under this criterion.
Extensive and invasive excavations implemented as part of the prior remediation activities have
resulted in the removal of archaeological resources and it is highly unlikely that archaeological
resources remain on the project site. Furthermore, site remediation has resulted in the loss of the
other original gas plant buildings and original equipment inside the Old Gas Works.
The Historic Preservation Report concludes that the Old Gas Works building retains integrity in
location, design, materials, workmanship, and feeling, maintaining its original masonry structure and
character-defining architectural features. However, the integrity of setting and association has been
diminished due to the loss of surrounding gas plant structures, making its industrial function less
visually apparent. Despite modifications and the removal of original equipment, the structure remains
a CEQA-eligible historical resource, benefiting from preservation measures, including seismic
retrofitting and retention of original architectural elements (Appendix B).
The proposed adaptive reuse of the Old Gas Works building described in Section 9, Description of the
Project, would involve minimal alterations to the building’s historic character while repurposing it for
contemporary use, which is consistent with the Secretary of the Interior’s Standards for the
Treatment of Historic Properties (Appendix B). The adaptive reuse of the Old Gas Works building
integrates the Mission Revival-style structure into a mixed-use development, including a restaurant
while maintaining its architectural integrity.
Key preservation measures include:
▪ Retention of character-defining features, such as Los Berros stone masonry and the distinctive
compact form.
▪ Minimal changes to original materials, with repairs to deteriorated elements rather than full
replacements.
ATTACHMENT G
Purview of the Environmental Checklist
Cultural Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 33
▪ New additions designed for compatibility, ensuring scale and spatial relationships are preserved
while differentiating modern elements.
▪ Re-use of original architectural features, including wooden doors and lunette, along with an
interpretive panel.
While the original industrial context of the Old Gas Works is no longer present, the adaptive reuse of
the Old Gas Works building is consistent with the Mission Revival architecture and Los Berros stone
masonry of the original structure.
The project would utilize helical piers to support the foundation of the proposed structures near the
existing Old Gas Works building. This foundation type would eliminate the need for pile driving,
minimizing potential vibration impacts to the historical structure (refer to Environmental Checklist
Section 4.13, Noise).
While new structures would be built around the Old Gas Works building, their scale, massing, and
spatial relationship would align with surrounding buildings, maintaining visual consistency within the
area. The building's historical significance is primarily tied to its features, and the adaptive reuse
approach would preserve key exterior elements, avoiding significant impacts to its historical integrity.
Given that the original industrial context is no longer present, adding another new structure to the
project site would not significantly impact the site’s historical character. The proposed location and
design of the residential building would ensure the long-term visibility of the historic resource would
remain. By conforming to the Secretary of the Interior’s Standards and meeting City conditions of
approval, the project would have a less than significant impact on historical resources, and would not
result in more severe adverse impacts than discussed in the 2014 LUCE EIR.
LESS THAN SIGNIFICANT IMPACT
b. Would the project cause a substantial adverse change in the significance of an archaeological
resource pursuant to §15064.5?
The 2014 LUCE EIR concluded that implementing proposed and existing policies, along with applying
project-specific mitigation measures where appropriate, would reduce the potential impact of
development facilitated by the General Plan to a less than significant level. The proposed project
would continue to be subject to the City’s General Plan policies, as well as the City’s adopted
Archaeological Resource Preservation Program Guidelines (ARPPG). While the project site is
considered an archaeologically sensitive area, it has undergone substantial subsurface disturbance
due to the prior site remediation work, as mentioned above and in Section 8, Surrounding Land Uses
and Setting. The soil removal action included site-wide soil excavation and off-site disposal of
approximately 3,150 tons of soil impacted with polycyclic aromatic hydrocarbons, arsenic, and lead.
Excavation depths varied from 1.5 to 22 feet below ground surface (Removal Action Plan Completion
Report Former Manufactured Gas Plant 2019). Contaminated soil was removed and excavated areas
were backfilled with clean soil. Archaeological monitoring and data recovery were completed as part
of the excavation work.
Although the subsurface of the project site has been substantially disturbed, the construction of the
project may result in minor encroachments into previously undisturbed native soils. The project
would include in the installation of helical piers to support the foundation of the proposed structures
at 1390 Walker Street and 280 Pismo Street. These piers would extend into undisturbed soils with the
potential to contain significant archaeological resources. Further information on the project
construction, including the limits of required excavation, would be developed and detailed as part of
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
34
construction drawings for the building permit application. To address the possibility of encountering
archaeological resources during construction consistent with the ARPPG, approval of the project
would be conditioned to require a qualified archaeologist be present for monitoring during pier
installation or any other construction activities, including but not limited to frontage improvements
and utility trenching and construction, with the potential to disturb previously undisturbed/native
soils, pursuant to Policies 3.5.5 Archaeological Resources Present and 3.5.6 Qualified Archaeologist
Present. The qualified archaeological monitor would have the authority to halt construction activity
if potential archaeological resources are encountered. The archaeological monitor would prepare
daily monitoring logs that include a description of construction activities, hours worked, and other
applicable observations. In the event Native American archaeological resources are identified, they
would be described in the daily monitoring log and the City and native tribes would be notified.
Compliance with these City policies would ensure the project’s impacts related to archaeological
resources would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project disturb any human remains, including those interred outside of formal
cemeteries?
There are no known human remains on the project site. Nonetheless, the discovery of remains or
resources is always a possibility during ground-disturbing activities. As stated in the 2014 LUCE EIR,
compliance with existing federal, State, and local laws would reduce potential impacts to a less than
significant level. Consistent with California Health and Safety Code Section 7050.5, if human remains
are encountered during project construction, the San Luis Obispo County Coroner must be notified
immediately and no further disturbance shall occur until the County Coroner has made a
determination of origin and disposition pursuant to PRC Section 5097.98. If the human remains are
determined to be prehistoric, the coroner is required to notify the Native American Heritage
Commission, a representative of which would determine and notify a most likely descendant. The
most likely descendant must complete the inspection of the site within 48 hours of notification and
may recommend scientific removal and nondestructive analysis of human remains and items
associated with Native American burials. Compliance with existing regulations would ensure that this
impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
Cultural resource assessments of the project area were conducted, and their findings were
incorporated into the analysis above. Compliance with existing federal, State, and local laws would
reduce impacts to historical resources, archaeological resources, and human remains to less than
significant levels. Accordingly, the project would have no new significant or substantially more severe
or peculiar impacts to cultural resources, nor are there any potentially significant off-site impacts,
cumulative impacts, or previously identified significant effects, which were not discussed in the prior
environmental document. Also, there are no previously identified significant effects which, because
of substantial new information that was not known at the time of the previous environmental review,
are determined to have a more severe adverse impact that discussed in the previous environmental
documents. Accordingly, no additional review is required.
ATTACHMENT G
Purview of the Environmental Checklist
Cultural Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 35
This page intentionally left blank.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
36
6 Energy
Significant
Impact
Less than
Significant
No
Impact
Analyzed in the
Prior EIR
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary
consumption of energy resources,
during project construction or
operation?
□ ■ □ ■
b. Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed energy consumption on pages 4-143 through 4-267, in Section 4.7, Global
Climate Change. These impacts were found to be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a. Would the project result in a potentially significant environmental impact due to wasteful,
inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy
efficiency?
Construction
Energy consumption accounts for energy consumed during construction and operation of the
proposed project, such as fuel consumed by vehicles, natural gas consumed for heating and/or power,
and electricity consumed for power. Construction practices would be required to comply with all local
and State regulatory requirements related to equipment age, operation, and design. As described in
detail in Environmental Checklist Section 3, Air Quality, the SCCAB is currently designated
nonattainment for federal and State standards for ozone and State standards for PM 10, therefore,
SLOAPCD is required to implement strategies that would reduce pollutant levels to recognized
acceptable standards. Based off this information, it can be reasonably assumed that industry standard
local construction practices would be relatively efficient, as contractors would streamline practices
ATTACHMENT G
Purview of the Environmental Checklist
Energy
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 37
like fuel use, travel miles, etc. to meet the National Ambient Air Quality Standards and California
Ambient Air Quality Standards. Construction equipment would be required to be maintained and
tuned according to manufacturer specifications, which would promote fuel efficiency. Therefore,
project construction would not result in wasteful, inefficient, or unnecessary consumption of energy
resources and energy impacts from construction of the project would be less than significant.
Operation
Once occupied and operating, the mixed-use development would be required to comply with local
and State policies regarding energy conservation. For example, Land Use Element Policy 9.7,
Sustainable Design, requires sustainable building practices that consume less energy, water, and
other resources. Compliance with this policy would ensure the proposed structures contain energy-
efficient appliances, natural ventilation, water conserving plumbing systems and drought tolerate
landscaping. State policies include the California Green Building Standards Code (CALGreen) Solar
Mandate, and solar panels would be incorporated to reduce reliance on fossil fuels and promote clean
energy. Because the project would be required to comply with these State and local regulations
supporting renewable energy and energy efficiency, the project design would result in decreased
reliance on fossil fuels, and impacts from operation of the project would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would not result in new significant effects which are peculiar to the project or project site
or substantially more severe impacts related to energy, nor would there be potentially significant off-
site impacts, cumulative impacts, or previously identified significant effects that were not discussed
in the prior environmental document. Furthermore, there are no previously identified significant
effects which, as a result of substantial new information not known at the time of the previous
environmental review, have been determined to have a more severe adverse impact than those
discussed in the previous environmental documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
38
7 Geology and Soils
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:
1. Rupture of a known earthquake fault,
as delineated on the most recent
Alquist-Priolo Earthquake Fault
Zoning Map issued by the State
Geologist for the area or based on
other substantial evidence of a known
fault?
□ ■ □ ■
2. Strong seismic ground shaking? □ ■ □ ■
3. Seismic-related ground failure,
including liquefaction?
□ ■ □ ■
4. Landslides? □ ■ □ ■
b. Result in substantial soil erosion or the
loss of topsoil?
□ ■ □ ■
c. Be located on a geologic unit or soil that
is made unstable as a result of the
project, and potentially result in on or
offsite landslide, lateral spreading,
subsidence, liquefaction, or collapse?
□ ■ □ ■
d. Be located on expansive soil, as defined in
Table 1-B of the Uniform Building Code
(1994), creating substantial risks to life or
property?
□ ■ □ ■
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater?
□ □ ■ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?
□ ■ □ ■
ATTACHMENT G
Purview of the Environmental Checklist
Geology and Soils
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 39
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed geology and soils impacts in Section 4.6, Geology and Soils, on pages 4-
119 through 4-141 and concluded that impacts related to geology and soils would be less than
significant. Impacts related to paleontology were discussed on pages 4-104 through 4-105 of Section
4.5, Cultural Resources, of the 2014 LUCE EIR and found to be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
project-specific would occur impacts that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a.1. Would the project directly or indirectly cause potential substantial adverse effects, including the
risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the
most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a known fault?
The nearest active fault is the Los Osos Fault, which runs northwest/southeast approximately 4.5
miles west of the City’s limits and does not pass through the project site (Climate Adaptation and
Safety Element 2023). As a result, the risk of fault rupture is low. There are no Alquist-Priolo
Earthquake Fault zones on-site or in the project vicinity (California Geological Survey: Earthquake
Zones of Required Investigation Map 2025c). Therefore, the proposed development would not be
placed on an Alquist-Priolo Earthquake Fault zone and would not result in hazards related to fault
rupture. This impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.2. Would the project directly or indirectly cause potential substantial adverse effects, including the
risk of loss, injury, or death involving strong seismic ground shaking?
Seismic events caused by active and potentially active faults in the region could result in seismic
ground shaking on-site. The California Building Code (CBC), which incorporates the Uniform Building
Code, and the California Division of Mines and Geology Guidelines for Evaluating and Mitigating
Seismic Hazards in California, Special Publication 117 (revised 2008), includes design and construction
requirements related to fire safety, life safety, and structural safety. As mentioned in the 2014 LUCE
EIR, the City’s General Plan Safety Element has policies to protect against seismic events, creating
structural damage or health and safety risks including Policy GE-6.1, Avoiding Faults. Compliance with
local and state building standards would minimize potential safety hazards from seismic ground
shaking, and ensure potential impacts associated with the project would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
40
a.3. Would the project directly or indirectly cause potential substantial adverse effects, including the
risk of loss, injury, or death involving seismic-related ground failure, including liquefaction?
The project site is not located in a high liquefaction zone (Climate Adaptation and Safety Element
2023). Safety Element Policy GE-6.3, Avoiding Liquefaction Hazards, states development shall not be
located in areas of high liquefaction potential unless a site-specific investigation by a qualified
professional determines that the proposed development would not be at risk of damage from
liquefaction. A soils engineering report was prepared for the project and recommendations related
to site preparation, earthwork, foundations, slabs, retaining walls, and pavement sections are
provided in the report and incorporated into the design (GeoSolutions, Inc. 2025; Appendix C). Based
on the consistency and relative density of the in-situ soils, the potential for seismic liquefaction of
soils at the project site is low. With implementation of General Plan Policies GE-6.1 through GE-6.4
per the 2014 LUCE EIR, the CBC, and recommendations of the soils engineering report, impacts related
to seismic ground shaking and liquefaction would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.4. Would the project directly or indirectly cause potential substantial adverse effects, including the
risk of loss, injury, or death involving landslides?
The project site is located in a flat area and is not surrounded by slopes. As identified in the 2014 LUCE
EIR, the project site is not located in a landslide zone and the nearest landslide zone is approximately
0.65-mile west of the project site. There is no significant risk of landslides affecting the project site.
As a result, this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil?
The site is previously disturbed, flat, and located in a developed area of the city. The most substantial
source of potential erosion of on-site would be during initial site ground disturbance/construction
and from stormwater run-off. Stormwater run-off is discussed in detail in Environmental Checklist
Section 10, Hydrology and Water Quality. The project applicant would be required to develop a
Stormwater Control Plan which would describe design requirements to address the collection of
stormwater and the direction of run-off flow to on and off-site drainages. In addition, the project
applicant would be required to develop and implement a SWPPP, which would describe best
management practices to minimize on- and off-site erosion and sediment run-off during construction.
