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Home My WebLink About02/06/1996, 4 - APPEAL OF THE DIRECTOR'S DETERMINATION TO REQUIRE A FOCUSED ENVIRONMENTAL IMPACT REPORT FOR A 66.6-ACRE ANNEXATION AND DEVELOPMENT PROJECT PROPOSED ALONG LOS OSOS VALLEY ROAD BETWEEN MADONNA ROAD AND HIGHWAY 101 (FROOM RANCH). ANNX/R/ER 80 UYIIII��Vlil�ll "J f N ME DATE: Cl o san SUIS OBISPO Z--6 - 6 COUNCIL AGEITEM NDA REPORT NUMBER: b FROM: Arnold Jonas, Community Development Director By: Whitney McIlvaine, Associate Planner 1 SUBJECT: Appeal of the Director's determination to require a focused environmental impact report for a 66.6-acre annexation and development project proposed along Los Osos Valley Road between Madonna Road and Highway 101 (Froom Ranch). Annx/R/ER 80-95. CAO RECOMMENDATION A. Deny the appeal based on findings outlined in the attached resolution for denial. B. Approve workscope for consultant services to prepare an Environmental Impact Report (EIR) for the Froom Ranch Project and authorize staff to proceed with sending out Request for Proposal (RFP) documents to qualified consulting firms, after consultation with the applicant regarding his desire to proceed with the project. C. Authorize the CAO to award the contract to a qualified consulting firm, contingent upon the developer depositing with the City the amount of the contract plus 30%. DISCUSSION Background The Community Development Department has received an application from Alex Madonna to develop a major new retail center along Los Osos Valley Road, roughly the size of the Central Coast Mall and the Madonna Shopping Plaza combined. Mr. Madonna is being represented by Ben Maddalena and Dennis Schmidt of Central Coast Engineering. The application specifically includes: ■ Annexation of 66.6 acres of property to the City limits. ■ Prezoning 54.5 acres of the site Retail-Commercial (C-R) and 12.1 acres Interim Open Space. ■ Lot Line Adjustment to align annexation and existing lot boundaries. ■ Prelbuinary Development Plan showing 300,000 square feet of big box retail in the first phase of development; 300,000 square feet of big box and smaller retail uses in the second phase of development; and 100,000 square feet of future development in the area proposed for Interim Open Space. Planning staff have determined that an EIR will be required to evaluate the potential impacts of the project and identify appropriate mitigation. The appellant's statement maintains that the y/ �iIINNf�II�II�IIII��hNNf�IIUI`� City of san l_ .s oBi spo .0ii% COUNCIL AGENDA REPORT Froom Ranch Appeal Page 2 project should be granted a negative declaration of environmental impact based on studies submitted by Central Coast Engineering on behalf of their client. CEQA RQuirements 1. For projects not exempt under the California Environmental Quality Act (CEQA), the lead agency must prepare an initial study to determine whether a Negative Declaration or EIR is needed. An initial study is then used either to support the Negative Declaration finding that a project will not have a significant unmitigated environmental impact or to focus the EIR. For each area of concern listed in the environmental checklist form, the initial study prepared for this project concludes that either. • The project will not have any significant impact; • There has not been sufficient or adequate information submitted to make a determination regarding the project's potential impacts; or • The project will have potentially significant impacts that must be mitigated. In the last two cases, the initial study recommends speck mitigation and/or funher analysis in order to identify the potential impacts and appropriate mitigation. Information submitted and subsequent project analysis by City staff and other affected agencies do not support a finding that the project will have no significant impact. Therefore, staff developed a workscope for a focused EIR which is attached to this report as pan of the initial study. The initial study and workscope provide a detailed discussion of potential project issues and work tasks that need to beperformed to fully evaluate these issues. 2. California Environmental Quality Act Guidelines state that an EIR, rather than a Negative Declaration, must be prepared if it can be fairly argued on the basis of substantial evidence that the project may have a significant environmental effect, even though the agency has other substantial evidence that the project will not have a significant impact. (Section 15064(8)(1). Substantial evidence noted in the initial study supports a finding that the following project impacts are potentially significant: the impacts of project-generated trafflc on existing street systems, the impacts of storin water runoff on the local drainage system as a result of site development; local air quality and noise impacts resulting from increased traffic; conversion of prime agricultural lands to nonagricultural uses; water supply impacts; and aesthetic impacts. �mM��MI►►�Illll��P�mu�9��U MY Of sari _aI s Oso SPO -11ii% COUNCIL AGENDA REPORT Froom Ranch Appeal Page 3 3. If there is disagreement between experts over the significance of an affect on the environment, the Lead Agency must treat the effect as significant and prepare an EIR. (Section 15064(h). (No Oil, Inc. v. City of Los Angeles, (1974) 13 Cal. 3d 68.) Caltrans, County Engineering, and the City Public Works Department staff disagree with the assumptions, methodology, and conclusions in the traffic study prepared by the applicant's consultant. Caltrans and County hydraulic engineering staff and City Public Works Department staff disagree with the assumptions and conclusions presented in the drainage study prepared by Central Coast Engineering. 4. Regardless of who prepares material used in an environmental determination, the Lead Agency - in this case, the City - is responsible for scope, content, and adequacy of the environmental review. The City would also be responsible for responding to any legal challenge regarding the adequacy of the environmental review. PotentiaHl SiS�g+ifi an Tmpa.rte The applicant was notified at the outset that this project would likely require an EIR because of its scope and potential impacts. City staff and staff from other agencies have reviewed and rereviewed studies and revised studies submitted by the applicant's representatives for the purpose of securing a mitigated Negative Declaration. Nonetheless, certain concerns remain which have not been clearly addressed. The workscope identifies those issues for which information submitted is not sufficient to adequately analyze potential environmental impacts, as in the case of noise, geology, and biological and botanical resources. The workscope also identifies the need for independent analysis where studies submitted (specifically, drainage and traffic) arrive at conclusions with which City staff and other reviewing agencies strongly disagree. Without an objective and complete assessment of potential impacts, appropriate mitigation cannot be identified. Specific concerns about project impacts and the adequacy of material submitted as part of the application in regard to the following issues are: QI= Space Dedication: The 28 acres of proposed open space dedication is not sufficient to be consistent with Land Use Element Policies 1.13.5 and 1.13.5A. The project does not include mitigation for converting prime agricultural land to nonagricultural uses as required by Land Use Element Policies 1.8.1 and 1.8.2, and Open Space Element Chapter II, Section 1.2. �f-3 ��► ►I�Illllp��u►►�U�II city of San t. .3 OBISpo = COUNCIL AGENDA REPORT Froom Ranch Appeal Page 4 Geology: The two-page letter from a Earth Systems Consultants, based on a visual survey without any sample borings and submitted in lien of a geologic report, does not provide sufficient information regarding fault lines, liquefaction, landslides, subsidence, erosion, the feasibility of proposed sedimentation basins, site conditions such as a high water table, and the extent of earthwork and foundation design criteria needed to support the major structures proposed. (See sitelgrading comments from the Building Division, dated July 19, 1995; and from Public Works, dated October 13, 1995.) Drainage: The drainage study submitted assumes that storm water run off from the project site would not be appreciably increased despite covering most ofthe site with nonporous surfaces. It does not adequately address impacts on Prefiuno Creek, freeway drainage culverts, and downstream areas of San Luis Creek. It also does not provide evidence that the ground water levels are deep enough to enable the proposed detention ponds to be functional. (See comments from Caltrans, dated July 28, 1995; from Public Works, dated July 3, October 13, and December 11, 1995; and from the County Hydraulic Engineer, dated January 22,1996.) Water Sunn>v: Senate Bill 901 requires the City to identify the water supply for a project subject to environmental review. The Local Agency Formation Commission (LAFCo) General Standards require the City to demonstrate the adequate, reliable, and sustainable supply of water for any proposed annexation area. The applicant is proposing to acquire a water allocation credit through retrofits. The Urban Water Management Plan estimates that roughly 33 acre feet of water available from retrofitting can be applied to annexation areas. This project will be competing with two other known annexation areas to date -the TK Annexation and Goldenrod -for available water credits. Water is a limited resource and whether or not sufficient allocations will be available for development of this site is largely dependent on the course of development in other annexation areas. If private well water is to be considered, a qualified independent hydrological investigation must demonstrate that on-site wells can reliably provide a sufficient quantity and quality of water for the proposed development without impacting the yields from City wells. (See comments from the Utilities Engineer, dated December 18, 1995) Transportation/Circulation: The first phase of the project (roughly 300,000 square feet of new retail commercial construction)is estimated to generate about 17,000 average daily trips. Current average daily trips along Los Osos Valley Road in this vicinity are 18,000. The first phase would therefore nearly double traffic on this road. Development of the entire project site would more than triple traffic along this road. Clearly, this is a significant impact. Unfortunately, despite costs to the applicant and staff time in three different agencies spent reviewing and rereviewing submittals, traffic impacts have not been squarely addressed by the traffic studies for which the applicant has privately contracted. Therefore, staff is recommending that traffic issues be reviewed by an independent third ply. '►°uu��l�ll��u11 �`I MY of San _.FIs OBispo AAMIGA COUNCIL AGENDA REPORT Froom Ranch Appeal Page 5 A baffle study for this project has been revised twice in response to comments from Caltrans, County Engineering, and City Public Works staff. Still,the report does not provide a clear picture of existing conditions, project impacts, appropriate mitigation for those impacts, an installation schedule for necessary road improvements relative to project phasing, the responsibility for installing such improvements, an accounting of improvement