Compliance with the required Stormwater Control Plan and SWPPP would ensure that the project
would not result in substantial temporary or long-term erosion or loss of topsoil. In addition, the
required dust-reduction measures discussed in Environmental Checklist Section 3, Air Quality, would
further reduce soil erosion and loss of topsoil during construction. Compliance with these required
construction practices would ensure this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project be located on a geologic unit or soil that is unstable, or that would become
unstable as a result of the project, and potentially result in on- or off-site landslide, lateral
spreading, subsidence, liquefaction, or collapse?
As detailed above under impacts a.3 and a.4, the project is consistent with the 2014 LUCE EIR and
would not result in impacts related to landslides and liquefaction. The 2014 LUCE EIR also concluded
that compliance with the CBC and San Luis Obispo General Plan policies would reduce potential
ATTACHMENT G
Purview of the Environmental Checklist
Geology and Soils
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 41
impacts related to unstable soils to less than significant levels. As identified under impacts a.3 and
a.4, the project site is not at risk of landslide or liquefaction. Lateral spreading may occur when soils
liquefy during an earthquake event, and the liquefied soils with overlying soils move laterally to
unconfined spaces (Mineral Resources Online Spatial Data 2023). As the project site is not located
within a highly sensitive liquefaction zone or on an active fault, the potential for lateral spreading is
less than significant. Construction of the project would be required to adhere to applicable General
Plan policies, the City’s Municipal Code, CBC, and recommendations of the soils engineering report,
which would ensure that the project would not be at risk of lateral spreading, subsidence, or collapse.
Impacts related to exposing people or structures to potential substantial adverse effects related to
unstable soils would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project be located on expansive soil, as defined in Table 18-1-B of the Uniform Building
Code (1994), creating substantial direct or indirect risks to life or property?
The project would be required to comply with the CBC and applicable local building and zoning codes
and regulations to reduce risks related to expansive soils. Per Section 1803 of CB Chapter 8, a
Geotechnical Investigation may be required to determine the soil engineering properties at a building
site. A soils engineering report has been prepared for the project and recommendations related to
site preparation, earthwork, foundations, slabs, retaining walls, and pavement sections are provided
in the report and incorporated into the design (GeoSolutions, Inc. 2025). Therefore, the project would
not result in a significant impact related to exposing people or structures to potential substantial
adverse effects related to expansive soils.
LESS THAN SIGNIFICANT IMPACT
e. Would the project have soils incapable of adequately supporting the use of septic tanks or
alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
The 2014 LUCE EIR concluded that all new development within the city is anticipated to be connected
to the municipal waste disposal system. The project is consistent with the 2024 LUCE EIR assumption,
in that it does not include construction or use of septic tanks or alternative wastewater disposal
system. Therefore, there would be no impact.
NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique
geologic feature?
The 2014 LUCE EIR analyzed development throughout the City that have geological and soils
conditions favorable for paleontological resources. The 2014 LUCE EIR concluded that impacts to
paleontological resources would be less than significant with the implementation of the 2014 LUCE
such as Conservation and Open Space Policy 3.5 which requires protection of both known and
potential archaeological sites. Due to previous site remediation actions, the project site has
undergone substantial subsurface disturbance and contains mostly engineered fill. The remainder of
the site is underlain by Qa-type sediments—relatively young deposits from valley floors made up of
unconsolidated sand and gravel—which have low potential for finding paleontological resources (The
National Geological Map Database: MapView 2025; Description of Map Units 1998). Due to the
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
42
project site being primarily underlain by engineered fill and sediments with low paleontological
sensitivity, potential impacts to paleontological resources would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to geology
and soils, nor would there be potentially significant off-site impacts, cumulative impacts, or previously
identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Geology and Soils
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 43
This page intentionally left blank.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
44
8 Greenhouse Gas Emissions
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment?
□ ■ □ ■
b. Conflict with any applicable plan,
policy, or regulation adopted for the
purposes of reducing the emissions of
greenhouse gases?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed in Section 4.7 Global Climate Change, on pages 4-143 through 4-169.
Impacts due to the incremental contribution of greenhouse gas (GHG) emissions associated with
adoption and implementation of the 2014 LUCE would be less than significant, and additional
mitigation was not required. It was concluded that impacts related to applicable plans, policies, or
regulations adopted for the purposes of reducing the emissions of GHG would be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a. Would the project generate GHG emissions, either directly or indirectly, that may have a
significant impact on the environment?
SLOAPCD has developed GHG thresholds of significance through 2045 in accordance with Assembly
Bill 1279 and the California Air Resource Board’s 2022 Scoping Plan, which set forth a goal of reducing
GHG emissions by 85 percent below 1990 levels no later than 2045 (CEQA Air Quality Handbook 2023).
Pursuant to SLOAPCD guidance, projects which result in less than 740 metric tons of carbon dioxide
equivalent7 (MT CO2e) per year in 2028 would have a less than significant impact related to GHG
emissions. Based on the results of the CalEEMod modeling (Appendix A), project construction would
generate approximately 207 MT CO2e. Because GHG emissions from construction would be short
term, in order to compare to the SLOAPCD annualized threshold of significance for GHG emissions,
GHG emissions are averaged over a 30-year period for the purpose of this analysis. Averaged over a
30-year period, construction of the project would generate approximately 7 MT CO2e per year. Project
7 Carbon dioxide equivalent is a unit of measurement used to standardize the climate effects of various GHGs in terms of the amount of
carbon dioxide that would create the same amount of global warming.
ATTACHMENT G
Purview of the Environmental Checklist
Greenhouse Gas Emissions
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 45
operation would generate approximately 215 MT CO2e annually (Appendix A). When combined,
construction and operation would generate approximately 222 MT CO2e annually, which would not
exceed the 740 MT CO2e significance threshold for GHG emissions. Therefore, the project would have
a less than significant impact related to the generation of GHG emissions.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose
of reducing the emissions of greenhouse gases?
The City adopted a Climate Action Plan in 2020 with a goal of carbon neutrality by 2035, which is
consistent with Assembly Bill 1279, which sets a goal of achieving statewide carbon neutrality by 2045.
Therefore, for the purposes of this analysis, the City’s Climate Action Plan is the applicable GHG
reduction plan for the project. Appendix C of the City’s Climate Action Plan includes thresholds and
guidance for preparation of GHG emissions analyses for projects within the city. To support progress
toward the City’s carbon neutrality goal, projects in San Luis Obispo must demonstrate consistency
with the Climate Action Plan.
Table 5 summarizes the proposed project’s consistency with the City’s Climate Action Plan, based on
applicable GHG Emissions Compliance Checklist measures (Appendix C – CEQA GHG Emissions
Thresholds and Guidance 2020a). As described therein, the proposed project would not conflict with
the Climate Action Plan. This impact would be less than significant.
Table 5 Project Consistency with the Climate Action Plan
Climate Action Plan Measures Project Consistency
Land Use Consistency
1a. Does the project include a land use element and/or
zoning designation amendment?
Consistent. The project does not include a land use or
zoning amendment, and the project’s proposed uses are
allowable within the existing land use and zoning
designations of the project site.
Pillar 2: Clean Energy Systems
Does the Project/Plan include an operational commitment
to participate in Monterey Bay Community Power?
Consistent. The project would be opted-in to receive
power procured by Central Coast Community Energy,
formerly known as Monterey Bay Community Power.
Pillar 3: Green Buildings
Does the Project/Plan exclusively include “All-electric
buildings”?
Inapplicable. On April 17, 2023, as a result of a Ninth
Circuit Court of Appeals ruling concerning the City of
Berkeley's ordinance prohibiting natural gas in new
buildings, the San Luis Obispo City Council voted to direct
the City Manager and Community Development Director
to temporarily suspend enforcement of the all-electric
building requirement for new buildings. As the project is
not required to incorporate all-electric buildings due to
recent case law, this pillar is currently not applicable.
If the Project/Plan includes a new mixed-fuel building or
buildings (plumbed for the use of natural gas as fuel for
space heating, water heating, cooking or clothes drying
appliances) does that building/those buildings meet or
exceed the City’s Energy Reach code?
Consistent. The project would be constructed in
accordance with the requirements of the City’s Energy
Reach Code.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
46
Climate Action Plan Measures Project Consistency
Pillar 4: Connected Community
Does the Project/Plan comply with requirements in the
City’s Municipal Code with no exceptions, including
bicycle parking, bikeway design, and electric vehicle
charging stations?
Consistent. The project would include bicycle parking and
electric vehicle charging stations consistent with the
requirements of the City’s Municipal Code. The project
does not include a bikeway and would not make
modifications to existing bikeways.
6a. Is the estimated Project/Plan-generated Vehicle Miles
Traveled (VMT) within the City’s adopted thresholds, as
confirmed by the City’s Transportation Division?
Consistent. As described in Environmental Checklist
Section 17, Transportation, the project would result in a
less than significant impact related to VMT.
Does the Project/Plan demonstrate consistency with the
City’s Bicycle Transportation Plan?
Consistent. As described in Environmental Checklist
Section 17, Transportation, the project would be
consistent with the Active Transportation Plan, which
effectively updated and replaced the Bicycle
Transportation Plan.
Pillar 5: Circular Economy
Will the Project/Plan subscribe all units and/or buildings
to organic waste pick up and provide the appropriate on-
site enclosures consistent with the provisions of the City
of San Luis Obispo Development Standards for Solid
Waste Services?
Consistent. As described in Environmental Checklist
Section 19, Utilities and Service Systems, the project
would comply with City Municipal Code requirements
related to organic waste.
Pillar 6: Natural Solutions
9. Does the Project/Plan comply with Municipal Code
requirements for trees?
Consistent. The project would comply with the Municipal
Code requirements for trees. No tree removal is
proposed.
Source: City of San Luis Obispo 2020a
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to GHG
emissions, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Greenhouse Gas Emissions
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 47
This page intentionally left blank.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
48
9 Hazards and Hazardous Materials
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials?
□ ■ □ ■
b. Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident
conditions involving the release of
hazardous materials into the
environment?
□ ■ □ ■
c. Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
0.25 mile of an existing or proposed
school?
□ □ ■ ■
d. Be located on a site that is included on a
list of hazardous material sites compiled
pursuant to Government Code Section
65962.5 and, as a result, would it create a
significant hazard to the public or the
environment?
□ ■ □ ■
e. For a project located in an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project result in a safety hazard or
excessive noise for people residing or
working in the project area?
□ □ ■ ■
f. Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
□ ■ □ ■
g. Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving wildland
fires?
□ ■ □ ■
ATTACHMENT G
Purview of the Environmental Checklist
Hazards and Hazardous Materials
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 49
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed hazardous materials impacts in Section 4.8, Hazards and Hazardous
Materials, on pages 4-171 through 4-203 and found that impacts related to hazards and hazardous
materials use in the city would be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
This section is partially based on Phase I and Phase II Environmental Site Assessments prepared by
Environmental Engineering, Consulting & Remediation, Inc. on February 18 2024 and April 5, 2024
(Appendices D and E), the Stormwater Report (Appendix F), and the Vapor Barrier Plans (Appendices
G and H).
a. Would the project create a significant hazard to the public or the environment through the
routine transport, use, or disposal of hazardous materials?
Residential uses and restaurants, such as those proposed by the project, typically do not use or store
large quantities of hazardous materials other than minor amounts needed for cleaning or landscaping
maintenance. During grading and construction activities, limited quantities of miscellaneous
hazardous substances, such as gasoline, diesel fuel, hydraulic fluid, solvents, oils, paints, may be
transported to the site, used on site, and disposed of after use. However, the project would be
required to comply with applicable federal, State, and local regulations that address the handling,
storage, use, and disposal of hazardous substances, including those overseen by the Central Coast
Regional Water Quality Control Board (CCRWQCB) and DTSC. Construction contractors would be
required to comply with applicable federal and State environmental and workplace safety laws.
Compliance with these applicable federal, State, and local regulations would ensure that potential
significant hazards to the public or the environment through the routine transport, use, or disposal of
hazardous materials would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project create a significant hazard to the public or the environment through
reasonably foreseeable upset and accident conditions involving the release of hazardous
materials into the environment?
The Phase I and Phase II Environmental Site Assessments completed for the project indicate levels of
Arsenic8 and Benzene9 that exceed the environmental screening level for residential and commercial
uses in the soil of the project site and along its perimeter. To address these contaminants, the Site
Assessments include recommendations for removal and disposal of contaminated soils; replacement
with clean imported soils; and proper handling and protection measures during project construction
8 Arsenic is a naturally occurring semi-metallic element found in soil, water, and air, with inorganic forms being highly toxic and associated
with significant human health risks.
9 Benzene is a known Class A carcinogen.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
50
as well as the inclusion of vapor barriers10 underneath the residential and commercial buildings to
allow for project occupancy. As required per the applicant/property owner’s agreement with DTSC,
the applicant shall acquire all necessary approvals from DTSC to ensure compliance with Title 22,
Division 4.5 of the California Code of Regulations prior to the issuance of any building permits. This
division establishes comprehensive environmental health standards for the management of
hazardous waste, including criteria for identifying and listing hazardous wastes, requirements for
waste generators and transporters (such as proper labeling, storage, and documentation),
operational standards for facilities managing hazardous waste (covering aspects like facility design,
operation, and closure), and procedures for investigating and remediating sites contaminated by
hazardous waste to protect human health and the environment. With the incorporation of Site
Assessment recommendations, including the vapor barrier designs, that are subject to review and
approval by DTSC as the applicable regulatory agency, the potential for accidental release of
hazardous materials into the environment would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an existing or proposed school?
There are no existing or proposed K-12 schools within 0.25-mile of the project site. The closest school
to the project site is Hawthorne Elementary at 2125 Story Street, approximately 0.5 mile east of the
project site. Therefore, the project would not emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or wastes within 0.25 mile of an existing or proposed school.
There would be no impact.