costs, and a determination of which improvements are eligible for Transportation Impact Fee credits, which improvements should be the financial responsibility of the applicant, and which improvements should involve a reimbursement agreement. (See comments from Caltrans dated July 28, 1995 and January 3, 1996; from County Engineering dated July 3, 1995 and January 22, 1996; and from Public Works dated December 8, 1995 and January 22, 1996.) Bioloev: Changes to the Froom Creek drainage channel may impact burrowing owls, which are designated as a species of special concern. A report prepared by a qualified biologist should identify potential impacts and appropriate mitigation. Botany: The botanical report submitted notes the need for performing an additional survey during the Spring when plants can be identified. The survey area should be enlarged to cover all areas affected by the proposed project. Noise: The EIR for the Circulation Element and Land Use Element updates(p.6.6-11) recommends that new development occurring along this segment of Los Osos Valley Road include measures which attenuate noise to less than significant levels(p.6.6-17)for affected residential areas. A noise analysis was not submitted as part of the application, but one should be prepared in order to evaluate the project's noise related impacts. Utility Systems: Project comments received from the Utilities Department note the need for wastewater calculations reflecting the ultimate development of the site so that the City can make a determination as to whether or not downstream facilities can adequately handle the additional flow. Aesthetics: The Circulation Element designates Los Osos Valley Road between Madonna Road and Highway 101 as a roadway with moderate scenic value. An independent visual analysis of the project should be prepared. The analysis should identify potential impacts on views of the Irish Hills and recommend mitigation. Consequences of Not Tatung the Recommended Action Not taking the recommended action could have public service, fiscal, and legal consequences. If a consultant is not retained to prepare the EIR, it would be the responsibility of the City to complete the environmental review of the project. Given the extensive and complex workscope that has been developed for the EE?,, staff would have great difficulty fitting this project into its existing workload. Applicants with other projects subject to planning review would likely ��I►�IIIII�IIP° �UIU city of San t. -.S OBISPO COUNCIL AGENDA REPORT Froom Ranch Appeal Page 6 The cost of staff time necessary to complete the environmental review would exceed application fees. In addition, staff would need to hive sub-consultants to adequately evaluate certain technical issues. It is not clear how that would be financed. Preparation of a mitigated Negative Declaration, as requested by the applicant, would open the City to legal challenge since CEQA requires preparation of an EIR when if it can be fairly argued on the basis of substantial evidence that the project may have a significant environmental effect. CONCURRENCES Other City Departments and affected agencies were routed project plans and materials and prepared written comments thatwere used in identifying issueareas and developing the workscope. FISCAL IMTACI'S Because the City has no appeal fee, the time involved in preparing this report has been absorbed by the City. Preparation of the EIR as recommended by the CAO will not incur any City expense. Once a qualified consultant is selected and a contract negotiated, the cost of the EIR production will be bome by the developer with the administration of the consultant contract overseen by the Community Development Department, in conjunction with the Finance Department. This is the approved procedure for City-required EIRs. Fiscal consequences of not following the CAO recommendation are discussed above. ALTERNATIVES Uphold the appeal and make a finding that the project will not have a significant environmental impact based on substantial evidence and direct staff to prepare a mitigated Negative Declaration. This alternative does not seem reasonable in light of the facts of the project. Attachments: Draft resolutions Initial study Project comments RESOLUTIONNO. (1996 Series) A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO DENYING AN APPEAL OF THE COMMUNITY DEVELOPMENT DIRECTOR'S DETERMINATION TO REQUIRE A FOCUSED ENVIRONMENTAL IMPACT REPORT FOR A 66.6-ACRE ANNEXATION AND DEVELOPMENT PROTECT PROPOSED ALONG LOS OSOS VALLEY ROAD BETWEEN MADONNA ROAD AND HIGHWAY 101 (FROOM RANCH) ANNX/R/ER 80-95 BE IT RESOLVED by the Council of the City of San Luis Obispo, as follows: SECTION 1. Findings. The Council, after consideration of the appellant's statement, the environmental determination of the Community Development Director, staff recommendations and reports thereon, makes the following finding: 1. It can be fairly argued on the basis of substantial evidence, as discussed in the initial study (ER 80-95), that the project may have a significant environmental effect. Therefore, an Envirommnetal Impact Report and not a Negative Declaration is required consistent with Section 15064(8)(1) .of the California Environmental Quality Act. SECTION 2. Action. The appeal of the Director's determination to require preparation of a focused environmental impact report is hereby denied. On motion of seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this _ day of , 1996. Mayor ATTEST: City Clerk y- � Draft resolution denying the•appeal ER 80-95 Page 2 APPROVED: Nloly RESOLUTION NO. (1996 Series) A RESOLUTION OF THE COUNCIL OF THE CITY OF SAN LUIS OBISPO UPHOLDING AN APPEAL OF THE COMMUNITY DEVELOPMENT DIRECTOR'S DETERMINATION TO REQUIRE A FOCUSED ENVIRONMENTAL IMPACT REPORT FOR A 66.6-ACRE ANNEXATION AND DEVELOPMENT PROTECT PROPOSED ALONG LOS OSOS VALLEY ROAD BETWEEN MADONNA ROAD AND HIGHWAY 101 (FROOM RANCH) ANNX/R/ER 80-95 BE IT RESOLVED by the Council of the City of San Luis Obispo, as follows: SECTION 1. Findinge. The Council, after consideration of the appellant's statement, the environmental determination of the Community Development Director, staff recommendations and reports thereon, makes the following finding(s): e.amb,"s'> o tre` ed, t .....:.. :....:....... �.} SECTION 2. Action. The appeal of the Director's determination to require preparation of a focused environmental impact report is hereby upheld and staff is directed to prepare a mitigated Negative Declaration. On motion of seconded by and on the following roll call vote: AYES: NOES: ABSENT: the foregoing resolution was passed and adopted this_ day of , 1996. Mayor ATTEST: City Clerk yl Draft resolution upholdingahe appeal . Page 2 APPROVED: INITIAL STUDY ENVIRONMENTAL CHECKLIST FORM 1. Project Title: Froom Ranch Annexation (Annx/R/ER 80-95) 2. Lead Agency Name and Address: City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93401 3. Contact Person and Phone Number: Whitney Mcllvaine (805)781-7175 4. Project Location: 12395 Los Osos Valley Road, on the southwest side of Los Osos Valley Road between Madonna Road and Calle Joaquin 5. Project Sponsor's Name and Address: Alex Madonna, Madonna Construction Co. P.O. Box 3910 San Luis Obispo, CA 93403 6. General Plan Designation: City: General Retail County: Residential- Single-Family and Agriculture 7. Zoning: County: Residential-Single-Family and Agriculture Requested Zoning Upon Annexation: 54.5 acres Retail-Commercial and 12.1 acres Interim Open Space 8. Description of the Project: The applicant proposes to annex 66.6 acres of land currently under County jurisdiction to the City of San Luis Obispo, with a prezoning of Retail-Commercial for the area designated on the site development plan as "project one" and Interim Open Space for the area designated as "project two." The "project one" area would be developed in two or more phases. The first phase of development would entail construction of two buildings with a total area of roughly 300,000 square feet, each to 1 y-rr be occupied by a single tenant warehouse retailer, such as Costco and Home Base. Changes to existing drainage, utility, and roadway infrastructure are proposed as part of phase one. Also, as part of phase one, the applicant is proposing an open space easement of 28.5 acres on the hillside directly behind the phase one development area. Phase two would include another 300,000 (+/-) square feet of commercial retail space housed in six separate buildings ranging in size from 7,000 square feet to 130,000 square feet. Future development plans for the "project two" area, currently being proposed for Interim Open Space zoning, show a 100,000 square-foot building. Staff anticipates the following public review sequence: 1. Consideration of the Annexation, Prezoning, and Environmental Determination by the Planning Commission, City Council, and Lafco. 2. Consideration of the development plan by the Planning Commission and the Architectural Review Commission. Additional environmental review may be required depending on how consistent the final development plan is with the preliminary development plan proposed in the initial application. However, it is the goal of this initial study to analyze the environmental impacts of the entire project; including-future site development, so that additional environmental review will not be required. 3. Consideration of a lot line adjustment or tentative parcel map to align annexation boundaries with lot lines by the Administrative Hearing Officer. 9. Surrounding Land Uses and Setting: Just outside the proposed annexation area to the south are the Froom Ranch farm house and outbuildings - what remains of one of the area's early dairy farms. To the southeast is agricultural land, used for grazing, that transitions from wetlands to grasslands as the elevation increases. Running roughly parallel with Los Osos Valley Road are the Irish Hills which provide a visual backdrop to the site. To the north of the project site is the Duvall property, which is currently farmed with row crops, but designated for future residential development by both the City and the County. Across Los Osos Valley Road are houses, farmland, and car dealerships. 10. Other public agencies whose approval is required (e.g. permits, financing approval, or participation agreement): San Luis Obispo County - Encroachment permit for right-of-way work on Los Osos Valley Road. Regional Water Quality Control Board - Storm water construction permit. San Luis Obispo County Health Department - Well water usage. Airport Land Use Commission - Project is within the boundary of the Airport Land Use Planning Area. 2 Caltrans - Encroachment permit for right-of-way work. Department of Fish and Game - Streambed Alteration Permit. Army Corps of Engineers - Section 404 Permit to do site work in the wetland area. 3 y-i3 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. X Land Use and Planning X Biological Resources X Aesthetics X Population and Housing X Energy and Mineral X Cultural Resources Resources X Geological Problems X Hazards Recreation X Water X Noise X Mandatory Findings of Significance X Air Quality X Public Services X Transportation and X Utilities and Service A Circulation Systems DETERMINATION: On the basis of this initial evaluation: I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because the mitigation measures described on an attached sheet have been added to the project. A MITIGATIVE NEGATIVE DECLARATION will be prepared. I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required. I find that the proposed project MAY have a significant effect(s) on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as X described on attached sheets, if the effect is a 'Potentially Significant Impact" or "Potentially Significant Unless Mitigated." An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. 