NO IMPACT
d. Would the project be located on a site that is included on a list of hazardous material sites
compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
The project is located at the site of a previous manufactured gas plant and substation (EnviroStor
online database, DTSC 2025). A Preliminary Endangerment Assessment was conducted for the project
site in 1992 which identified contaminants on the site including polycyclic aromatic hydrocarbons,
arsenic, lead and tetrachloroethylene. The site has since undergone remediation that involved
excavating and removing soils, off-site disposal of the soils, backfilling with clean imported fill and
gravel cover, and implementation of operation and maintenance plan between the former owner
(PG&E) and DTSC (Appendices D and E). To facilitate this project, a Standard Voluntary Agreement
was signed by the applicant/current property owner and DTSC on July 1, 2024, which detailed the
property owner’s desire to request a variance at 1390 Walker Street to allow residential development
and comply with the remaining provisions of the land use covenants. The scope of this agreement
includes the parcels located at 251 Pacific Street, 1390 Walker Street, 280 Pismo Street, and any
offsite area to which the contamination has or may have migrated from the site. DTSC would provide
oversight and documents related to engineering and geological work for the project are subject to
DTSC’s review and approval. As a result of this agreement, the project includes the installation of
vapor barrier systems designed to avoid potential adverse impacts from contaminated soil
underneath the residential and commercial buildings for long-term occupancy. The proposed vapor
10 The vapor barrier would consist of a layer of permeable aggregate material that would be placed below an impermeable vapor
mitigation membrane barrier. The impermeable membrane would be installed wherever the building is in contact with the earth, but not
at foundation footings and grade beams.
ATTACHMENT G
Purview of the Environmental Checklist
Hazards and Hazardous Materials
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 51
barrier design would be subject to DTSC’s review and approval to ensure compliance with Title 22,
Division 4.5 of the California Code of Regulations. Prior to City issuance of any construction permits,
the applicant will be required to provide evidence that all necessary approvals from DTSC have been
acquired for project construction. With approval from DTSC, the project would be required to
incorporate the appropriate measures related to construction activities and include the proposed
vapor barrier into the design of their construction and building plans, which would ensure the project
would not pose a significant hazard to the public or environment. Therefore, this impact would be
less than significant.
LESS THAN SIGNIFICANT IMPACT
e. For a project located within an airport land use plan or, where such a plan has not been adopted,
within two miles of a public airport or public use airport, would the project result in a safety
hazard or excessive noise for people residing or working in the project area?
The project site is not located within two miles of an airport or the San Luis Obispo Airport Land Use
Plan. The nearest airport, San Luis Obispo County Regional Airport, is approximately 2.5 miles
southeast of the project site. There would be no impact.
NO IMPACT
f. Would the project impair implementation of or physically interfere with an adopted emergency
response plan or emergency evacuation plan?
The project does not involve alteration to roadways used for emergency evacuation. Compliance with
applicable federal, State, and local laws and regulations regarding handling of hazardous materials,
and Safety Element policies OP-7.1 and OP-7.3 require adequate access and prompt response time,
would ensure the project would not interfere with an adopted emergency response plan, or
emergency evacuation plan and this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of
loss, injury, or death involving wildland fires?
The project site is located within a Very High Fire Hazard Severity Zone (VHFHSZ) based on the Fire
Hazard Severity Zone maps prepared by CAL FIRE, which went into effect on July 17, 2025 (CAL FIRE
2025). Although the surrounding environment is highly developed and lacks natural ignition sources
or other conditions that could exacerbate wildland fire risks, the hazard designation reflects the
potential for wildfire spread under extreme conditions. As a result, new development on the site
would be subject to wildfire risk reduction measures, including compliance with defensible space
requirements pursuant to California Government Code Section 51182 and the California Fire Code,
Chapter 49, as well as ignition-resistant construction standards under California Building Code
Chapter 7A (WUI). Property owners would also be required to provide natural hazard disclosure at
the time of sale and implement home hardening measures consistent with State and local regulations.
With implementation of these measures, the project would not inherently create new ignition sources
and potential impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
52
10 Hydrology and Water Quality
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Violate any water quality standards or
waste discharge requirements or
otherwise substantially degrade surface
or ground water quality?
□ ■ □ ■
b. Substantially decrease groundwater
supplies or interfere substantially with
groundwater recharge such that the
project may impede sustainable
groundwater management of the basin?
□ ■ □ ■
c. Substantially alter the existing drainage
pattern of the site or area, including
through the alteration of the course of a
stream or river or through the addition of
impervious surfaces, in a manner which
would:
□ ■ □ ■
(i) Result in substantial erosion or
siltation on- or off-site;
□ ■ □ ■
(ii) Substantially increase the rate or
amount of surface run-off in a
manner which would result in
flooding on- or off-site;
□ ■ □ ■
(iii) Create or contribute run-off water
which would exceed the capacity of
existing or planned stormwater
drainage systems or provide
substantial additional sources of
polluted run-off; or
□ ■ □ ■
(iv) Impede or redirect flood flows? □ ■ □ ■
d. In flood hazard, tsunami, or seiche zones,
risk release of pollutants due to project
inundation?
□ ■ □ ■
e. Conflict with or obstruct implementation
of a water quality control plan or
sustainable groundwater management
plan?
□ ■ □ ■
ATTACHMENT G
Purview of the Environmental Checklist
Hydrology and Water Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 53
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed hydrology and water quality impacts in Section 4.9, Hydrology and Water
Quality, on pages 4-205 through 4-233. The EIR found that potential impacts to hydrology and water
quality would be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
if project-specific impacts would occur that 1) are peculiar to the project or the parcel on which the
project is located; 2) were not previously analyzed in previous environmental documents as significant
effects; 3) are potentially significant off-site impacts and cumulative impacts that were not previously
discussed in the previous environmental documents; and 4) are now determined to have a more
severe impact than discussed in the previous environmental documents due to substantial new
information.
Project-Specific Impacts
a. Would the project violate any water quality standards or waste discharge requirements or
otherwise substantially degrade surface or ground water quality?
The 2014 LUCE EIR concluded that compliance with existing regulations, including the City’s
requirement for projects to submit a Stormwater Management Plan for review and approval, and the
General Plan policies proposed under the LUCE, impacts related to water quality due to anticipated
development under the 2014 LUCE implementation would be less than significant. As the
development of the project site was anticipated under the LUCE, the potential impacts discussed
below would not include new or more severe adverse impacts than discussed in the 2014 LUCE EIR.
Construction Impacts
During grading activities, on-site soils would be exposed to wind and water erosion that could
transport sediments into local stormwater drainages. Furthermore, accidental spills of fluids or fuels
from construction vehicles and equipment, or miscellaneous construction materials and debris, could
be mobilized and transported off-site in overland flow. The project would disturb more than one acre
of land and therefore would be required to obtain coverage under the General Permit for Discharges
of Storm Water Compliance. The General Permit regulates discharges to waters of the United States
from stormwater and authorized non-stormwater associated with construction activity. The project
would also be required to comply with the City’s Land Use Element includes policies to reduce run-
off, including Policy 6.6.7., Discharge of Urban Pollutants, which requires future development
proposals to minimize discharge of urban pollutants (such as oil and grease) into area drainages.
Compliance with local, regional, and State requirements that regulate potential stormwater run-off
or damages to water quality would ensure construction of the project would not violate water quality
standards, substantially alter the drainage pattern of the area such that substantial erosion or siltation
would occur and would not degrade water quality.
Operational Impacts
The majority of the project site is currently undeveloped, and as a result, the project would increase
the area of impervious surfaces to the site. Increasing impervious surfaces has the potential to
increase stormwater run-off which can introduce pollutants to receiving waters. Urban run-off can
carry a variety of pollutants, including oil and grease, metals, sediment, and pesticide residues from
roadways, parking lots, rooftops, and landscaped areas and deposit them into adjacent waterways
via the storm drain system. The City requires post-development run-off to not exceed pre-
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
54
development flows for rain events up to the 100-year, 24-hour storm event, as defined by the National
Oceanic and Atmospheric Administration’s Precipitation Frequency Data Server. Additionally, the
project would be subject to the CCRWQCB Resolution No. R3-2013-0032, the Post-Construction
Stormwater Management Requirements for Development Projects in the Central Coast. This
resolution includes project-specific requirements and best management practices which emphasize
protecting and, where degraded, restoring key watershed processes to create and sustain linkages
between hydrology, channel geomorphology, and biological health necessary for healthy watersheds
(POST-Construction Stormwater Management Requirements for Development Projects in the Central
Coast Region 2013). By adhering to local and the Post-Construction Stormwater Management
Requirements, the operation of the project would not result in adverse effects on water quality and
or in the violation of water quality standards or waste discharge requirements during construction or
operation. As a result, this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project substantially decrease groundwater supplies or interfere substantially with
groundwater recharge such that the project may impede sustainable groundwater management
of the basin?
The project would increase the area of impervious surface coverage on the site, reducing infiltration.
Development of the proposed project would not include installation of new groundwater wells or
result in a substantial increase in demand for groundwater from existing wells. The project includes a
bio-retention basin in the west corner of the project site, which would have a storage capacity of 130
cubic feet. The proposed bio-retention area would implement the 2014 LUCE EIR’s requirement that
projects include infiltration features that contribute to groundwater recharge and minimize
stormwater run-off. Therefore, the proposed project would not substantially decrease groundwater
supplies or interfere with groundwater recharge. This impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c.(i) Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would result in substantial erosion or siltation on- or off-site?
c.(ii) Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would substantially increase the rate or amount of surface run-off
in a manner which would result in flooding on- or off-site?
c.(iii) Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner that would create or contribute run-off water which would exceed the
capacity of existing or planned stormwater drainage systems or provide substantial additional
sources of polluted run-off?
c.(iv) Would the project substantially alter the existing drainage pattern of the site or area, including
through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would impede or redirect flood flows?
The project site is relatively flat, with minimal changes in elevation. The project site is in an urban area
and does not contain natural drainage features onsite. The nearest creek or stream is the San Luis
Obispo Creek, approximately 250 feet west of the project site. No development or construction
ATTACHMENT G
Purview of the Environmental Checklist
Hydrology and Water Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 55
staging is proposed near the creek bed, and no project activity would directly or indirectly alter the
course of the San Luis Obispo Creek. Although the project would increase the total area of impervious
surfaces on the site, the project would be required to comply with the CCRWQCB’s Post-Construction
Stormwater Compliance Resolution R3-2013-0032 and the Stormwater Management Guidance
Manual for Low Impact Development & Post Construction Requirements, ensuring the project would
not substantially modify the existing drainage patterns through the addition of impervious surfaces.
Erosion and Siltation
During the construction phase of the project, earth-moving activities could temporarily affect on-site
drainage patterns by exposing the underlying soils, increasing site permeability, and altering the site’s
terrain. Moreover, construction activities have the potential to contribute to erosion and sediment in
stormwater run-off. However, the project would be required to comply with the National Pollutant
Discharge Elimination System11 (NPDES) Water Quality Stormwater Management Development
Standards which would ensure construction activities associated with the project would not cause
substantial erosion or siltation either on- or off-site. Following completion of the project, the project
site would be entirely occupied by the proposed development, permeable pavers, paved areas,
buildings and landscaping, leaving no exposed bare soil vulnerable to erosion. Therefore, operation
of the project would not result in significant erosion or siltation on or off-site.
On and Off-Site Flooding
The project would be subject to the City’s Land Use Element Section 6.6, Creeks Wetlands, and
Flooding Policies, which includes policies and programs designed to limit the potential for increased
flood damage in urbanized areas. Land Use Element Policy 6.6.5, Run-off Reduction and Groundwater
Recharge, requires stormwater drainage systems to minimize surface water run-off and enhance
groundwater recharge. Compliance with this policy, other applicable City General Plan policies, and
regional and state policies relating to flood prevention, would ensure the project would not
significantly increase the rate or amount of surface run-off in a manner which would result in flooding
on- or off-site.
Stormwater Drainage Capacity and Polluted Run-Off
The 2014 LUCE EIR added three policies to the Land Use Element of the General Plan –6.6.5 Run-off
Reduction and Groundwater Recharge, 6.6.6 Development Requirements and 6.7.1 Previously
Developed Areas – which address the potential for development projects to increase impervious
surfaces within the city, potentially increasing polluted run-off and the need for additional
stormwater infrastructure. These policies would reduce polluted run-off and the need for additional
stormwater drainage systems by mandating the implementation of post-construction measures,
requiring projects to reduce impervious surfaces and drainage concentrations while avoiding
floodplain areas, ensuring compliance with the City’s floodplain ordinance, setbacks, specific plans,
and design standards to mitigate flood damage and prevent encroachment into floodplains. The
project would be subject to these policies as well as other applicable local policies that reduce run-off
during construction and operation of the project. Although the project site is located within a flood
zone, each parcel associated with the project is zoned for development. Therefore, the development
within the flood zone is consistent with that envisioned, and mitigated for, under the LUCE.
11 The NPDES permit program addresses water pollution by regulating point sources that discharge pollutants to waters of the United
States. Created in 1972 by the Clean Water Act, the NPDES permit program is authorized to state governments by the Environmental
Protection Agency to perform many permitting, administrative, and enforcement aspects of the program (National Pollutant Discharge
Elimination System 2025).
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
56
Additionally, the project would be required to comply with the NPDES permit program, which
regulates stormwater discharges and requires implementation of management practices during both
construction and operation phases to ensure run-off impacts remain less than significant.
Flood Flows
The project would not alter the course of a stream or river or through the addition of impervious
surfaces. As mentioned above, the nearest body of water to the project site is the San Luis Obispo
Creek. The proposed project does not include equipment storage, staging or development within the
wetland habitat. In addition to the bioretention basins proposed onsite, there are existing curbs and
gutters between the project site and the creek. These elements would all serve to divert run-off from
the proposed impervious surfaces to groundwater recharge or the City’s wastewater system.
Therefore, any run-off due to new impervious surfaces would not impact existing flood flows.
Compliance with local, regional, and State policies and regulations would ensure the proposed project
would not involve the altering course of streams or rivers, nor would it substantially modify the
existing drainage patterns through the addition of impervious surfaces which would result in
substantial erosion or siltation on- or off-site, substantially increase the rate or amount of surface
run-off in a manner which would result in flooding on- or off-site, in a manner that would create or
contribute run-off water which would exceed the capacity of existing or planned stormwater drainage
systems or provide substantial additional sources of polluted run-off, or to the extent that it could
cause flooding or redirection of floodwaters. Impacts would be substantially reduced by required
compliance with uniformly applicable development policies, and would be less than significant
overall.