4 I find that although the proposed project could have a significant effect on the environment, there WILL NOT be a significant effect in this case because all potentially significant effects (1) have been analyzed in an earlier EIR pursuant to applicable standards and (2) have been avoided or mitigated pursuant to that earlier EIR, including revisions or mitigation measures that are imposed upon the proposed project. January 3 1996 ignatu,w Date Ronald Whisenand Development Review Manager Arnold Jonas Community Development Dir. Printed Name For EVALUATION OF ENVIRONMENTAL IMPACTS: 1) A brief explanation is required for all answers except"No Impact" answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A "No Impact" answer is adequately supported.if the referenced information sources sbow that the impact simply does not apply to projects like the one involved (e. g.the project falls outside a fault rupture zone). A "No Irfipact" answer should be explained where it is based on project-specific factors as well as general standards(e. g.the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis). 2) All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts. 3) "Potentially Significant Impact' is appropriate if there is substantial evidence that an effect is significant. If there are one or more "Potentially Significant Impact" entries when the determination is made, an EIR is required. 4) "Potentially Significant Unless Mitigation Incorporated" applies where the incorporation of mitigation measures has reduced an effect from "Potentially Significant Impact" to a "Less than Significant Impact." The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from Section 17, "Earlier Analysis," may be cross- referenced). 5) Earlier analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. Section 15063 (c) (3) (D)• Earlier analyses are discussed in Section 17 at the end of the checklist. 6) Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g. general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated. A source list should be attached, and other sources used or individuals contacted should be cited in the discussion. 5 4460" Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 1. LAND USE AND PLANNING. Would the proposal: a) Conflict with general plan designation or zoning? 1 X Prezoninp: The proposed prezoning of Commercial-Retail and Interim Open Space is consistent with the General Plan Land Use designation of General Retail and with Land Use Element Policy 8.10, which states that the Irish Hills area shall be zoned Conservation/Open Space upon annexation, and shall be zoned for appropriate urban districts upon approval of development plans. Planning Commission and City Council will determine whether development plans submitted are adequate to enable Commercial-Retail zoning in conjunction with the annexation. Open Soace: The applicant is proposing to dedicate an area of open space equal to the first phase of development - approximately 28 acres on the hillside just outside the annexation boundary. The open space easement proposed may not be consistent with Land Use Element Policies 1.13.5 and 1.13.5A. Policy 1.13.5 states that each annexation shall help secure permanent protection for areas designated Open Space on the General Plan Land Use_Element map, such as the Irish Hills above the 150-foot elevation and the wetland area to the south of the project site. Policy 1.13.5A states that Irish Hills Area properties shall dedicate land or easements covering an area at/east equal to the area to be developed. Ultimately,the entire annexation area is to be developed, consistent with the General Plan land use designation of General Retail. Dedicating an open space area equal to the annexation area would seem more consistent with the General Plan policies. Mitigation: The project shall include a dedication of open space at least equal to the area to be annexed. b) Conflict with applicable environmental plans or policies X adopted by agencies with jurisdiction over the project? The project may require modification to be consistent with environmental polices of the Department of Fish and Game, the Amry Corp of Engineers. However, since the project is subject to compliance with the environmental polices of these agencies prior to issuance of any permit, significant impacts are not likely. c) Be incompatible with existing land use in the vicinity? X Site development is subject to architectural review. During that process,site planning and building design will be evaluated for compatibility with existing and proposed development in the vicinity of the project. The need to develop mitigation for traffic, noise and visual impacts is discussed below. 6 y�� Issues and Supporting Information Sources Sources Potentially Potentially Loss Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated d) Affect agricultural resources or operations (e.g. impact to 1,2,4 X soils or farmlands, or impacts from incompatible land uses)? The project will ultimately remove 66.6 acres of farmland from agricultural production. According to the U.S.D.A. Soil Conservation Service maps, the two dominant soil types on the site (Cropley clay 127, and Salinas silty clay loam, 197) are prime farmland soils (pp 102, 103; Soil Survey of San Luis Obispo County, Coastal Part). Without mitigation, the project may not be consistent with the following General Plan goal and policies: ► Land Use Element Goal #5 states: Recognize the importance of farming to the economy of the planning area and the county, protect agriculture from development and incompatible uses, and protect remaining undeveloped prime agricultural soils. ► Land Use Element Policy 1.8.1 Agricultural Protection states: It is the City's policy to encourage preservation of economically viable agricultural operations and land within the urban reserve and city limits. The City should provide for the continuation of farming through steps such as provision of appropriate general plan designations and zoning. ► Land Use Element Policy 1.8.2 Prime Agricultural Land states: Development of prime agricultural land may be permitted, if the development contributes to the protection of agricultural land in the urban reserve or greenbelt by one or more of the following methods, or an equally effective method. acting as a receiver site for transfer of development credit from prime agricultural land of equal quantity; securing for the City or for a suitable land conservation organization open space easements or fee ownership with deed restrictions;helping to directly fund the acquisition of fee ownership or open space easements by the City or a suitable land conservation organization. Development of small parcels which are essentially surrounded by urbanization need not contribute to agricultural land protection. The Environmental Impact Report for the Land Use(LUE)and Circulation Elements, prepared for the City of San Luis Obispo by Fugro-McClelland (West) in January, 1993, includes a copy of Resolution No. 8332, approving the LUE update. That resolution identifies an overriding consideration for conversion of prime agricultural land to urban use, which is: Accommodating a reasonable share of anticipated regional growth within the urban reserve line, contiguous to existing development, while preserving land outside the urban reserve line. This statement of overriding consideration does not eliminate the need for the project to mitigate loss of prime agricultural land consistent with Policy 1.8.2. The project has been reviewed by the County Agricultural Commissioner, and his recommendations are incorporated into the recommended mitigation measures. 7 Issues and Supporting Information Sources Sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Mitigation: To avoid conflicts with ongoing farming and grazing operations in the vicinity, consistent with Open Space Element (Chapter Il. Section I. 2), the project shall include an agricultural buffer, providing a barrier of vegetation capable of eliminating potentially adverse impacts associated with agriculture on adjacent parcels. At the time of sale or lease,the applicant should disclose to prospective buyers and tenants the consequences of existing and potential intensive agricultural operations on nearby parcels including but not limited to dust, noise, odors, agricultural chemicals, and the County's Right to Farm Ordinance. A copy of such disclosure should be submitted to the County Agricultural Commissioner and the City Community Development Director for review, approval, and recordation prior to any further subdivision or site development. The project shall be modified to include one or more of the following methods, or an equally effective method, for protecting prime agricultural land within the urban reserve or greenbelt: acting as a receiver site for transfer of development credit from prime agricultural land of equal quantity; securing for the City or for a suitable land conservation organization open space easements or fee ownership with deed restrictions; helping to directly fund the acquisition of fee ownership or open space easements by the City or a suitable land conservation organization. e) Disrupt or divide the physical arrangement of an y established community (including a low-income or minority community)? 2. POPULATION AND HOUSING. Would the proposal: a) Cumulatively exceed official regional or local population X projections? See discussion under 2.b. b) Induce substantial growth in an area either directly or 2 X indirectly (e.g. through projects in an undeveloped area or major infrastructure? Resolution No. 8332, approving the 1994 Land Use Element Update acknowledges the likelihood of the number of workers to increase more than the number of residents, resulting in additional commuting, with secondary impacts to energy consumption, air pollution, and traffic levels of service. Despite the further imbalance between jobs and housing likely to result from a future development scenario that is consistent with Land Use Element policies, the Council approved the update based on an overriding consideration for maintaining San Luis Obispo's fiscal health and hub role, and avoiding further expansion of residential development into open space areas. It is recommended under associated categories in this initial study that mitigation be included in the project which helps to reduce the adverse impacts to energy consumption, air pollution, and traffic. c) Displace existing housing, especially affordable housing? X 8 1/49 Issues and Supporting Information Sources Sources Potentially Potentially Leve Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 3. GEOLOGIC PROBLEMS. Would the proposal result in or expose people to potential impacts involving: a) Fault rupture? 