LESS THAN SIGNIFICANT IMPACT
d. In flood hazard, tsunami, or seiche zones, would the project risk release of pollutants due to
project inundation?
Due to its close proximity to the San Luis Obispo Creek, the project site is located within a high-risk
area (Flood Zone AE), meaning the site is subject to inundation by the 1 percent annual chance flood,
also commonly referred to as the 100-year flood (FEMA's National Flood Hazard Layer Viewer 2024).
The City’s General Plan and Municipal Code, in addition to the City of San Luis Obispo’s Waterways
Management Plan,12 Engineering Standards,13 and the Stormwater Quality Ordinance14 outline
regulations and requirements development projects must comply with to minimize or avoid
environmental impacts associated with flooding and inundation. Additionally, as discussed in
Environmental Checklist Section 9, Hazards and Hazardous Materials, the project would be required
to comply with applicable federal, State, and local regulations that address the handling, storage, use,
and disposal of hazardous substances, including those overseen by CCRWQCB and DTSC. The project
would also be required to comply with all applicable federal, State, and local regulations related to
flooding, inundation, and the handling of hazardous substances. As a result, the project would not
result in a significant risk of releasing pollutants due to project inundation.
LESS THAN SIGNIFICANT IMPACT
12 The WMP includes procedures for hydrologic and hydraulic analysis, and guidelines and design criteria for the design of channels, storm
drain systems, stormwater detention facilities, bank repair and stream restoration.
13 The current Engineering Standards for the City include requirements relevant to water quality. These include but are not limited to
compliance with the Waterways Management Plan and approval of a Stormwater Control Plan.
14 The purpose and intent of this Ordinance is to ensure the health, safety, and general welfare of citizens, and protect and enhance the
quality of watercourses and water bodies in a manner pursuant to and consistent with the Clean Water Act.
ATTACHMENT G
Purview of the Environmental Checklist
Hydrology and Water Quality
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 57
e. Would the project conflict with or obstruct implementation of a water quality control plan or
sustainable groundwater management plan?
The project site is under the jurisdiction of the CC RWQCB, who provide permits for projects that may
affect surface waters and groundwater locally and is responsible for preparing the Water Quality
Control Plan for the Central Coast Basin (Basin Plan). The Basin Plan serves as the basis for the
CCRWQCB’s regulatory programs and incorporates an implementation plan for achieving water
quality objectives (Water Quality Control Plan for the Central Coast Basin 2024). As detailed under
impact a, the proposed project would need to demonstrate compliance with CCRWQCB Resolution
R3-2013-0032 and their Post-Construction Stormwater Compliance Resolution R3-2013-0032. The
project applicant would be required to submit a final stormwater control plan prior to issuance of
building permits that addresses requirements within the City’s Engineering Standards. With approval
of the final stormwater control plan, the project would not conflict with the objectives and goals of
the Basin Plan. Therefore, this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to
hydrology and water quality, nor would there be potentially significant off-site impacts, cumulative
impacts, or previously identified significant effects that were not discussed in the prior environmental
document. Furthermore, there are no previously identified significant effects which, as a result of
substantial new information not known at the time of the previous environmental review, have been
determined to have a more severe adverse impact than those discussed in the previous
environmental documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
58
11 Land Use and Planning
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Physically divide an established
community?
□ □ ■ ■
b. Cause a significant environmental
impact due to a conflict with any land
use plan, policy, or regulation adopted
for the purpose of avoiding or
mitigating an environmental effect?
□ □ ■ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR addressed land use and planning impacts in Section 4.10, Land Use, on pages 4-
235 through 4-254. The 2014 LUCE EIR concluded that the proposed land use changes near the San
Luis Obispo County Regional Airport would conflict with the Airport Land Use Plan, particularly policies
concerning safety, noise, overflight, and airspace obstruction. At the time, the Airport Land Use
Commission was in the process of updating the Airport Land Use Plan and a draft was not yet released
for public review; therefore, it was not possible to review the 2014 LUCE update for consistency with
the pending Airport Land Use Plan update. Since the Airport Land Use Commission had not reviewed
the LUCE for a consistency determination, it was assumed they would find it inconsistent with the
Airport Land Use Plan, leading to a significant unavoidable impact due to conflicts with the adopted
Airport Land Use Plan. All other Land Use and Planning related impacts were determined to be less
than significant in the document.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project physically divide an established community?
The project site is entirely surrounded by existing development, and proposed new development
would be limited to the project site and would not include linear or other features that could impede
access between or within neighborhoods. Therefore, the project would not result in any new
obstruction or division between any established communities.
NO IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Land Use and Planning
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 59
b. Would the project cause a significant environmental impact due to a conflict with any land use
plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental
effect?
The Land Use, Circulation, and Housing Elements of the City’s General Plan, and the Zoning Ordinance,
are the primary land use planning guidance documents for the development pattern of the city. The
project would be consistent with existing General Plan goals, programs, and policies, and zoning
ordinance requirements, adopted for the purpose of avoiding or mitigating an environmental effect,
for the Services and Manufacturing land use designation and C-S zone. Land Use Plan Goal 1.4,
Efficient Urban Form, encourages infill and redevelopment in designated areas, such as C-S zones, to
reduce sprawl and VMT, thereby minimizing air quality and GHG impact. The project is located within
the C-S zone and includes high density residential to reduce urban sprawl, as well as bicycle parking
and proximity to transit stations to reduce VMT. The project site is not located within the Airport Land
Use Plan area or its area of influence; therefore, it is not affected by Airport Land Use Plan policies.
The project would not conflict with a land use plan, policy, or regulation for the purpose of avoiding
or mitigating an environmental effect.
NO IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to land
use and planning, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects, which as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
60
12 Mineral Resources
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Result in the loss of availability of a
known mineral resource that would be
of value to the region and the residents
of the state?
□ □ ■ ■
b. Result in the loss of availability of a
locally important mineral resource
recovery site delineated on a local
general plan, specific plan, or other
land use plan?
□ □ ■ ■
Analysis in Previous Environmental Documents
Potential impacts to mineral resources were analyzed in Section 4.6, Geology and Soils, page 4-127,
of the 2014 LUCE EIR. All potential impacts to geology and soils, including native minerals, were found
to be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project result in the loss of availability of a known mineral resource that would be of
value to the region and the residents of the state?
b. Would the project result in the loss of availability of a locally important mineral resource recovery
site delineated on a local general plan, specific plan, or other land use plan?
The project site is not zoned or designated for mining uses and no active mining operations are in the
project site or vicinity. The project site is not classified as a Mineral Resource Zone and would not
result in the loss of availability of a known mineral resource that would be of value to the residents
of the state and the region, nor would it result in loss of a locally important mineral resource recovery
site (Mineral Resources Online Spatial Data 2025). The project site has been previously disturbed, and
the project would not involve developing land with the potential to contain valuable mineral
resources. There would be no impact.
NO IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Mineral Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 61
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to mineral
resources, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
62
13 Noise
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior
EIR
Would the project:
a. Generation of a substantial temporary or
permanent increase in ambient noise
levels in the vicinity of the project in
excess of standards established in the
local general plan or noise ordinance, or
applicable standards of other agencies?
□ ■ □ ■
b. Generation of excessive groundborne
vibration or groundborne noise levels?
□ ■ □ ■
c. For a project located within the vicinity of
a private airstrip or an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public
airport or public use airport, would the
project expose people residing or
working in the project area to excessive
noise levels?
□ □ ■ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed noise in Section 4.11, Noise, on pages 4-255 through 4-282. The 2014
LUCE EIR concluded that short-term construction noise impacts, including cumulative impacts, would
be significant and unavoidable. However, all long-term impacts were determined to be less than
significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in a previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project result in generation of a substantial temporary or permanent increase in
ambient noise levels in the vicinity of the project in excess of standards established in the local
general plan or noise ordinance, or applicable standards of other agencies?
SLOMC Chapter 9.12 mandates that operating tools or equipment used for construction activities
between weekday hours of 7:00 p.m. and 7:00 a.m. or any time on Sundays or holidays is strictly
prohibited, except for emergency works of public service utilities or by exception issued by the City
ATTACHMENT G
Purview of the Environmental Checklist
Noise
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 63
Community Development Department. The Municipal Code also states that construction activities
shall be conducted in such a manner, where technically and economically feasible, that the maximum
noise levels at affected properties shall not exceed 75 A-weighted decibels (dBA) at single-family
residences, 80 dBA at multi-family residences, and 85 dBA at mixed residential/commercial uses and
business properties.
Project construction activities on-site and traffic noise from construction vehicles would increase
noise levels in the project vicinity. The closest noise-sensitive receptors to the project site are single-
family residences located approximately 50 feet southeast of the project site. In addition, several
business properties surrounding the project site are within 50 feet of the project site. At this distance,
the maximum anticipated construction noise levels could result in up to 86 dBA at the nearest single-
family residences and business properties (Appendix I). Therefore, noise receptors surrounding the
project site would be exposed to intermittent and temporary construction noise levels that exceed
Municipal Code standards for construction near single-family residential and business properties.
While this is consistent with the determination in the 2014 LUCE EIR that short-term construction
noise would be significant and unavoidable, the project would be conditioned to implement standard
construction noise best management practices to address these short-term noise impacts on
residential properties in the vicinity and reduce this impact to a less than significant level.
The project would result in the construction of 49 residential units and the adaptive reuse of the Old
Gas Works building. The project does not include any components that would substantially contribute
to long-term ambient noise in the project vicinity. Upon completion of construction activities, the
project would include the use of heating, ventilation, and air conditioning systems; however, use of
these systems would not result in a noticeable increase in ambient noise levels due to compatibility
with the existing noise environment. Typically, a doubling of traffic volumes is needed to produce a
noticeable noise increase. The project has been designed to minimize vehicle trips to and from the
site by providing on-site bicycle parking and proximity to existing transit facilities. Given the volume
of surrounding residential developments and businesses, the addition of 49 residential units to the
project site would not result in a doubling of vehicle trips along surrounding roadways, and no
substantial mobile noise increases would occur. Therefore, operation would have a less than
significant impact related to generating permanent increases in ambient noise.
LESS THAN SIGNIFICANT IMPACT
b. Would the project result in generation of excessive groundborne vibration or groundborne noise
levels?
The City Municipal Code prohibits operating any device that creates ground vibration above the
vibration perception threshold of an individual at or beyond 150 feet from the source on a public
space or right-of-way. Vibration levels would begin to be perceptible at levels of 0.04 inches per
second peak particle velocity (in/sec ppv) for continuous events and 0.25 in/sec ppv for transient
events (Transportation and Construction Vibration Guidance Manual 2020). The vibration threshold
at which there is a risk to historic buildings is 0.5 in/sec ppv for transient sources and 0.25 in/sec ppv
for continuous/frequent intermittent sources. Construction of the project would not require the use
of pile drivers, vibratory rollers, or blasting which could create substantial groundborne vibration.
Construction equipment required for the project would generate a groundborne vibration level of
approximately 0.089 in/sec ppv 25 feet from a receptor which, at 50 feet, would result in a vibration
level of 0.031 in/sec ppv (Federal Transit Administration 2018; Appendix I). This vibration level would
not exceed the 0.04 in/sec ppv continuous or 0.25 in/sec ppv transient vibration level perception
thresholds or the 0.25 in/sec ppv threshold for risk to historic buildings. Therefore, construction would
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
64
not generate substantial groundborne vibration or groundborne noise exceeding applicable human
annoyance thresholds.
Operation of the project would not include any components that would cause substantial vibration
and therefore would not result in generation of excessive groundborne vibration. Therefore, potential
impacts from groundborne vibration would be less than significant.
LESS THAN SIGNIFICANT IMPACT
c. For a project located within the vicinity of a private airstrip or an airport land use plan or, where
such a plan has not been adopted, within two miles of a public airport or public use airport, would
the project expose people residing or working in the project area to excessive noise levels?
The nearest airport to the project site, the San Luis Obispo County Regional Airport, is located
approximately 2.5 miles southeast of the project site. According to the Airport Land Use Plan for the
San Luis Obispo County Regional Airport, the project site is located outside of the noise contours of
the San Luis Obispo County Regional Airport (Amended and Restated San Luis Obispo County Regional
Airport Land Use Plan 2021). Therefore, the project would not expose construction workers or
residents to excessive airport noise. No impact would occur.
NO IMPACT
Conclusion
The project would not have peculiar or substantial noise impacts, nor would there be any potentially
significant off-site impacts, cumulative impacts, or previously identified significant effects, which were
not discussed in the prior environmental document. Also, there are no previously identified significant
effects which, as a result of substantial new information that was not known at the time of the
previous environmental review, are determined to have a more severe adverse impact that discussed
in the previous environmental documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Population and Housing
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 65
14 Population and Housing
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Induce substantial unplanned
population growth in an area, either
directly (e.g., by proposing new homes
and businesses) or indirectly (e.g.,
through extension of roads or other
infrastructure)?
□ ■ □ ■
b. Displace substantial amounts of existing
housing, necessitating the construction
of replacement housing elsewhere?
□ □ ■ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR discussed population and housing impacts in Section 4.12, Population and Housing,
on pages 4-283 through 4-288. The 2014 LUCE EIR estimated a population of 48,550 by 2035 and
found that impacts would be less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project induce substantial unplanned population growth in an area, either directly (for
example, by proposing new homes and businesses) or indirectly (for example, through extension
of roads or other infrastructure)?
By constructing new residential units in the City, the project has the potential to directly generate
population growth. Using the most recent California Department of Finance population estimates,
the City’s average household size is 2.22 persons/household. Applying this average to the proposed
49 units of the project, the project would add approximately 109 new residents to the City. The project
is consistent with the existing zoning and land use designation established under the 2014 LUCE EIR,
which considers a site’s zoning district and associated maximum density and encourages projects with
density bonuses. Therefore, potential population growth associated with the project is anticipated
and evaluated in the 2014 LUCE EIR. The project would not induce substantial unplanned population
growth, and this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
66
b. Would the project displace substantial numbers of existing people or housing, necessitating the
construction of replacement housing elsewhere?