1 3 1 X A draft EIR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Amendment (County file Nos.: G851030:2; ED86-67) notes that a branch of the Los Osos Valley fault may be present under the alluvium near the base of the Irish Hills. Investigations of the Los Osos fault by PG&E include a series of aerial photos which show a tonal lineament near the base of the Irish Hills on the project site, which could be indicative of faulting or could merely represent a distinct boundary between two soil units. It is not possible to know which is the case without further investigation. A letter from Earth Systems Consultants dated October 10, 1995 was submitted as part of the application. It does not address the location of fault lines relative to the project site. Workscope Issue: An independent geologic investigation should identify the likelihood of a fault zone at the base of the Irish Hills. b) Seismic ground shaking? X See discussion under 3.c. c) Seismic ground failure, including liquefaction? 1 X The project site is shown on the City's General Plan Seismic Safety Element map as having a high risk for liquefaction. Workscope Issue: This should be further investigated as part of an independent engineering geology report and preliminary soils report. d) Seiche, tsunami, or volcanic hazard? X e) Landslides or mudflows? 1,3,4 X 9 Issues and Supporting Information Sources Sources Potentially Potentially Lege Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated The City's General Plan Seismic Safety Element map shows two landslide areas on the hills just above the project site. The County designates the Irish Hills as a geologic study area. Springs in the hills can accelerate creep and should be located in relation to the project site. The Soil Conservation Service maps indicate that the soils on the slopes immediately behind the proposed development area (Los Osos-Diablo complex, 164) have a high shrink-swell potential in the subsoil and are subject to slippage when wet. It is not clear how setting two large building into the toe of the hillside would affect hillside stability. Workscope Issue: A 2-page letter from Earth Systems Consultants dated October 10, 1995 was submitted as part of the project application, which discusses a staff geologist's visual survey of the site. It should be reviewed as part of an independent engineering geology report, but its cursory evaluation of the site's geology is not an adequate substitute for a full report. The geologist who prepared the letter found no evidence of landslide activity, but did note an existing mudslide and significant mounds of fill near the proposed Building 2. These areas should be mapped as part of the engineering geology report. f) Erosion, changes in topography or unstable soil conditions 4 X from excavation, grading or fill? Because of the type of soil and the steepness of the slopes at the rear of the project site, surface runoff is fast and the hazard of water erosion is high. The project proposes to locate sediment basins at the rear of Buildings 1 and 2 to catr rock and other debris moving down slope during a storm. Workscope Issue: An independent engineering geology report should evaluate the viability of the proposal and provide recommendations for the construction, capacity, and maintenance of such basins. g) Subsidence of the land? 3 X A soils report prepared by Pacific Geoscience for a project previously proposed on property immediately to the south of the project site identified conditions - such as high ground water - that would require extensive earthwork to provide suitable support for major structures. Also see discussion under 41 regarding subsidence as a result of well water use. Workscope Issue: A preliminary soils engineering report should be prepared for this project that identifies necessary earthwork and foundation design criteria for the site development proposed. h) Expansive soils? 3,4 X 10 y-� Issues and Supporting Information Sources sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated The Soil Conservation Service maps indicate that three of the four soil types underlying the project site have a high shrink- swell potential. A soils engineering report is required prior to building permit issuance. Foundation design and construction must be in accordance with recommendations in the soils report. A preliminary soils engineering report is typically required for large development projects to identify the site's ability to support proposed development and earthwork necessary to offset any constraints posed by the character of on-site soils. Workscope Issue: A preliminary soils engineering report should be prepared for this project that identifies necessary earthwork and foundation design criteria for the site development proposed. i) Unique geologic or physical features? X The project will change the character of the Irish Hills in this area. However, the impact is primarily aesthetic and is therefore discussed below. - 11 Issues and Supporting Information Sources Sources Potentially Potentially Leve Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 4. WATER. Would the proposal result in: a) Changes in absorption rates, drainage patterns, or the rate 1,5 X and amount of surface runoff? A hydrology report was submitted by Central Coast Engineering in November, 1995. After reviewing the report, the City Engineer concluded that the report misapplies City standards in calculating storm water runoff, and errs in assuming that since storm flows currently exceed the capacity of drainage facilities in Los Osos Valley Road, any additional runoff resulting from developing the project site is not significant. The report estimates an overall runoff increase of around 4%. City and County engineering staff estimate the likely increase in runoff to be between 47% and 143% for a 10 year storm. Unless this runoff is properly conveyed, the resulting flooding of roadways and businesses could pose a serious threat to public health and safety. In reviewing the report, Cal Trans staff also note the need for accurate mapping of depth to ground water in order to assess the viability of the proposed sedimentation ponds and detention basins. Workscope Issue: A drainage and hydrology study, prepared by an independent engineer, which reasonably assesses the likely impacts of development on the drainage system in the vicinity and feasible methods of mitigating such impacts, should be submitted to the satisfaction of the City, County, and Cal Trans. The study should analyze ground water depth, availability and quality; estimate storm water runoff as a result of impervious surfacing; identify the capacity of drainage facilities n Highway 101 to convey storm water from this project, identify necessary improvements and associated costs improvements to avoid flooding those facilities; quantify runoff from the hills behind the area proposed for development; specifically evaluate the likely effectiveness of proposed detention basin(s) in the wetlands area; and identify feasible methods for collection and management of sedimentation likely to occur in conjunction with upslope runoff. The study should adequately answer all issues raised in Section 4 of the City's environmental checklist, including likely impacts of well-water use on available groundwater. Using the information in the drainage and hydrology study, a drainage master plan must be formulated to the approval of the City, County, and Cal Trans. The plan should show how the total property is to be developed, including Froom Creek and the area between the proposed development and Highway 101. The drainage shall be designed to mitigate any adverse impacts that may be caused by development of the project site, and be adequately conveyed to an appropriate point of disposal in San Luis Creek to the satisfaction of the City Engineer. This may require detention basins (on-or off- site, and above or below ground), culvert enlargements, etc. Costs of necessary improvements should be estimated so that fiscal impacts on the City,if any, can be evaluated consistent with Land Use Element Policies 1.13.2 and 1.13.3, both of which require an analysis of needed capital facilities and their financing. b) Exposure of people or property to water related hazards X such as flooding? See discussion under 4.a. c) Discharge into surface waters or other alteration of X surface water quality (e.g. temperature, dissolved oxygen or turbidity? 12 2Vou Issues and Supporting Information Sources Sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated See discussion under 4.a. d) Changes in the amount of surface water in any water X body? See discussion under 4.a. e) Changes in currents, or the course or direction of water X movements? See discussion under 4.a. f) Change in the quantity of ground waters, either through X direct additions or withdrawals, or through interception of an aquifer by cuts or excavations or through substantial - loss of groundwater recharge capability? See discussion under 4.a. g) Altered direction or rate of flow of groundwater7 X See discussion under 4.a. h) Impacts to groundwater quality? X See discussion under 4.a. i) Substantial reduction in the amount of groundwater 1,5 X otherwise available for public water supplies? See discussions under 4.a and 12.g. Policy 1.13.4 in the Land Use Element explains that actual development of annexed areas may be approved if any combination of City water, retrofitting, or interim well water (subject to Council approval) is available. Private well water may be used, but only as an interim source and only where it is demonstrated that the use of well water will not diminish the City's municipal ground water supply. The Urban Water Management Plan (pp 25-32) stipulates that the City will be the only purveyor of water and that a well can only serve the lot on which it is located. Use of well water is subject to Council approval. A qualified independent hydrological investigation must demonstrate that the wells can reliably provide a sufficient quantity and quality of water for the proposed development without impacting the yields from City wells. Workscope Issue: If the subdivider wishes to use well water, he shall arrange with the Utilities Director for the preparation of an independent hydrological investigation, that describes the reliability, yield, and quality of available ground water, impacts on groundwater recharge, and the likelihood of subsidence as a result of projected well water use. The findings and recommendations of such an investigation shall be submitted to City Council for consideration in its determination to allow use of well4water for development of this subdivision prior to final map approval. 