“Substantial” displacement would occur if the proposed project would displace more residences than
would be accommodated through growth facilitated by the project. The goal of the proposed project
is to accommodate and encourage new residential development in San Luis Obispo. The project site
is currently developed with the Old Gas Works building and no residential structures. The proposed
project would not result in displacement as there are no residences onsite that would need to be
demolished. Therefore, there would be no impact.
NO IMPACT
Conclusion
The project would not involve development in areas not previously analyzed in the 2014 LUCE EIR,
nor would it result in impacts to population and housing not covered in the 2014 LUCE EIR The project
would have no new significant or substantially more severe or peculiar impacts concerning population
and housing, nor would there be any potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects, which were not discussed in the prior environmental
document. Also, there are no previously identified significant effects which, as a result of substantial
new information that was not known at the time of the previous environmental review, are
determined to have a more severe adverse impact that discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Public Services
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 67
15 Public Services
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
a. Would the project result in substantial
adverse physical impacts associated
with the provision of new or physically
altered governmental facilities, or the
need for new or physically altered
governmental facilities, the construction
of which could cause significant
environmental impacts, in order to
maintain acceptable service ratios,
response times or other performance
objectives for any of the public services:
1 Fire protection? □ ■ □ ■
2 Police protection? □ ■ □ ■
3 Schools? □ ■ □ ■
4 Parks? □ ■ □ ■
5 Other public facilities? □ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed public services in Section 4.13, Public Services, on pages 4-289 through
4-302 and concluded that impacts regarding police protection services, schools, parks, and other
public facilities would be less than significant. The 2014 LUCE EIR concluded that the increase in
demand for fire protection services had the potential to be significant but was deemed mitigatable to
a less than significant level through implementation of a policy which requires confirmation that
adequate fire suppression services exist prior to approving development projects within the city.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
68
Project-Specific Impacts
a.1. Would the project result in substantial adverse physical impacts associated with the provision of
new or physically altered fire protection facilities, or the need for new or physically altered fire
protection facilities, the construction of which could cause significant environmental impacts, in
order to maintain acceptable service ratios, response times or other performance objectives?
The project would be 1.1 mile drive from San Luis Obispo’s Fire Station 1, with an estimated travel
time of less than 4 minutes with no traffic (Google Maps 2025). The 2014 LUCE EIR establishes that a
response time of four minutes or less can generally be achieved if the call for service for location is
less than 1.5 miles from the fire station. The 2014 LUCE EIR found new development could impact
emergency response times, particularly projects located beyond the City Fire Department’s
designated four-minute travel time. As the project site is located within the City Fire Department’s
designated four-minute response area, it would not require new fire facilities or significantly impact
fire protection services. The City reviews development plans and conducts construction inspections
to ensure that new development complies with existing building and fire code requirements. The
project would be subject to applicable General Plan policies, including Policy FI-5.3, City-Wide Fire-
Smart New Development, which ensures development is only approved when adequate fire
suppression services and facilities are available, required enforcement of fire and building codes, and
the City’s fire prevention regulations and procedures. As adequate fire suppression services and
facilities would be available, the project would not result in substantial adverse physical impacts
associated with the provision of new or physically altered fire protection facilities, or the need for
new or physically altered fire protection facilities. As a result, the project’s potential impact on fire
protection services would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.2. Would the project result in substantial adverse physical impacts associated with the provision of
new or physically altered police protection facilities, or the need for new or physically altered
police protection facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other performance
objectives?
The project involves infill mixed-use residential development, which was envisioned in the LUCE and
would be located in an area currently served by police protection services. The LUCE EIR evaluated a
citywide population increase associated with buildout of the General Plan and concluded that, while
population growth could potentially affect police response times, such impacts would remain less
than significant with proportional increases in staffing and facilities. The project is consistent with the
type and density of growth evaluated in the City’s 2014 LUCE EIR, and would not introduce new or
unanticipated demands on law enforcement services.
As the project falls within the scope of development already considered and would not exceed service
thresholds or necessitate unplanned facility expansion, the project would not adversely impact police
department response capabilities. Continued implementation of City policies to maintain appropriate
officer-to-population ratios ensures that adequate law enforcement services would be available to
serve the project and surrounding community. Therefore, the project would not result in substantial
adverse physical impacts associated with the provision of new or physically altered police protection
facilities, or the need for new or physically altered police protection facilities. As a result, the project’s
potential impact on police protection services would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
Purview of the Environmental Checklist
Public Services
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 69
a.3. Would the project result in substantial adverse physical impacts associated with the provision of
new or physically altered schools, or the need for new or physically altered schools, the
construction of which could cause significant environmental impacts, in order to maintain
acceptable service ratios or other performance objectives?
While new residential development, including the proposed project, has the potential to increase the
demand for new school facilities, the 2014 LUCE EIR analyzed this issue and found impacts to be less
than significant due to Senate Bill (SB) 50, which requires new development to pay school impact fees
to offset potential impacts on school facilities. The 2014 LUCE EIR identified eight potential residential
planning areas within the city which could contribute to over‐capacity conditions at certain schools.
The proposed project is not within any of those planning areas. Additionally, mitigation identified
within the 2014 LUCE EIR requires school impact fees to be paid for each residential project,
consistent with SB 50. This project would be subject to the required school impact fees under SB 50
to offset potential impacts to school facilities. Pursuant to Section 65995(3)(h) of the California
Government Code (SB50, chaptered August 27, 1998), the payment of statutory fees pursuant to
California Education Code 17620 “…is deemed to be full and complete mitigation of the impacts of
any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or
development of real property, or any change in governmental organization or reorganization.” As a
result, the project’s potential impact on school facilities and services would be less than significant.
LESS THAN SIGNIFICANT IMPACT
a.4. Would the project result in substantial adverse physical impacts associated with the provision of
new or physically altered parks, or the need for new or physically altered parks, the construction
of which could cause significant environmental impacts, in order to maintain acceptable service
ratios or other performance objectives?
Buildout of the General Plan was analyzed under the 2014 LUCE EIR, which concluded that impacts
on parkland would be less than significant. Because the proposed project would be within the
anticipated buildout evaluated in the 2014 LUCE EIR, the project would not result in the need for new
or physically altered parks, the construction of which could cause significant environmental impacts.
In addition, the project is subject to the Quimby Act, which requires the dedication of land for park
and recreational purposes or payment of in-lieu fees to the City in the amount it would cost to acquire
the required amount of parkland to support the proposed minor subdivision. The required in-lieu fee
provides funding for existing parks and construction of new parks to support the potential increased
use of public parks due to new development. Therefore, this impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
70
a.5. Would the project result in substantial adverse physical impacts associated with the provision of
other new or physically altered public facilities, or the need for other new or physically altered
public facilities, the construction of which could cause significant environmental impacts, in order
to maintain acceptable service ratios, response times or other performance objectives?
The proposed project does not include and would not require new or physically altered governmental
facilities. Population growth facilitated by the proposed residential units included in the project would
generate additional demand for library and other public services, but this growth would be consistent
with that anticipated within the LUCE. Impacts to other public facilities would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to public
services, nor would there be potentially significant off-site impacts, cumulative impacts, or previously
identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Recreation
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 71
16 Recreation
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior
EIR
a. Would the project increase the use of
existing neighborhood and regional
parks or other recreational facilities
such that substantial physical
deterioration of the facility would occur
or be accelerated?
□ ■ □ ■
b. Does the project include recreational
facilities or require the construction or
expansion of recreational facilities
which might have an adverse physical
effect on the environment?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed potential impacts to recreational facilities in Section 4.14, Recreation, on
pages 4-303 through 4-315 and identified a less than significant impact to recreation.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
Project-Specific Impacts
a. Would the project increase the use of existing neighborhood and regional parks or other
recreational facilities such that substantial physical deterioration of the facility would occur or
be accelerated?
The project includes new residential development with the potential to increase population in San
Luis Obispo (refer to Environmental Checklist Section 14, Population and Housing). This additional
population would increase the use of existing parks and other recreational facilities. There are six
parks located within one mile of the project site: Meadow Park, Emerson Park, North Broad Street
Neighborhood Park, Cheng Park, Laguna Lake Park, and Mitchell Park. The project does not include
any new parks, but it would include an on-site exercise area for use by residents. Pursuant to SLOMC
Sections 16.22.080 and 16.22.080, the applicants are required to either dedicate land for park and
recreational purposes or pay an in-lieu fee to the City in the amount it would cost to acquire the
required amount of parkland to support the proposed minor subdivision. This requirement would
ensure existing parks are sufficiently funded, or new parks are built, to support the potential increased
use of public parks, due to the project. Therefore, potential increased use resulting from the project
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
72
would not lead to a substantial physical deterioration or overcrowding of existing parks and
recreational facilities, and the project’s impact on recreational facilities would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Does the project include recreational facilities or require the construction or expansion of
recreational facilities which might have an adverse physical effect on the environment?
The project includes recreational amenities as part of the residential building for future residents. The
potential environmental effects associated with these recreational features are analyzed throughout
this report as part of overall project construction and operation. The project does not include any new
public recreational facilities, and consistent with the findings of Environmental Checklist Section 15,
Public Services, the project would not result in the need to construct or expand any public recreational
facilities. This impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to
recreation, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Transportation
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 73
17 Transportation
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Conflict with a program, plan,
ordinance or policy addressing the
circulation system, including transit,
roadway, bicycle and pedestrian
facilities?
□ ■ □ ■
b. Conflict or be inconsistent with CEQA
Guidelines section 15064.3,
subdivision (b)?
□ ■ □ □
c. Substantially increase hazards due to a
geometric design feature (e.g., sharp
curves or dangerous intersections) or
incompatible use (e.g., farm
equipment)?
□ ■ □ ■
d. Result in inadequate emergency
access?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR evaluated transportation impacts in Section 4.15, Transportation and Circulation,
on pages 4-317 through 4-353. According to the 2014 LUCE EIR, traffic volumes as a result of 2014
LUCE implementation would result in a significant and unavoidable impact associated with traffic
level-of-service, which is a measure of traffic congestion. However, the 2014 LUCE EIR was prepared
and certified prior to adoption of the final CEQA Guidelines that changed the metric of transportation
analyses under CEQA from level-of-service to VMT pursuant to SB 743. Accordingly, traffic level-of-
service impacts are no longer considered significant environmental impacts for the purpose of CEQA
analysis.
Impacts relating to increased traffic volumes or traffic speed in designated neighborhood traffic
management areas, heavy vehicle traffic on non‐designated truck routes, activity at San Luis Obispo
County Regional Airport that may lead to changes in traffic volumes or traffic patterns were found to
be less than significant. Other less than significant impacts included potential conflicts with increased
transit ridership and provision of services increased transit ridership and provision of services.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
74
Project-Specific Impacts
a. Would the project conflict with a program, plan, ordinance or policy addressing the circulation
system, including transit, roadway, bicycle and pedestrian facilities?
Vehicle trips associated with project construction activities would be limited to worker trips to and
from the project site, delivery trips for heavy equipment and construction tools, and trips to dispose
of soil and other construction debris. Construction-related vehicle trips would be temporary and
would cease once construction is complete. Construction contractors would be required to comply
with the temporary traffic control provisions set forth in the City’s Standard Specifications and
Engineering Standards (Standard Specifications and Engineering Standards 2020c). This document
provides guidelines for traffic control during construction, including maintaining traffic, specifications
for flagging, pavement delineation, among other topics. In addition, a Traffic Control Plan, compliant
with the provisions set forth in the California Department of Transportation Manual on Uniform
Traffic Control Devices would be required to be approved by the City Engineer or their designee prior
to the start of construction activities. All traffic coordination of city streets undertaken by construction
contractors would require the City Engineer’s approval no fewer than three days prior to
implementation of traffic coordination activities (Standard Specifications and Engineering Standards
2020c). Compliance with these existing standards and measures would ensure that project
construction would not conflict with a program, plan, ordinance or policy addressing the circulation
system.
The City’s Active Transportation Plan (2021) identifies goals related to increasing active transportation
in San Luis Obispo (Active Transportation Plan 2021). The project would add 116 bicycle parking
spaces to the project site, providing facilities for bicycle travel consistent with Goal 3 of the Active
Transportation Plan which aims to make active transportation more convenient. The project would
not result in changes to existing bicycle or pedestrian facilities on surrounding roadways such as Pismo
Street and Higuera Street. The proposed project’s driveways would be subject to review and approval
by the City and the San Luis Obispo Fire Department, which would ensure the project would conform
to driveway access control and vision clearance standards and minimize potential vehicle to
pedestrian and vehicle to cyclist conflicts, thereby ensuring reasonable standards of safety for
pedestrians and cyclists consistent with Goal 2 of the Active Transportation Plan which strives to make
active transportation safer for residents (Active Transportation Plan 2021).
The nearest bus stop to the project site is located on Pismo Street approximately 80 feet east of the
project site at the intersection of Pismo Street and Archer Avenue. The proposed project would not
alter this bus stop or disrupt service at this bus station and therefore would not conflict with transit
facilities. As described in Environmental Checklist Section 14, Population and Housing, the project
could increase the city’s population by approximately 109 residents. The increase of 109 people could
increase the number of transit users; however, an increase of 109 people is marginal and would not
result in substantial delays of transit service. Furthermore, placing residential development proximate
to existing transit facilities would improve connection to transit for cyclists and pedestrians residing
at the project site, consistent with Goal 3 of the Active Transportation Plan.
The City’s Mid-Higuera Street Enhancement Plan (2001) identifies plans to close Walker Street at the
Walker Street/Higuera Street/Pacific Street intersection. The intent of this recommendation is to
reduce conflicts at the intersection and improve traffic safety. The City plans to advance a capital
improvement project referred to as the Higuera Complete Streets Project (State Clearinghouse No.
2025071184) in early 2026, which includes implementation of this street closure. However, as a
Condition of Approval for the project, the City would require implementation of this closure as part
ATTACHMENT G
Purview of the Environmental Checklist
Transportation
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 75
of this development project if this has not been completed sooner by the City. The street closure
would be designed using strategies that do not require substantial excavation or grading that would
change existing drainage patterns or incur disturbance of soils beneath the existing roadway surface
and sidewalks. Design details for the street closure would be approved to the satisfaction of the City
Public Works and Fire Departments.