13 4g23 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 5. AIR QUALITY. Would the proposal: a) Violate any air quality standard or contribute to an exiting 9 X or projected air quality violation? San Luis Obispo County is a nonattainment area for the State ozone and PM„ (fine particulate matter 10 microns or less in diameter) air quality standards. State law requires that emissions of nonattainment pollutants and their precursors be reduced by at least 5% per year until the standards are attained. Motor vehicles account for about 40% of the precursor emissions responsible for ozone formation, and are also a significant source of PM,,. All jurisdictions are expected to incorporate applicable strategies in their project review process to ensure that motor vehicle emissions resulting from new development are minimized to the maximum extent possible. Site development will impact air quality as a result of construction activity and traffic generated by uses established. Standard mitigation is recommended to minimize the impacts resulting from construction activity and future site development. Mitigation: Phase one improvements shall include transit turnouts, with shelters on Los Osos Valley Road, to the satisfaction of the Transit Manager,as well as sidewalk installation, street tree planting, and bike lane striping to the satisfaction of the C' Engineer. Grading and construction of site improvements shall include the following dust suppression measures: Consistent with grading standards in the Uniform Building Code appendix (Chapter 70, Section 7004 b), all graded surfaces shall be wetted, protected or contained in such a manner as to prevent dust or spill upon any adjoining property or street. The following measures shall constitute the project's dust management plan and shall remain in effect during all phases of the project's construction: a. Regular wetting of roads and graded areas (at least twice daily with complete coverage of all active areas); b. Increasing frequency of watering whenever winds exceed 15 mph; c. Cessation of grading activities during periods of winds over 25 mph; d. Direct application of water on material being excavated and/or transported onsite or off site; e. Watering material stockpiles; f. Wheel washers shall be installed where vehicles enter and exit unpaved surfaces onto the surrounding streets; and g. Daily wash downs, or mechanical street sweeping, of Los Osos Valley Road in the vicinity of the construction site. h. Use of non-potable water is required in all construction and dust control work. All PM„ mitigation measures required shall be shown on grading and building plans. The contractor shall designate a person or persons to monitor the dust control program consistent with APCD guidelines and shall provide the contact name(s) and telephone number(s) to the Community Development Department prior to permit issuance. 14 Issues and Supporting Information Sources sources Potentially Potentially Lose Than No Significant Significant Significant impact Issues Unless Impact Mitigation Incorporated Air Quality Mitigation cont'd: Future site development shall include measures to minimize negative impacts to air quality, such as: a. Extensive tree planting in the parking areas to reduce evaporative emissions from automobiles. b. A carpool/rideshare/public-transit information bulletin board installed in a visually prominent and easily accessible location. c. Weatherproof and lockable bicycle storage, as well as short-term bicycle parking racks. d. Bicycle parking and shower and locker facilities for employee use. e. Shared-use parking reduction. - f. Designated employee carpool parking. g. On-site food facilities to encourage employees to stay on site during the lunch hour. b) Expose sensitive receptors to pollutants X c) Alter air movement, moisture, or temperature, or cause X any change in climate? d) Create.objectionable odors? X 15 7aZS Issues and Supporting Information Sources Sources Potentially Potentially Leve Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 6. TRANSPORTATION/CIRCULATION. Would the proposal result in: a) Increased vehicle trips or traffic congestion? 1,7 X X The City Engineer has reviewed the plans and the traffic study and recommends the following mitigation: Mitigation: The Developer shall provide for dedication of needed right of way (R/W) to accommodate the ultimate width of 108 ft. for Los Osos Valley Road (LOVR), between Madonna Rd. and US 101, as depicted on the development plans. This may require dedication on both sides of LOVR, including portions not owned by the Developer. The City Council may consider lending its power of condemnation, if offsite acquisition is not able to be negotiated successfully, and upon execution of an agreement between the City and Developer, wherein the Developer agrees to pay all applicable costs to acquire such offsite R/W, as determined by the City. - The Developer shall provide paving of Los Osos Valley Rd., between Madonna Rd. and US 101 to accommodate 4 lanes of traffic, 6 ft. bike lanes, necessary tum lanes, including signing and striping (thermoplastic), asphalt berms and concrete curb and gutters(adjacent to Phases 1 and 2) and such median improvements determined to be necessary to control traffic movements and drainage, to the satisfaction of the City Engineer, County Engineer and CalTrans. Six (6) ft.-wide detached sidewalk shall be installed along the frontage of Phases 1 and 2, as part of Phase 1. Graded sidewalk/parkway areas (4 ft. wide minimum behind the curb line) shall be provided for the remainder of the frontages, pending development of those properties. Offsite easements and all-weather surface access roads will be required, to the satisfaction of the City Engineer and Utilities Engineer. Street lighting shall be installed that meets City standards along the LOVR corridor. Traffic Study: Penfield&Smith submitted a traffic study prepared for Central Coast Engineering in June, 1995. After receiving comments from the City Engineer, Cal Trans, and County Engineering, the consulting firm submitted a revised report in November, 1995. After reviewing the second submittal, Public Works Department staff note that there continue to be serious issues which are not adequately addressed in the traffic study. They are, therefore, recommending that an independent consultant review the traffic analysis to develop clear statements of impact and specific mitigation. Some specific concerns with the traffic analysis as submitted are: 1. The project description used for the traffic analysis only addresses impacts associated with the first phase of development. CEO.A Section 15063(a)(1) requires that all phases of a project be considered in the initial study. 16 .yo2G Issues and Supporting Information Sources Sources Potentially Potentially Lasa Than No Significant Significant Significant Impact ' Issues Unless Impact Mitigation Incorporated 2. The analysis seems to contradict itself in concluding that the studied section of Los Osos Valley Road currently operates within acceptable levels of service, but then recommending that extensive (projects totaling an estimated $900,000) mitigation is necessary to correct existing poor operating conditions, in order to better accommodate the project. 3. The analysis concludes that Los Osos Valley Road does not need to be widened between Madonna Road and the project's northerly entrance, despite the fact that the first phase of the project would nearly double existing traffic levels. 4. Pedestrian crossing as designed at the mid-site entrance may result in numerous auto-pedestrian conflicts, possibly in violation of the MUTCD guidelines for proper signaling. 5. The analysis assumes that locating 300,000 square feet of new retail space will not alter the existing traffic distribution, and that, therefore, impacts on the LOS OSOS VALLEY ROAD/Highway 101 interchange can be mitigated with signalization. Cal Trans, County Engineering, and City Public Works disagree with this assumption, and recommend that the distribution of traffic be related more realistically to the likely market for the proposed retail uses. 6. It is not clear from the traffic study when traffic mitigation would be installed. 7. The traffic study proposes 3 additional signals on Los Osos Valley Road between Madonna Road and the Highway 101 on-ramp. This may not be beneficial to the city because of delays caused by signals and because this increase in the number of signals will have fiscal impacts on the City. Each signal costs the City roughly 0,000 a year (energy and maintenance) plus staffing costs. 8. A bus turn-out was required and indicated in the traffic report but is not shown on the street improvement plans. 9. The study suggests that parking be provided at a ratio of 1 space to approximately 150 square feet of building area, for a total of 1,950 spaces in phase one. Using the same ratio for phases two and three would result in 4,875 spaces, or roughly 40 acres of surface parking. The feasibilty of a parking structure should be evaluated. City standards would require 1 space per each 500 square feet of building area. The study also recommends that the parking lot be utilized as a park-and-ride lot but doesn't provide any analysis of the likely users and their destinations. 10. The study does not clearly analyze improvement costs and fiscal impacts on the City. Workscope Issue Area: An independent consultant should review the traffic analysis, provide additional evaluation as required by the City Engineer, and develop clear statements of impact and specific mitigation. The review should include an Executive Summary that identifies all assumptions, impacts, and recommendations, and addresses all areas of concern listed above to the satisfaction of the City Engineer, Cal Trans, and County Engineering. The applicant should provide the City with a disk copy of the computer analysis so the information can be independently assessed. Without access to this data the modeling assumptions and analysis techniques cannot be easily evaluated. 17 Issues and Supporting Information Sourdes Sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated b) Hazards to safety from design features (e.g. sharp curves X or dangerous intersections) or incompatible uses (e.g. farm equipment))? See discussion under 6.a. above. c) Inadequate emergency access or access to nearby uses? X See discussion under 6.a. above. d) Insufficient parking capacity on-site or off-site? X See discussion under 6.a. above. e) Hazards or barriers for pedestrians or bicyclists? X See discussion under 6.a. above. f) Conflicts with adopted policies supporting alternative X transportation (e.g. bus turnouts, bicycle racks)? See discussion under 6.a. above. g) Rail, waterborne or air traffic impacts (e.g. compatibility "'0 X with San Luis Obispo Co. Airport Land Use Plan)? The project site is within land use area 6 as designated by the Airport Land Use Plan. Uses proposed as part of this project are listed as compatible in the plan's Airport Land Use Compatibility Listing. Site development is subject to review by the Airport Land Use Commission. The recommendations of that commission will be presented to the City Planning Commission and Council for a determination of General Plan consistency. 18 y2$ Issues and Supporting Information Sources Sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 7. BIOLOGICAL RESOURCES. Would the proposal result in: a) Endangered, threatened or rare species or their habitats 1,3,6 X (including but not limited to plants, fish, insects, animals or birds)? Biological Resources: The Draft EIR prepared for the Madonna General Plan Amendment for property immediately south of this project site notes the presence of burrowing owls along the banks of Froom Creek. This species is designated as a species of special concern, second priority, in California by the California Department of Fish and Game and the U.S. Fish and Wildlife Service. In general,all wetlands provide valuable wildlife habitat. The project proposes changes to the Froom Creek drainage channel and the wetland area. Workscope Issue: A biological study should identify potential impacts on the burrowing owl and other species as a result of proposed modifications to the banks of Froom Creek and changes to the existing drainage pattern. The report should include recommended mitigation measures where impacts may be significant. Botanical Resources: A botanical study prepared by V. L. Holland for 50 acres of the project site was submitted with the application. Essentially, the level area proposed to be prezoned Retail Commercial was surveyed. The hillside portion of the project one area and the remaining area to be prezoned Interim Open Space were not surveyed. The report states that no rare plants were found within the boundaries of the 50 acre site studied. However, the report also notes that the area was surveyed only in July, and that plants listed are only those found in identifiable condition. The report states that a thorough survey throughout the entire year, especially during Spring, would be necessary for a complete listing of the site's flora. The report concludes that loss of the vegetation cover will result in loss of the site's current agricultural use as rangeland and will reduce the amount of open grassland areas available to various wildlife species. The botanist anticipates Tittle loss of native plants due to the already disturbed nature of the site. The report recommends that site development be confined to the valley floor as much as possible and that grading on the western boundary be minimized to ensure avoidance of the serpentine habitat that supports rare plants. Workscope Issue: The botanical report is very thorough and well-documented. To complete the work begun, one additional survey should be done in the Spring to better determine the full range of plant species that inhabit the site. That.survey should include the entire project area and the adjacent wetland since modifications to the wetland area are proposed as part of the drainage plan. Any additional potential impacts identified as a result of the second survey should be documented together with recommended mitigation. b) Locally designated species (e.g. heritage trees)? X See discussion under 7.a. c) Locally designated natural communities (e.g. oak forest, X coastal habitat, etc.)? 19 02/ Issues and Supporting Information Sources Sources Potentially Potentially Lege Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated See discussion under 7.a and d. Alteration of the drainage pattern in the wetland area is proposed. d) Wetland habitat le.g. marsh, riparian and vernal pool)? I I X The project proposes to build a levee on the outside bank of Froom Creek where it bends to the east to form the channel that runs alongside the Howard Johnson's property. The design of the levee and a hydraulic analysis of the flows and velocity of water the levee should be able to withstand must be determined in order to evaluate this proposal and its potential effects on the surrounding wetlands. The project also proposes to establish detention basins in the wetland area, which would be fed by storm water runoff from the project conveyed via open culvert along Los Osos Valley Road. Workscope Issue Area: As part of the drainage study evaluation recommended above under Section 4.a, a hydraulic analysis of Froom Creek should be performed with recommendations for levee design. Installation of a levee should then be analyzed to determine how much wetland area will be lost as a result of the fill necessary to create the levee, and how`the diversion of water might reduce the sustainability of the remaining wetlands. A restoration plan should be formulated in the event the levee washes out and deposits sedimentation in the wetlands. The likely effectiveness and impacts of detention basins in the wetlands area should also be evaluated. e) Wildlife dispersal or migration corridors? X Workscope Issue: A master plan for project drainage must identify potential impacts on wildlife supported by the existing wetland area, with recommend mitigation where necessary. 8. ENERGY AND MINERAL RESOURCES. Would the proposal: a) Conflict with adopted energy conservation plans? 1 X The Energy Element states that, "New development will be encouraged to minimize the use of conventional energy for space heating and cooling, water heating, and illumination by means of proper design and orientation, including the provision and protection of solar exposure." See recommended mitigation under 8.b below. b) Use non-renewable resources in a wasteful and inefficient 1 X manner? 20 30 Issues and Supporting Information Sources Sources Potentially Potentially Less Then No Significant Significant Significant Impaet Issues Unless Impact Mitigation Incorporated To avoid using non-renewable resources in an inefficient manner, the following standard mitigation is recommended: Mitigation: Future construction projects shall include a solid waste recycling plan for recycling discarded materials, such as concrete, sheetrock, wood, and metals, from the construction site. The plan must be submitted for approval by the Community Development Director, prior to building permit issuance. Future site development should incorporate: Skylights to maximize natural daylighting. Operable windows to maximize natural ventilation. • Energy-efficient lighting systems for both interior and exterior use. 4 Facilities for interior and exterior on-site recycling. Monitoring: Architectural review and building permit issuance. c) Result in the loss of availability of a known mineral X resource that would be of future value to the region and the residents of the State? 9. HAZARDS. Would the proposal involve: a) A risk of accidental explosion or release of hazardous X substances (including, but not limited to: oil, pesticides, chemicals or radiation)? b) Possible interference with an emergency response plan or X emergency evacuation plan? c) The creation of any health hazard or potential health X hazard? d) Exposure of people to existing sources of potential health X hazards? e) Increased fire hazard in areas with flammable brush, grass j j j X of trees? 21 Issues and Supporting Information Sources Sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 10. NOISE. Would the proposal result in: a) Increase in existing noise levels? 1,2 X The project will have potentially, negative impacts on residential uses as a result of developing commercial facilities immediately adjacent to property zoned for residential development and as a result of road widening and increased traffic. The Circulation Element lists widening of Los Osos Valley Road between Madonna Road and Highway 101 as a project to be completed if the Irish Hills area is developed (p.28). This project triggers the need for road widening. The EIR for the Circulation Element and Land Use Element updates (p.6.6-11) estimates that the increase in traffic associated with the road widening will increase the noise level within 100 feet of the centerline by 1.4 Ldn (average decibel increase over a 24 hour period). This would expose residential properties along the frontage road between Garcia Drive and Madonna Road to an Ldn level of 62.9. The EIR notes that the existing situation (an Ldn of 61.5 within the 100-foot contour) already exceeds recommended noise exposure thresholds for residential uses (p.6.6-4). The Noise Element states that outdoor activity areas for residential uses should not be exposed to a noise level exceeding 60 Ldn (p.1.18).-The EIR recommends as mitigation that new development that occurs along this segment should include measures which attenuate noise to less than significant levels (p.6.6-17). A noise analysis was not submitted as part of the application, but one should be prepared in order to evaluate the project's noise related impacts. Workscope Issue: The proposed site planning and design of the road widening and center median should be reviewed by an independent acoustical engineer to determine appropriate noise attenuation measures, which may include buffer areas, earthen berms, sound walls, or a combination thereof. b) Exposure of people to severe noise levels] X 11. PUBLIC SERVICES. Would the proposal have an effect upon, or result in a need for new or altered government services in any of the following areas: a) Fre protection? X b) Police protection? X c) Schools? X d) Maintenance of public facilities, including roads? 1,7 X 22 3Z i Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact 1 Issues Unless Impact Mitigation Incorporated In reviewing the traffic study submitted with this project, Public Works staff note that each new traffic signal proposed would cost the City roughly $5,000 per year to maintain, and that staff resources*are now fully used in maintaining the existing system. Upon annexation, maintenance of the annexed portion of Los Osos Valley Road would also become the responsibility of the City. Land Use Element Policy states that development plans in annexation areas must identify needed capital facilities and funding. Workscope Issue: The City's responsibility for road and traffic signal maintenance and associated fiscal impacts should be evaluated as part of the recommended independent analysis of the traffic study. e) Other governmental services? X 12. UTILITIES AND SERVICE SYSTEMS. Would the proposal result in a need for new systems or supplies, or substantial alterations to the following utilities: - a) Power or natural gas? X The project was routed to PG&E for comment. They note that pole lines across the project site to serve the ranch house and along Los Osos Valley Road will have to be relocated to accommodate the project. City policy requires that these and any new power lines be installed underground. The project was also routed to Southern California Gas Company for comment. They note there are gas lines within the project boundary and recommend that construction plans specifically state who to contact for facility location and marking prior to the start of construction. Mitigation: All new and existing overhead wire utilities shall be undergrounded along the project frontage, to the satisfaction of the respective utility companies and City Engineer. Overhead wire utilities adjacent to "offsite' frontages may be relocated utilizing overhead facilities, to the satisfaction of the City Engineer and utility companies. To allow Southern California Gas Company time to locate and mark existing gas lines that will be affected by the project, the following note shall be placed on plans submitted for a building or grading permit application: For location and marking of Southern California Gas Company facilities, call Underground Service Alert (USA) toll free at 1-800-642-2444 a minimum of 48 hours, but preferably 10 days, prior to the start of construction. Monitoring: Building permit plan check. b) Communications systems? X See discussion under 12.a above. Road widening and frontage improvements may affect telephone, cable, and AT&T's fiber-optic services. City policy requires all new and relocated electric, telephone, and cable services for this project to be installed underground to avoid visual impacts of overhead service lines. 