Based on the above, the project’s impact related to conflicts with transit, roadway, bicycle, and
pedestrian facilities would be less than significant.
LESS THAN SIGNIFICANT IMPACT
b. Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision
(b)?
As discussed above, SB 743 and the subsequent amendment of the CEQA Guidelines were not
incorporated into CEQA at the time the 2014 LUCE EIR was prepared and certified. This impact analysis
is based on the potential to conflict with or be inconsistent with CEQA Guidelines Section 15064.3(b).
Consistent with guidance from the Governor’s Office of Land Use and Climate Innovation, the City’s
Multimodal Transportation Impact Study Guidelines (2020) includes screening criteria for projects
exempt from a VMT analysis. A project that meets a screening criterion is assumed to result in a less
than significant impact related to VMT. Screening criteria include a criterion for locating a project in
an area with existing VMT at least ten percent below adopted thresholds, which is used to evaluate
the residential portion of the project. The commercial portion of the project is evaluated using the
criterion for locally serving development which states retail development projects with less than
50,000 square feet gross floor area may assumed to cause a less than significant impact.
The City includes VMT screening maps in the Multimodal Transportation Impact Study Guidelines
(Multimodal Transportation Impact Study Guidelines 2020b). As shown therein, the project site is
located in an area below 85 percent of the regional average of residential VMT per capita. Because
the project site is located in a low-VMT area, is consistent with surrounding residential uses, and
would promote infill housing which would minimize vehicle trips, the project’s residential uses are
presumed to have a less than significant VMT impact.
The project’s commercial uses would have a floor area of 2,190 square feet, which is below the 50,000
square foot threshold for a locally serving use. The proposed restaurant would serve the local
community and would not be substantially larger than existing restaurants or include other
components which could cause the restaurant to become regionally serving. Therefore, the project’s
commercial uses are presumed to have a less than significant impact.
Therefore, the project would have a less than significant impact related to conflicts or inconsistencies
with CEQA Guidelines Section 15064.3(b).
LESS THAN SIGNIFICANT IMPACT
c. Would the project substantially increase hazards due to a geometric design feature (e.g., sharp
curves or dangerous intersections) or incompatible use (e.g., farm equipment)?
The project would not alter or affect the city’s existing street network in a manner that would
introduce or exacerbate hazards due to geometric design features. Construction vehicles and
equipment would be in a staging area on-site, thereby minimizing the potential to result in roadway
hazards. If temporary partial road closures are required, construction contractors would be required
to comply with temporary traffic control provisions set forth in the City’s Standard Specifications and
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
76
Engineering Standards, including implementation of a traffic control plan to reduce temporary traffic
hazards during construction (Standard Specifications and Engineering Standards 2020c). Compliance
with these standards would ensure construction would not substantially increase circulation-related
hazards.
The project includes the addition of two new driveways located on Pacific Street and Pismo Street. If
not properly designed, these driveways could cause line-of-sight disruptions and increase hazards
between vehicles and pedestrians and vehicles and cyclists. However, the project site ingress and
egress would be designed in accordance with City’s driveway access control and vision clearance
standards contained within the Standard Specifications and Engineering Standards. These design
features include width limitations, frontage limitations, and considerations for locating new
driveways at an appropriate distance from nearby intersections to minimize potential conflicts. The
proposed project design features would be required to be reviewed and approved by the City, which
would ensure the project would conform to City driveway access control and vision clearance
standards and minimize potential vehicle to pedestrian and vehicle to cyclist conflicts related to
driveway design. Adherence to City driveway standards would ensure the proposed project would not
introduce features that would substantially increase hazards due to a geometric design feature.
The City plans to implement a closure of Walker Street at the intersection of Walker Street/Higuera
Street/Pacific Street prior to construction and occupancy of this development project. However, as a
Condition of Approval for the project, the City will require the project to install this street closure if it
has not yet been implemented sooner by others. The street closure is intended to improve traffic
safety by reducing conflict points at this intersection and is consistent with recommendations in the
City’s Mid-Higuera Street Enhancement Plan. The street closure would be designed per applicable City
and State engineering design standards and to the satisfaction of the City Fire Department to ensure
these improvements would not introduce features that would substantially increase hazards.
The project would not introduce new incompatible uses, such as farm equipment, to roadways, and
the proposed project’s uses would be consistent with surrounding land uses. Accordingly, project
design would ensure the proposed project’s impacts to increased hazards would be less than
significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project result in inadequate emergency access?
Traffic impacts during project construction would be primarily associated with minor roadway delays
and potential temporary partial lane closures. However, any minor delays during project construction
would be temporary in nature and would not result in long-term inadequate emergency access. To
minimize potential impacts to emergency access during construction, the project would be required
to comply with the City’s Standard Specifications and Engineering Standards and implement a traffic
control plan that adheres to City standards for emergency access, including prohibiting personal
vehicles of construction workers from parking on the traveled way of the construction zone and
approval from the City’s Engineer or their designee for any traffic restrictions (Standard Specifications
and Engineering Standards 2020c). Compliance with these standards would ensure construction
would not result in inadequate emergency access.
The project would be designed in accordance with applicable standards for emergency access
enforced City of San Luis Obispo Fire Department, which include minimal vertical clearance
requirements, road width requirements, prohibitions on parking on access roads that do not exceed
minimum widths, provisions for required emergency vehicle turnarounds, and inclusion of
ATTACHMENT G
Purview of the Environmental Checklist
Transportation
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 77
appropriate signage and addressing (San Luis Obispo Fire Department: Developers Guide 2023).
Compliance with applicable development standards would ensure the project’s impacts related to
inadequate emergency access would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to
transportation, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
78
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Tribal Cultural Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 79
18 Tribal Cultural Resources
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior
EIR
Would the project cause a substantial adverse change in the significance of a tribal cultural
resource, defined in a Public Resources Code Section 21074 as either a site, feature, place, or
cultural landscape that is geographically defined in terms of the size and scope of the landscape,
sacred place, or object with cultural value to a California Native American tribe, and that is:
a. Listed or eligible for listing in the
California Register of Historical
Resources, or in a local register of
historical resources as defined in Public
Resources Code Section 5020.1(k), or
□ ■ □ ■
b. A resource determined by the lead
agency, in its discretion and supported by
substantial evidence, to be significant
pursuant to criteria set forth in
subdivision (c) of Public Resources Cod
Section 5024.1. In applying the criteria set
forth in subdivision (c) of Public
Resources Code Section 5024.1, the lead
agency shall consider the significance of
the resource to a California Native
American tribe.
□ ■ □ ■
California Assembly Bill 52 of 2014 (AB 52) expanded CEQA by defining a new resource category,
“tribal cultural resources.” AB 52 establishes that “a project with an effect that may cause a
substantial adverse change in the significance of a tribal cultural resource is a project that may have
a significant effect on the environment” (PRC Section 21084.2). It further states that the lead agency
shall establish measures to avoid impacts that would alter the significant characteristics of a tribal
cultural resource, when feasible (PRC Section 21084.3).
PRC Section 21074 (a)(1)(A) and (B) defines tribal cultural resources as “sites, features, places, cultural
landscapes, sacred places, and objects with cultural value to a California Native American tribe” and
is:
1. Listed or eligible for listing in the California Register of Historical Resources, or in a local register
of historical resources as defined in PRC Section 5020.1(k), or
2. A resource determined by the lead agency, in its discretion and supported by substantial
evidence, to be significant pursuant to criteria set forth in subdivision (c) of PRC Section 5024.1.
In applying these criteria, the lead agency shall consider the significance of the resource to a
California Native American tribe.
AB 52 also establishes a formal consultation process for California tribes regarding those resources.
The consultation process must be completed before a CEQA document can be certified. Under AB 52,
lead agencies are required to “begin consultation with a California Native American tribe that is
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
80
traditionally and culturally affiliated with the geographic area of the proposed project.” Native
American tribes to be included in the process are those that have requested notice of projects
proposed within the jurisdiction of the lead agency.
Analysis in Previous Environmental Documents
At the time of the LUCE, the discussion of a project’s potential to impact tribal cultural resources was
considered as a part of the Cultural Resources discussion. This EIR was certified in June of 2015, before
AB 52 was enacted, which resulted in Tribal Cultural Resources being added as a standalone topic to
the CEQA Guidelines checklist. Therefore, tribal consultation did not occur as part of the 2014 LUCE
EIR.
The 2014 LUCE EIR analyzed cultural resources on pages 4-101 through 4-118, which included
discussion relevant to tribal cultural resources regarding potentially significant cultural resources and
procedural compliance if human remains of Native American origin are found. The 2014 LUCE EIR
found that compliance with existing federal, State, and local laws as well as policies in the LUCE would
reduce potential impacts to cultural resources to a less than significant level after mitigation.
Project-Specific Impacts
a. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code Section 21074 that is listed or eligible for listing in
the California Register of Historical Resources, or in a local register of historical resources as
defined in Public Resources Code Section 5020.1(k)?
b. Would the project cause a substantial adverse change in the significance of a tribal cultural
resource as defined in Public Resources Code 21074 that is a resource determined by the lead
agency, in its discretion and supported by substantial evidence, to be significant pursuant to
criteria set forth in subdivision (c) of Public Resources Code Section 5024.1?
As this project qualifies for a statutory exemption from CEQA review under Section 15183 of the CEQA
Guidelines, it is not subject to the tribal consultation requirements of AB 52 and therefore did not
undergo tribal consultation during the CEQA process.
The 2014 LUCE EIR determined development facilitated by the 2014 LUCE EIR could adversely affect
identified and previously unidentified tribal cultural resources. However, individual projects can
potentially reduce impacts to a less than significant level through adherence to existing federal, State,
and City policies and programs.
Figure 1: Cultural Resources, within the City’s Conservation and Open Space Element, identifies the
project site as a Burial Sensitivity Area. Pursuant to Policy 3.5.4, Archaeologically Sensitive Areas, of
the City’s Conservation and Open Space Element, a preliminary site survey was required for the
project due to the project site’s cultural sensitivity. EarthWorks prepared multiple Cultural
Archaeological Resources Assessments which evaluated the entirety of the site. As part of the
archaeological evaluations of the project site and vicinity, Applied Earthworks consulted with the
Native American Heritage Commission in Sacramento to determine if any sites recorded in the
Commission’s Sacred Lands File occur in or near the project vicinity. The Commission indicated that
there are no sites within the study areas listed in the Sacred Lands Inventory. Additionally, Applied
Earthworks conducted archaeological surveys and sensitivity assessments of the project site. The
pedestrian surveys did not identify cultural resources of Native American origin at the project site.
With the information from the surveys and the Native American Heritage Commission, Applied
ATTACHMENT G
Purview of the Environmental Checklist
Tribal Cultural Resources
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 81
Earthworks concluded the project site has a low to moderate degree of sensitivity for buried
archaeological resources.
No tribal cultural resources were identified in the 2014 LUCE EIR, or the more recent site specific
surveys. Although there are no identified tribal cultural resources are not anticipated to occur at the
site, as a condition of approval for the project, the City would require a qualified archaeologist to be
present during pier installation or any other construction activities with the potential to disturb
previously undisturbed/native soils, to satisfy Conservation and Open Space Policies 3.5.5,
Archaeological Resources Present, and 3.5.6, Qualified Archaeologist Present. The qualified
archaeological monitor would have the authority to halt construction activity if potential
archaeological resources are encountered. The archaeological monitor would prepare daily
monitoring logs that include a description of construction activities, hours worked, and other
applicable observations. In the event Native American archaeological resources are identified, they
would be described in the daily monitoring log and the City and native tribes would be notified.
Implementation of this condition of approval would reduce potential impacts to tribal cultural
resources to a less than significant level.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to tribal
cultural resources, nor are there potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, no additional review is required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
82
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Utilities and Service Systems
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 83
19 Utilities and Service Systems
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Would the project:
a. Require or result in the relocation or
construction of new or expanded water,
wastewater treatment or storm water
drainage, electric power, natural gas, or
telecommunications facilities, the
construction or relocation of which could
cause significant environmental effects?
□ ■ □ ■
b. Have sufficient water supplies available to
serve the project and reasonably
foreseeable future development during
normal, dry and multiple dry years?
□ ■ □ ■
c. Result in a determination by the
wastewater treatment provider which
serves or may serve the project that it has
adequate capacity to serve the project’s
projected demand in addition to the
provider’s existing commitments?
□ ■ □ ■
d. Generate solid waste in excess of State or
local standards, or in excess of the capacity
of local infrastructure, or otherwise impair
the attainment of solid waste reduction
goals?
□ ■ □ ■
e. Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR analyzed impacts in Section 4.16, Utilities and Service Systems, on pages 4-355
through 4-371. This discussion addressed the issues of water supply and delivery, wastewater
collection and treatment, and solid waste disposal, recycling, and composting. The 2014 LUCE EIR
identified impacts to all utilities and service systems as less than significant.
The following describes applicable analysis in the 2014 LUCE EIR and provides a review to determine
whether there would be project-specific impacts that 1) are peculiar to the project or the parcel on
which the project is located; 2) were not previously analyzed in previous environmental documents
as significant effects; 3) are potentially significant off-site impacts and cumulative impacts that were
not previously discussed in the previous environmental documents; and 4) are now determined to
have a more severe impact than discussed in the previous environmental documents due to
substantial new information.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
84
Project-Specific Impacts
a. Would the project require or result in the relocation or construction of new or expanded water,
wastewater treatment or storm water drainage, electric power, natural gas, or
telecommunications facilities, the construction or relocation of which could cause significant
environmental effects?
b. Would the project have sufficient water supplies available to serve the project and reasonably
foreseeable future development during normal, dry and multiple dry years?
c. Would the project result in a determination by the wastewater treatment provider which serves
or may serve the project that it has adequate capacity to serve the project’s projected demand
in addition to the provider’s existing commitments?