23 y33 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impatt - Issues Unless Impact Mitigation Incorporated c) Local or regional water treatment or distribution facilities? X To ensure adequate water and sewer services, the following standard mitigation is recommended: Mitigation: Sanitary sewer and water mains shall be installed to City standards and specifications. Main line alignment, sizes and grades are subject to modifications to the satisfaction of the City Engineer and Utilities Engineer. Any oversizing of public mains required by the City to serve tributary areas outside the Developer's ownership and/or greater than required for providing for development minimum fire flows will qualify for reimbursement by the City, in accordance with City regulations. d) Sewer or septic tanks? x See 12.c above. Workscope Issue: Project comments received from the Utilities Department note that the developer should submit wastewater calculation reflecting the ultimate development of the site so that the City can make a determination as to whether or not downstre, facilities can adequately handle the additional flow. e) Storm water drainage? x See discussion under 4.a above. f) Solid waste disposal? x See discussion under 8.b. 24 Al. 3 Issues and Supporting Information Sources Sources Potentially Potentially Lees Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated g) Local or regional water supplies? 1,5 X X Development of the project site is subject to Water Allocation Regulations and Water Impact Fees. Based on past water consumption patterns, and assuming retrofit of all plumbing facilities in the City and an ongoing water conservation program, the Urban Water Management Plan estimates that roughly 33 acre feet of water (available from retrofitting existing plumbing facilities throughout the City to save twice the water allocation required for proposed development) can be applied to annexation areas outside the 1994 city limits but inside the urban reserve, without reducing water available - also from retrofitting-to the anticipated build out potential within the 1994 city limits boundary. For projects in annexation areas, including the Froom Annexation, this retrofit credit will be made available on a first come first serve basis at the time of building permit issuance. In some cases the necessary amount of retrofitting may be offset by use of well water, providing well water use is approved consistent with the Urban Water Management Plan. . City water use factors estimate water usage for a warehouse store at .056 acre foot/1000 square feet. If the proposed 700,000 square feet of development on this site is composed of nothing but warehouses, the resulting water demand would be 39.2 acre feet per year. If well water is approved for landscaping and if landscaping requires 20% of total water demand, that figure would be reduced to 31.26 acre feet. Other uses allowed in the Commercial Retail zone, such as restaurants and retail sales of groceries have much higher water demands than warehouse stores. This project will be competing with two other known annexation areas to date -the TK Annexation and Goldenrod -for available water credits. Anticipated demand for water necessary to accommodate 100,000 square feet of neighborhood shopping center uses and 100,000 square feet of service-commercial uses conceptually proposed for the TK Annexation Area, could ultimately require the entire 33 acre feet. Forty-seven single-family homes are proposed for the Goldenrod Annexation. This would require roughly 14 acre feet. Policy 1.13.4 in the Land Use Element explains that actual development of annexed areas may be approved if any combination of City water, retrofitting, or interim well water is available. Private well water may be used, but only as an interim source and only where it is demonstrated that the use of well water will not diminish the City's municipal ground water supply. The Urban Water Management Plan (pp 25-32) stipulates that the City will be the only purveyor of water and that a well can only serve the lot on which it is located. Use of well water is subject to Council approval. A qualified independent hydrological investigation must demonstrate that the wells can reliably provide a sufficient quantity and quality of water for the proposed development without impacting the yields from City wells. The Utilities Department generally does not support the use of private wells that result in a project not acquiring a water allocation, when water allocations are available through the retrofitting program. Water is a limited resource and whether or not sufficient allocations will be available for development of this site is largely dependent on the course of development in other annexation areas. 25 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impeet Issues Unless Impact Mitigation Incorporated Mitigation: Well location and use shall be approved by the County Health Department, the City Utilities Department, City Council, and any other agency with authority relating to the use of well water. Discharge of wastewater from any well water treatment process is also subject to approval by the City and may require a permit to discharge and on-site pretreatment. If well water is approved for use on any of the parcels, a determination will be made by the Utilities Department on what the appropriate wastewater charge will be. Typically, wastewater charges are based on water consumption. In the absence of a City water meter, City staff will estimate the usage. This estimate may be based on fixture units, usage by similar properties, installation of a meter on the well, installation of a meter on the wastewater discharge lateral, or some other means. Any cost associated with the determination of wastewater flows will be the responsibility of the developer. Workscope Issue: In order for the Council to consider approval of a project that includes the use of private wells in lieu of acquiring a we allocation,the developer must submit a report with the findings of a qualified, independent, hydrological investigation t demonstrates the well(s)can reliably provide sufficient quality and quantity of water for the proposed project and will not impact the yields from City wells (Adopted Urban Water Management Plan, Policy 2.9.1 B). The findings in the report will be reviewed by the Utilities Department in a recommendation to Council. 13. AESTHETICS. Would the proposal: a) Affect a scenic vista or scenic highway? 1 X On the Scenic Roadways Map in Appendix B of the Circulation Element, the segment of Los Osos Valley Road between Madonna Road and Highway 101, on which the project fronts, is designated as one of moderate scenic value. From this segment are views of Cerro San Luis, the Santa Lucia Foothills, and the Irish Hills. This project will not impact views of Cerro San Luis or the Santa Lucia Foothills. However, it could extensively block views of the Irish Hills. Workscope Issue Area: An independent visual analysis of the project should be prepared. The analysis should identify potential impacts on views of the Irish Hills and recommend mitigation. b) Have a demonstrable negative aesthetic effect? X See discussion under 13.a above. c) Create light or glare? X Architectural review of the project lighting will address this aspect of design to ensure against glare. 26 y 36 Issues and Supporting Information Sources sources Potentially Potentially Lose Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 14. CULTURAL RESOURCES. Would the proposal: a) Disturb paleontological resources? X Workscope Issue Area: The disposition of fossils on this site is unknown. This could be addressed as part of the engineering geology report recommended under Section 3. b) Disturb archaeological resources? 8 X A phase one archaeological surface survey of 60 acres of the project site was conducted by Robert Gibson in October, 1993. Neither the records search nor the visual survey indicated the presence of prehistoric cultural material in areas that would be disturbed as a result of the project. c) Affect historical resources? 8 X The archaeological survey referred to above notes that the old Froom ranch complex (ranch house and outbuildings) may be historically significant, but that additional study would be required to make that determination. The ranch is representative of the early dairy farms in the area (circa 1870). The ranch has been purposely excluded from the annexation boundary. Because it would be outside that boundary and since no site work is proposed in this area, the project is not likely to have any significant adverse effect on the ranch buildings. d) Have the potential to cause a physical change which X would affect unique ethnic cultural values? e) Restrict existing religious or sacred uses within the X potential impact area? 15. RECREATION. Would the proposal: a) Increase the demand for neighborhood or regional parks or X other recreational facilities? b) Affect existing recreational opportunities? X 27 �f-37 16. MANDATORY FINDINGS OF SIGNIFICANCE. a) Does the project have the potential to degrade the quality of X the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to 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? The project has the potential to degrade the quality of the environment by increasing traffic in the vicinity with related adverse impacts on air quality and noise; by erecting buildings that would block views of the Irish Hills; by removing agricultural land from production; by adding fill to a wetland area and possibly diminishing the sustainability of the wetland and its habitat value; by increasing storm water runoff with possible flooding impacts on roadways and developed properties in the vicinity; and by developing the project site beyond the City's capability of supplying adequate water service. b) Does the project have the potential to achieve short-term, to X the disadvantage of long-term, environmental goals? Short- and long-term environmental goals are the same. c) Does the project have impacts that are individually limited, X but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of the past projects, the effects of other current projects, and the effects of probable future projects) With the exception of an increase in traffic-related noise, which is a localized impact, all other potential impacts listed under 16.a above are cumulatively considerable. d) Does the project have environmental effects which will X cause substantial adverse effects on human beings, either directly or indirectly? In their evaluation of the traffic study, Public Works Department staff note that pedestrian access at the Los Osos Valley and Garcia Drive intersection, as proposed, would be hazardous. 28 3F 18. SOURCE REFERENCES 1 San Luis Obispo City General Plan: Land Use, Circulation, Noise, Energy, Open Space, Seismic Safety Elements 2 Environmental Impact Report for the Land Use and Circulation Elements, prepared by Fugro- McClelland(West) in January, 1993 3 Draft EIR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Amendment (County file Nos: G851030:2; ED 86-67) 4 U.S.D.A. Soil Conservation Service maps 5 Urban Water Management Plan 6 Botanical Survey prepared by V. L. Holland for 50 acres of the project site, July 30, 1994 7 Traffic Impact Analysis for the Froom Ranch prepared by Penfield &Smith, November 1995 8 Archaeological Surface Survey of 60 acres of the project site prepared by Robert Gibson in October 1993 9 CEQA Air Quality Handbook, prepared by the San Luis Obispo Air Pollution Control District, August 1995 19. RECOMMENDED MITIGATION Ooen Space " The project shall include a dedication of open space at least equal to the area to be annexed. Agricultural Land To avoid conflicts with ongoing farming and grazing operations in the vicinity, consistent with Open Space Element(Chapter II. Section 1. 