Water
The 2014 LUCE EIR determined that the City has sufficient water supplies available to serve the future
development implemented by the LUCE. The project site is currently connected to the City’s existing
water supply infrastructure and public water system. New water facilities or expansion of existing
facilities were not identified in the 2014 LUCE EIR as necessary to support growth in the city
anticipated by the LUCE. As discussed in Environmental Checklist Section 14, Population and Housing,
population growth generated by the project would not constitute a significant environmental impact
as the project is consistent with the zoning and allowed uses under the LUCE. Because the project’s
population and water demand were anticipated in the 2014 LUCE and adequate water supplies were
determined to be available for General Plan buildout, sufficient water would be available to serve the
project. Therefore, the project would not require the construction or relocation of new or expanded
water facilities that could result in significant environmental effects. This impact would be less than
significant, and the project would not result in new or more severe adverse impacts than discussed in
the 2014 LUCE EIR.
Wastewater
The 2014 LUCE EIR concluded that potential impacts from development facilitated by the 2014 LUCE
would be less than significant, based on required compliance with the General Plan’s Water and
Wastewater Element policies, which are designed to minimize and mitigate wastewater collection
and treatment impacts. As the project’s population and wastewater demand were anticipated in the
2014 LUCE and adequate wastewater services were determined to be available for General Plan
buildout, sufficient wastewater treatment infrastructure and capacity would be available to serve the
project.
The project is located within a wastewater collection system capacity constrained area (General Plan
Water and Wastewater Element, Figure 3: Wastewater Collection System Capacity Constrained Area).
The wastewater collection system within these areas are constrained during wet weather events due
to inflow and infiltration. The City established a Wastewater Flow Offset Program and adopted
Municipal Code Regulations (13.08.396) applicable to properties within the currently defined capacity
constrained areas, which require either replacement of existing sewer laterals or an in-lieu
improvement (such as replacement of an existing sewer main section), which would then off-set the
capacity needs of the project within the wastewater collection system. The City is currently in the
process of an update to the capacity constrained area map, which will require consideration and
approval by City Council. If the project site remains subject to Municipal Code Section 13.08.396, the
project applicant will be required to complete the necessary off-sets (either off-site sewer lateral
ATTACHMENT G
Purview of the Environmental Checklist
Utilities and Service Systems
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 85
replacements, or the replacement of an approximately 375-foot section of sewer main within Pismo
Street, between Walker and Higuera). Therefore, the project would be consistent with the General
Plan, adopted Program, and Code requirements, all of which would mitigate any impact associated
with the wastewater collection system constraints and create capacity in the collection system to
serve the project.
Although the project site is located within a wastewater collection system capacity constrained area,
the City’s Wastewater Flow Offset Program and Municipal Code Section 13.08.396 require
implementation of off-site improvements or in-lieu measures to offset the project’s wastewater
demand and ensure adequate system capacity. With compliance with these requirements, the project
would not require the construction or relocation of new or expanded wastewater treatment facilities
that could result in significant environmental effects. Therefore, sufficient wastewater services and
infrastructure would be available to accommodate the project, and this impact would be less than
significant, consistent with the conclusions of the 2014 LUCE EIR.
Stormwater
The 2014 LUCE EIR concluded that compliance with City development requirements would ensure
potential impacts related to stormwater infrastructure would be less than significant. The project site
is connected to the City’s existing stormwater conveyance system, and construction would be
required to comply with CCRWQCB’s Post Construction Requirements. The project would not require
or result in the relocation or construction of new or expanded stormwater facilities, the construction
or relocation of which could cause significant environmental effects. Therefore, the project would not
result in new or more severe impacts beyond those assessed in the 2014 LUCE EIR.
Gas/Electricity/Telecommunications
The 2014 LUCE EIR concluded that with compliance with applicable energy efficiency standards and
regulations, future development would result in less than significant impacts related to natural gas,
electricity, and telecommunications. The project would be served by existing electricity, natural gas,
and telecom infrastructure. Therefore, the project would not require the construction of any new
utility infrastructure, the construction or relocation of which could cause significant environmental
effects. This impact would be less than significant.
LESS THAN SIGNIFICANT IMPACT
d. Would the project generate solid waste in excess of State or local standards, or in excess of the
capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction
goals?
e. Would the project comply with federal, state, and local management and reduction statutes and
regulations related to solid waste?
Solid waste generated in the City is primarily disposed of at the Cold Canyon Landfill, approximately
7.5 miles southeast of the project site. The 2014 LUCE EIR concludes that compliance with applicable
regulations and policies that regulate solid waste disposal would ensure that solid waste associated
with development in the City would not exceed the capacity of Cold Canyon Landfill.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
86
Construction
Project construction activity would generate solid waste, including materials such as scrap wood,
concrete, and plaster materials. Construction debris would be removed and disposed of in accordance
with all applicable laws and regulations. The handling of all debris and waste generated during
construction of the project would be subject to CALGreen requirements and the California Integrated
Waste Management Act of 1989 (AB 939) requirements for salvaging, recycling, and reuse of materials
from construction activity on the project site. In accordance with CALGreen requirements, the project
would be required to achieve a minimum of 65 percent diversion rate for construction waste. The
project would also be subject to applicable local regulations including Chapter 8.05 of the City’s
Municipal Code, Construction and Demolition Debris Recycling Program, which outlines sustainable
building regulations designed to reduce waste generated by construction projects. The removal of
construction debris would only occur during the construction period and would be hauled to a facility
that allows the inert debris (gravel, rocks, soil, etc.) that is currently on the project site. Therefore,
construction of the proposed project would not contribute to an exceedance of the permitted
capacity of any local landfill, and potential solid waste impacts related to project construction would
be less than significant. Operation
According to the 2014 LUCE EIR, long‐term waste disposal impacts are minimized by requiring new
development projects to include facilities for the collection and storage of recyclables. Handling of
debris from operational uses would be subject to CALGreen requirements and AB 939 requirements
for salvaging, recycling, and reuse of materials from construction activity on the project site. The
project would also be required to comply with the City’s Municipal Code Chapter 8.04, Solid Waste,
Recycling, and Organic Waste, which includes requirements to facilitate recycling and reduce solid
waste and organic waste. As a result, operation of the project would not conflict with federal, State
or local management and reduction statues related to solid waste. This impact would be less than
significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts to utilities
and service systems, nor would there be potentially significant off-site impacts, cumulative impacts,
or previously identified significant effects that were not discussed in the prior environmental
document. Furthermore, there are no previously identified significant effects which, as a result of
substantial new information not known at the time of the previous environmental review, have been
determined to have a more severe adverse impact than those discussed in the previous
environmental documents. Accordingly, additional review is not required.
ATTACHMENT G
Purview of the Environmental Checklist
Wildfire
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 87
20 Wildfire
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project:
a. Substantially impair an adopted
emergency response plan or emergency
evacuation plan?
□ ■ □ □
b. Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks and
thereby expose project occupants to
pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
□ ■ □ □
c. Require the installation or maintenance
of associated infrastructure (such as
roads, fuel breaks, emergency water
sources, power lines or other utilities)
that may exacerbate fire risk or that may
result in temporary or ongoing impacts
to the environment?
□ ■ □ □
d. Expose people or structures to
significant risks, including downslopes or
downstream flooding or landslides, as a
result of run-off, post-fire slope
instability, or drainage changes?
□ ■ □ □
Analysis in Previous Environmental Documents
The time 2014 LUCE EIR discussed potential impacts associated with wildfire in Section 4.8, Hazards
and Hazardous Materials, on pages 4-171 through 4-173. The 2014 LUCE EIR identified impacts to
wildfire hazards as less than significant. Wildfire was subsequently added as a standalone topic in the
CEQA Guidelines checklist.
The following provides a review to determine whether there would be project-specific impacts that
1) are peculiar to the project or the parcel on which the project is located; 2) were not previously
analyzed in previous environmental documents as significant effects; 3) are potentially significant off-
site impacts and cumulative impacts that were not previously discussed in the previous environmental
documents; and 4) are now determined to have a more severe impact than discussed in the previous
environmental documents due to substantial new information.
Project-Specific Impacts
a. If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project substantially impair an adopted emergency response plan or emergency
evacuation plan?
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
88
b. If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire
risks and thereby expose project occupants to pollutant concentrations from a wildfire or the
uncontrolled spread of a wildfire?
c. If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project require the installation or maintenance of associated infrastructure (such
as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate
fire risk or that may result in temporary or ongoing impacts to the environment?
d. If located in or near state responsibility areas or lands classified as very high fire hazard severity
zones, would the project expose people or structures to significant risks, including downslopes or
downstream flooding or landslides, as a result of run-off, post-fire slope instability, or drainage
changes?
The project site is located within a VHFHSZ as designated by CAL FIRE. However, the site is within an
urbanized area with an established roadway network, including U.S. 101 and local streets, which
provide multiple access and evacuation routes. Project construction and operation would not involve
road closures or other activities that would interfere with emergency response or evacuation. Final
site plans would be reviewed by the City and the Fire Department to ensure compliance with
applicable fire safety and access requirements. Therefore, the project would not substantially impair
an adopted emergency response plan or emergency evacuation plan.
Although the project site is generally flat and surrounded by urban development, its location within
a VHFHSZ indicates potential wildfire exposure under extreme conditions. The project would not
introduce uses that inherently increase wildfire risk, such as large fuel storage or industrial operations.
Compliance with the CBC Chapter 7A (Wildland-Urban Interface standards), California Fire Code, and
defensible space requirements under Public Resources Code Section 4291 would minimize the
potential for the project to exacerbate wildfire risks or expose occupants to pollutant concentrations
from a wildfire. Therefore, the project would not exacerbate wildfire risks.
The project would utilize existing infrastructure and would not require new roads, fuel breaks, or
emergency water sources that could increase fire risk or result in significant environmental impacts.
Utility connections would occur within existing public rights-of-way and would not create conditions
that exacerbate wildfire hazards. Therefore, the project would not require the installation or
maintenance of associated infrastructure that could increase fire risk or cause temporary or ongoing
environmental impacts.
The project site in close proximity to San Luis Obispo Creek, which is within a FEMA-designated Flood
Zone AE (100-year floodplain). While the site and surrounding area are generally flat and lack steep
slopes that could contribute to landslides or debris flows, the combination of wildfire and flood
hazards creates potential for post-fire runoff and localized flooding. However, the project would not
substantially alter drainage patterns or increase susceptibility to post-fire slope instability.
Compliance with the City’s adopted regulatory framework would further minimize these risks. The
General Plan includes policies in the Safety, Water, and Conservation Elements that require
development to avoid or mitigate flood and fire hazards. The Municipal Code establishes enforceable
standards for floodplain development and stormwater management to prevent increased flood risk.
The Waterways Management Plan provides hydrologic and hydraulic guidance to maintain flood
conveyance capacity and protect riparian resources. The City’s Engineering Standards govern grading,
drainage design, and erosion control to ensure stability and proper stormwater conveyance. Finally,
the Stormwater Quality Ordinance requires post-construction controls to reduce pollutant discharges
and maintain water quality during storm events. Together, these measures would support the project
ATTACHMENT G
Purview of the Environmental Checklist
Wildfire
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 89
by requiring incorporation of design and construction practices that reduce the potential for flooding,
drainage changes, or pollutant release following a wildfire. Therefore, although the site is within a
VHFHSZ and a mapped flood hazard area, the project would not expose people or structures to
significant risks related to post-fire flooding, landslides, or drainage changes.
Although the project site is located within a Very High Fire Hazard Severity Zone, the project would
not substantially impair emergency response or evacuation plans, exacerbate wildfire risks, require
new fire-related infrastructure, or expose people or structures to significant post-fire hazards.
Compliance with applicable State and local requirements, including defensible space standards,
ignition-resistant construction, and fire code provisions, would minimize wildfire-related risks.
Therefore, wildfire impacts would be less than significant.
LESS THAN SIGNIFICANT IMPACT
Conclusion
The project would have no new significant or substantially more severe or peculiar impacts related to
wildfire risks, nor would there be potentially significant off-site impacts, cumulative impacts, or
previously identified significant effects that were not discussed in the prior environmental document.
Furthermore, there are no previously identified significant effects which, as a result of substantial
new information not known at the time of the previous environmental review, have been determined
to have a more severe adverse impact than those discussed in the previous environmental
documents. Accordingly, additional review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
90
This page intentionally left blank.
ATTACHMENT G
Purview of the Environmental Checklist
Mandatory Findings of Significance
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 91
21 Mandatory Findings of Significance
Significant
Impact
Less than
Significant
No
Impact
Analyzed in
the Prior EIR
Does the project:
a. Have the potential to substantially reduce
the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop
below self-sustaining levels, eliminate a
plant or animal community, reduce the
number or restrict the range of a rare or
endangered plant or animal or eliminate
important examples of the major periods
of California history or prehistory?
□ ■ □ ■
b. Have impacts that are individually limited,
but cumulatively considerable?
(“Cumulatively considerable” means that
the incremental effects of a project are
considerable when viewed in connection
with the effects of past projects, the
effects of other current projects, and the
effects of probable future projects)?
□ ■ □ ■
c. Have environmental effects which will
cause substantial adverse effects on
human beings, either directly or
indirectly?
□ ■ □ ■
Analysis in Previous Environmental Documents
The 2014 LUCE EIR identified significant and unavoidable impacts related to air quality, land use and
planning, transportation and circulation, and noise due to cumulative regional growth. Consistent
with CEQA Guidelines Section 15183.3, this evaluation finds that the proposed project would not
result in new or more severe significant impacts beyond those already analyzed in the 2014 LUCE EIR.
The 2014 LUCE EIR evaluated the potential regional buildout associated with new potential
development under the LUCE throughout the City of San Luis Obispo. As a result, the analysis of
potential environmental impacts in the 2014 LUCE EIR represents a cumulative analysis, and this
project-specific evaluation acknowledges that the project’s potential contribution to cumulative
impacts—including air quality, GHG emissions, transportation, and noise—remains within the scope
of previously disclosed citywide growth impacts. The project would be required to implement the
applicable mitigation measures identified in the 2014 LUCE EIR, ensuring that cumulative
environmental impacts remain similar or less than those evaluated in the prior analysis.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
92
Project-Specific Impacts
a. Does the project have the potential to substantially reduce the habitat of a fish or wildlife species,
cause a fish or wildlife population to drop below self-sustaining levels, eliminate a plant or animal
community, reduce the number or restrict the range of a rare or endangered plant or animal or
eliminate important examples of the major periods of California history or prehistory?
As discussed in Environmental Checklist Section 4, Biological Resources, the project site does not
contain habitats for sensitive or endangered species. The closest environmentally sensitive habitat to
the project site is the San Luis Obispo Creek. The project would be required to comply with local and
state regulations regarding stormwater run-off and storage of hazardous materials to prevent impacts
to the creek. Therefore, the project would not substantially reduce the habitat of a fish or wildlife
species; cause a fish or wildlife species population to drop below self-sustaining levels; threaten to
eliminate a plant or animal community; or reduce the number or restrict the range of a rare or
endangered plant or animal.
As discussed in Environmental Checklist Section 5, Cultural Resources, and Environmental Checklist
Section 18, Tribal Cultural Resources, the project would not eliminate important examples of the
major periods of California history or prehistory, including archaeological or paleontological
resources. As such, the project would not result in impacts peculiar to the project beyond those
identified in the 2014 LUCE EIR and subsequent environmental documents.
b. Does the project have impacts that are individually limited, but cumulatively considerable?
(“Cumulatively considerable” means that the incremental effects of a project are considerable
when viewed in connection with the effects of past projects, the effects of other current projects,
and the effects of probable future projects)?
Required conformance with City’s General Plan policies specified in this document would ensure
potential impacts are individually limited and not cumulatively considerable in the context of impacts
associated with other pending and planned development projects. The 2014 LUCE EIR includes an
evaluation of potential cumulative impacts associated with buildout of infill projects. The project
involves mixed-use development, development which was anticipated for this site under the 2014
LUCE Update, and other existing and allowable land uses near the project are not significantly
different than those studied in the cumulative analysis of the 2014 LUCE EIR. The 2014 LUCE Update
established goals, policies, and objectives for development and growth throughout the city, through
the year 2035. Therefore, the impact analysis in the 2014 LUCE EIR represents a combined assessment
of the approved land uses within the planning area. The project would not result in significant impacts
peculiar to the project site, as indicated in the individual topic environmental discussions in
Environmental Checklist Sections 1 through 20 above. Nearby development would be similarly
required to comply with local planning documents, otherwise, mitigation measures would be required
to address impacts not covered in the 2014 LUCE EIR. Therefore, the project’s consistency with the
General Plan and subsequent analysis above in Environmental Checklist Sections 1 through 20 indicate
that the project would not result in significant cumulative impacts that were not addressed in the
2014 LUCE EIR.
ATTACHMENT G
Purview of the Environmental Checklist
Mandatory Findings of Significance
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 93
c. Does the project have environmental effects which will cause substantial adverse effects on
human beings, either directly or indirectly?
In general, impacts to human beings are generally associated with air quality, geology and soils,
hazardous materials, noise, traffic safety, and wildfire. As detailed in the preceding Environmental
Checklist sections, the project would not result, either directly or indirectly, in substantial adverse
impacts related to these issue areas. The project’s effects on regional air quality, geology and soils,
hazards and hazardous materials, noise, transportation/traffic, and wildfire would be less than
significant with adherence to applicable regulations and the City’s Standards Conditions of Approval.
Therefore, the project would not have substantial direct or indirect adverse effects on human beings.
Conclusion
The proposed project would be consistent with the development density established by the Land Use,
Circulation, and Housing Elements of the City’s LUCE goals, programs, and policies for which the 2014
LUCE EIR was certified. The project does not conflict with a land use plan, policy or regulation for the
purpose of avoiding or mitigating an environmental effect. Accordingly, based on the assessments
presented in the environmental checklist, the project does not require additional environmental
review as the impacts:
1. Are not peculiar to the project or the parcel on which the project would be located.
2. Were analyzed as significant effects in a prior EIR on the zoning action, general plan, and specific
plan, with which the project is consistent where applicable.
3. Are not potentially significant off-site impacts and cumulative impacts which were not discussed
in the prior EIR prepared for the General Plan and Mid-Higuera Street Enhancement Plan.
4. Are not previously identified significant effects which, as a result of substantial new information
which was not known at the time the 2014 LUCE EIR was certified, are determined to have a more
severe adverse impact than discussed in 2014 LUCE EIR.
The project’s potential environmental impacts were analyzed previously in the 2014 LUCE EIR, and
would be less than significant, or would be reduced or mitigated by the imposition of uniformly
applied development policies or other applicable City Municipal Code requirements. Accordingly,
implementation of the project complies with Section 15183 of the CEQA Guidelines and further
environmental review is not required.
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
94
This page intentionally left blank.
ATTACHMENT G
References
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 95
References
Bibliography
Bies, D., Hansen, C., and Howard, C. 2018. Engineering Noise Control Fifth Edition.
California Air Resources Board (CARB). 2025a. Emissions by Air Basin.
https://ww2.arb.ca.gov/applications/emissions-air-basin (accessed April 2025).
______. 2025b. Overview: Diesel Exhaust and Health. https://ww2.arb.ca.gov/resources/overview-
diesel-exhaust-and-health (accessed May 2025).
California Department of Forestry and Fire Protection (CAL FIRE). 2025. Fire Hazard Severity Zone
Viewer. https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/
(accessed March 2025).
California Department of Conservation (DOC). 2025a. California Important Farmland Finder.
https://maps.conservation.ca.gov/DLRP/CIFF/. (accessed April 2025).
______. 2025b. California Williamson Act Enrollment Finder.
https://maps.conservation.ca.gov/dlrp/WilliamsonAct/. (accessed April 2025).
______. 2025c. California Geological Survey (CGS). Earthquake Zones of Required Investigation Map.
2025. https://maps.conservation.ca.gov/cgs/EQZApp/app/. (accessed April 2025).
California Department of Fish and Wildlife (CDFW). 2025. Natural Community Conservation Planning
(NCCP). https://wildlife.ca.gov/Conservation/Planning/NCCP (accessed June 2025)
California Departments of Transportation (Caltrans). 2020. Transportation and Construction
Vibration Guidance Manual. https://dot.ca.gov/-/media/dot-
media/programs/environmental-analysis/documents/env/tcvgm-apr2020-a11y.pdf
(accessed April 2025).
______. 2025. California State Scenic Highway System Map. 2025.
https://www.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116
f1aacaa . (accessed April 2025).
California State Water Resources Control Board (SWRCB). 2024. Water Quality Control Plan for the
Central Coast Basin.
https://www.waterboards.ca.gov/centralcoast/water_issues/programs/basin_plan/docs/20
24_basin_plan_r3.pdf. (accessed April 2025).
Carr, Paula Juelke, M.A. 2024 (revised August 2025). Historic Preservation Report for the Old Gas
Works, 280 Pacific Street (APN 002-505-006), San Luis Obispo, San Luis Obispo County,
California.
Central Coast Regional Water Quality Control Board (CCRWQCB). 2013. POST-Construction
Stormwater Management Requirements for Development Projects in the Central Coast
Region. July 2013.
https://www.slocity.org/home/showpublisheddocument/5180/635580779348800000
(accessed April 2025)
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
96
Department of Toxic Substances Control (DTSC). 2025 Envirostor. 2025. Webpage.
https://www.envirostor.dtsc.ca.gov/public/profile_report?global_id=40490013 (accessed
April 2025).
Federal Emergency Management Agency (FEMA). 2024. FEMA's National Flood Hazard Layer (NFHL)
Viewer. June 2024. https://hazards-
fema.maps.arcgis.com/apps/webappviewer/index.html?id=8b0adb51996444d4879338b552
9aa9cd&extent (accessed March 2025).
Federal Transit Administration. 2018. Transit Noise and Vibration Impact Assessment Manual.
https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research-
innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no-
0123_0.pdf (accessed April 2025).
Google Maps. 2025.
https://www.google.com/maps/dir/Station+1,+2160+Santa+Barbara+Ave,+San+Luis+Obispo
,+CA+93401/280+Pismo+St,+San+Luis+Obispo,+CA+93401/@35.2727466,-
120.6649193,1107m/data=!3m1!1e3!4m13!4m12!1m5!1m1!1s0x80ecf11845b3b4b3:0x5f2
6dfe97d649d00!2m2!1d-
120.6560299!2d35.2698683!1m5!1m1!1s0x80ecf0e2fbc338cb:0x6df17d8a9ff64b45!2m2!1
d-
120.6684208!2d35.2732331?entry=ttu&g_ep=EgoyMDI1MDYxMS4wIKXMDSoASAFQAw%3
D%3D
Harris, C. 1991. Handbook of Acoustical Measurements and Noise Control.
RS&H. 2021. Amended and Restated San Luis Obispo County Regional Airport (SBP) Airport Land Use
Plan. https://sloairport.com/wp-
content/uploads/2024/02/Airport_Land_Use_Plan_Amended_5-26-21.pdf (accessed April
2025).
San Luis Obispo Air Pollution Control District (SLOAPCD). 2001. Clean Air Plan. December 2001.
https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/business/pdf/CAP.pdf (accessed April 2025).
______. 2018. SLO APCD NOA Screening.
https://www.google.com/maps/d/u/0/viewer?mid=1YAKjBzVkwi1bZ4rQ1p6b2OMyvIM&ll=
35.364843571956705%2C-120.5257891436516&z=10 (accessed April 2025).
______. 2023. CEQA Air Quality Handbook. https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/CEQA%20Handbook%202023_Final.pdf (accessed June 2025).
______. 2025. San Luis Obispo County Attainment Status.
https://storage.googleapis.com/slocleanair-
org/images/cms/upload/files/AttainmentStatus13Jan2025.pdf (accessed April 2025).
San Luis Obispo, City of. 2001. Mid Higuera Street Enhancement Plan. March 2001.
https://www.slocity.org/home/showpublisheddocument/4300/635501904529800000
(accessed March 2025).
______. 2006. General Plan: Conservation and Open Space. Adopted April 2006, revised December
2014.
https://www.slocity.org/home/showpublisheddocument/6651/635670212786530000
(accessed April 2025)
ATTACHMENT G
References
Environmental Consistency Checklist Pursuant to
CEQA Guidelines Section 15183 97
______. 2014. General Plan: Land Use Element. December 2014.
https://www.slocity.org/home/showpublisheddocument/6635/637878804756400000
(accessed March 2025).
______. 2015. General Plan Glossary. 2015.
https://www.slocity.org/home/showpublisheddocument/6653/635670215693100000
(accessed June 2025)
______. 2020a. Appendix C – CEQA GHG Emissions Thresholds and Guidance.
https://www.slocity.org/home/showpublisheddocument/27835/637334343695800000
(accessed April 2025).
______. 2020b. Multimodal Transportation Impact Study Guidelines.
https://www.slocity.org/home/showpublisheddocument/26883/637290299618070000
(accessed April 2025).
______. 2020c. Standard Specifications and Engineering Standards.
https://www.slocity.org/home/showpublisheddocument/27919/637341402080900000
(accessed April 2025).
______. 2021. Active Transportation Plan.
https://www.slocity.org/home/showpublisheddocument/30668/637612629135300000
(accessed April 2025).
______. 2022. Zoning Regulations. February 2022.
https://www.slocity.org/home/showpublisheddocument/5861/637819823369400000
(accessed March 2025).
______. 2023. Climate Adaptation and Safety Element. January 17, 2023.
https://www.slocity.org/home/showpublisheddocument/33524/638102304918770000
(accessed March 2025).
______. 2025. Creeks and Watersheds. https://www.slocity.org/government/department-
directory/city-administration/office-of-sustainability-and-natural-resources/creeks-and-
watersheds (accessed April 2025).
______. 2020. Housing Element 2020-2028.
https://www.slocity.org/home/showpublisheddocument/30985/637667061640130000
(accessed April 2025).
San Luis Obispo Fire Department. 2023. Developers Guide.
https://www.slocity.org/home/showpublisheddocument/5125/638502470796500000
(accessed April 2025).
Terra Pacific Group. 2018. Final Removal Action Workplan Former PG&E Zone 1 Substation Operable
Unit 2. May 24, 2018.
https://www.envirostor.dtsc.ca.gov/getfile?filename=/public%2Fdeliverable_documents%2
F5914797723%2F13137_SLOSUB-Zone1_OU2%20FS-RAW_20180524_Final.pdf (accessed
May 2025).
United States Environmental Protection Agency (EPA). 2025. National Pollutant Discharge
Elimination System (NPDES). 2025. https://www.epa.gov/npdes (accessed April 2025).
ATTACHMENT G
City of San Luis Obispo
Gas Works Mixed-Use Project
98
United States Fish and Wildlife Service (USFWS). 2025a. Information for Planning and Consultation.
https://ipac.ecosphere.fws.gov/location/XLD6QK5PFBCKZJAELLNVIE4SPY/resources
(accessed April 2025).
______. 2025b. National Wetlands Inventory.
https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/ (accessed February
2024).
United States Geological Survey (USGS). 2025. Mineral Resources Online Spatial Data.
https://mrdata.usgs.gov/general/map-us.html#home (accessed March 2025).
______. 2023. Lateral Spread. July 2023. Webpage. https://www.usgs.gov/media/images/lateral-
spread#:~:text=Lateral%20spreads%20are%20distinctive%20because%20they%20usually,fr
om%20a%20solid%20into%20a%20liquefied%20state (accessed April 2025).
_______. 1998. Description Of Map Units. https://pubs.usgs.gov/of/1998/0579/pdf/fskn_dmu.pdf
(accessed June 2025).
_______. 2025. The National Geological Map Database: MapView.
https://ngmdb.usgs.gov/ngmdb/ngmdb_home.html (accessed June 2025).
List of Preparers
Rincon Consultants, Inc. prepared this evaluation under contract to the City of San Luis Obispo.
Persons involved in data gathering analysis, project management, and quality control are listed below.
RINCON CONSULTANTS, INC.
Megan Jones, MPP, Managing Principal
Chris Bersbach, MESM, Senior Supervising Environmental Planner
Zoe Zepp, Environmental Planner
Ethan Knox, Environmental Planner
Steven Treffers, Director of Cultural Resources
Rachel Perzel, Senior Architectural Historian
Jennifer Schwartz, PE, Supervising Engineer
Carly Caswell, Data Analyst
ATTACHMENT G