2),the project shall include an agricultural buffer, providing a barrier of vegetation capable of eliminating potentially adverse impacts associated with agriculture on adjacent parcels. At the time of sale or lease, the applicant should disclose to prospective buyers and tenants the consequences of existing and potential intensive agricultural operations on nearby parcels including but not limited to dust, noise, odors, agricultural chemicals, and the County's Right to Farm Ordinance. A copy of such disclosure should be submitted to the County Agricultural Commissioner and the City Community Development Director for review, approval, and recordation prior to any further subdivision or site development. The project shall be modified to include one or more of the following methods, or an equally effective method, for protecting prime agricultural land within the urban reserve or greenbelt: acting as a receiver.site for transfer of development credit from prime agricultural land of equal quantity; securing for the City or for a suitable land conservation organization open space easements or fee ownership with deed restrictions; helping to directly fund the acquisition of fee ownership or open space easements by the City or a suitable land conservation organization. Air Quality Phase one improvements shall include transit turnouts, with shelters on Los Osos Valley Road, to the satisfaction of the Transit Manager, as well as sidewalk installation, street tree planting, and bike lane striping to the satisfaction of the City Engineer. Grading and construction of site improvements shall include the following dust suppression measures: 29 �1%3 � Consistent with grading standards in the Uniform Building'Code appendix(Chapter 70, Section 7004 b), all graded surfaces shall be wetted, protected or contained in such a manner as to prevent dust or spill upon any adjoining property or street. The following measures shall constitute the project's dust management plan and shall remain in effect during all phases of the project's construction: a. Regular wetting of roads and graded areas (at least twice daily with complete coverage of all active.areas); b. Increasing frequency of watering whenever winds exceed 15 mph; c. Cessation of grading activities during periods of winds over 25 mph; d. Direct application of water on material being excavated and/or transported onsite or off site; e. Watering material stockpiles; f. Wheel washers shall be installed where vehicles enter and exit unpaved surfaces onto the surrounding streets; and g. Daily wash downs, or mechanical street sweeping, of Los Osos Valley Road in the vicinity of the construction site. h. Use of non-potable water is required in all construction and dust control work. All PM,, mitigation measures required shall be shown on grading and building plans. The contractor shall designate a person or persons to monitor the dust control program consistent with APCD guidelines and shall provide the contact name(s)and telephone number(s)to the Community Development Department prior to permit issuance. Future site development shall include measures to minimize negative impacts to air quality,-such as: a. Extensive tree planting in the parking areas to reduce evaporative emissions from automobiles. b. A carpool/rideshare/public-transit information bulletin board installed in a visually prominent and easily accessible location. c. Weatherproof and lockable bicycle storage, as well as short-term bicycle parking racks. d. Bicycle parking and shower and locker facilities for employee use. e: Shared-use parking reduction. f. Designated employee carpool parking. g. On-site food facilities to encourage employees to stay on site during the lunch hour. Transportation/Circulation The Developer shall provide for dedication of needed right of way (R/W) to accommodate the ultimate width of 108 ft. for Los Osos Valley Road (LOVR), between Madonna Rd. and US 101, as depicted on the development plans. This will require dedication on both sides of LOVR, including portions not owned by the Developer. The City Council may consider lending its power of condemnation, if offsite acquisition is not able to be negotiated successfully, and upon execution of an agreement between the. City and. Developer, wherein the Developer agrees to pay all applicable costs to acquire such offsite R/W, as determined by the City. The Developer shall provide paving of Los Osos Valley Rd., between Madonna Rd. and US 101 to accommodate 4 lanes of traffic, 6 ft. bike lanes, necessary tum lanes, including signing and striping (thermoplastic), asphalt berms and concrete curb and gutters (adjacent to Phases 1 and 2) and such median improvements determined to be necessary to control traffic movements and drainage, to the satisfaction of the City Engineer, County 30 Al-LIC Engineer and CalTrans. Six (6) ft.-wide detached sidewalk shall be installed along the frontage of Phases 1 and 2, as part of Phase 1. Graded sidewalk/parkway areas(4 ft. wide minimum behind the curb line) shall be provided for the remainder of the frontages, pending development of those properties. Offsite easements and all-weather surface access roads will be required, to the satisfaction of the City Engineer and Utilities Engineer. Street lighting shall be installed that meets City standards along the LOVR corridor. Energy Resources Future construction projects shall include a solid waste recycling plan for recycling discarded materials, such as concrete,sheetrock, wood, and metals, from the construction site. The plan must be submitted for approval by the Community Development Director, prior to building permit issuance. Future site development should incorporate: Skylights to maximize natural daylighting. • Operable windows to maximize natural ventilation. - • Energy-efficient lighting systems for both interior and exterior use. • Facilities for interior and exterior on-site recycling. Utility and Service Systems All new and existing overhead wire utilities shall be undergrounded along the project frontage, to the satisfaction of the respective utility companies and City Engineer. Overhead wire utilities adjacent to "offsite" frontages may be relocated utilizing overhead facilities, to the satisfaction of the City Engineer and utility companies. To allow Southern California Gas Company time to locate and mark existing gas lines that will be affected by the project, the following note shall be placed on plans submitted for a building or grading permit application: For location and marking of Southern California Gas Company facilities, call Underground Service Alert (USA) toll free at 1-800-642-2444 a minimum of 48 hours, but preferably 10 days, prior to the start of construction. Sanitary sewer and water mains shall be installed to City standards and specifications. Main line alignment, sizes and grades are subject to modifications to the satisfaction of the City Engineer and Utilities Engineer. Any oversizing of public mains required by the City to serve tributary areas outside the Developer's ownership and/or greater than required for providing for development minimum fire flows will qualify for reimbursement by the City, in accordance with City regulations. Attachments: Reductions of project plans 31 20. MR WORKSCOPE Based on the completed initial study environmental checklist form, staff has found that there may be significant environmental impacts associated with project development and has determined that an environmental impact report (EIR) is required. The following workscope specifically identifies issues and tasks that need to be performed to evaluate potential impacts of the project. Geoloaic Problems An independent geologic and soils investigation should address the following: 1. Likelihood of a fault zone at the base of the Irish Hills. 2. Risk of liquefaction. 3. Location of mudslides, areas of fill, springs, and nearest landslides. 4. Viability of the proposed sedimentation basins with recommendations for the construction, capacity, and maintenance of such basins. 5. Constraints posed by the character of on-site soils and necessary earthwork and foundation:design for the site development proposed. Exnected Work Products Engineering Geology Report Engineering Soils Report Available Information City Construction Codes incorporating grading regulations City Seismic Safety Element (July 1975) Letter from Earth Systems Consultants dated October 10, 1995 Draft MR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Amendment, pp. V-2 through V-9 PG&E studies of local faulting, 19881 Drainaae and Water Suooly A drainage and hydrology study, prepared by an independent engineer, which reasonably assesses the likely impacts of development on the drainage system in the vicinity and feasible methods of mitigating such impacts, should be submitted to the satisfaction of the City, County, and Cal Trans. The study should analyze ground water depth, availability and quality; estimate storm water runoff as a result of impervious surfacing; identify the capacity of drainage facilities near Highway 101 to convey existing storm water and estimated runoff from this project, identify necessary improvements and associated costs of improvements to avoid flooding those facilities; quantify runoff from the hills behind the area proposed for development; specifically evaluate the likely effectiveness of proposed detention basin(s) in the wetlands area; and identify feasible methods for collection and management of sedimentation likely to occur in conjunction with upslope runoff. The study should adequately answer all issues raised in Section 4 of the City's environmental checklist, including potential reliability of on-site wells and likely impacts of well-water use on available groundwater. 32 1� 4�z As part of the drainage study evaluation recommended above under Section 4.a, a hydraulic analysis of Froom Creek should be performed with recommendations for levee design. Installation of a levee should then be analyzed to determine how much wetland area will be lost as a result of the fill necessary to create the levee, and how the diversion of water might reduce the sustainability of the remaining wetlands. A restoration plan should be formulated in the event the levee washes out and deposits sedimentation in the wetlands. The potential for downstream property damage should be assessed. The likely effectiveness and impacts of detention basins in*the wetlands area should also be evaluated. One-hundred-year flood elevation contours must be established so that finish floor elevations can be determined. Using the information in the drainage and hydrology study, a drainage master plan must be formulated to the approval of the City, County, and Cal Trans. The plan should show how the total property is to be developed, including Froom Creek and the area between the proposed development and Highway 101. The drainage system shall be designed to mitigate any adverse.impacts that may be caused by development of the project site, and run off shall be adequately conveyed to an appropriate point of disposal in San Luis Creek to the satisfaction of the City Engineer. This may require detention basins lon- or off-site, and above or below ground), culvert enlargements, etc. Costs of necessary improvements should be estimated so that the project can be assessed an appropriate share of costs and fiscal impacts on the City, if any, can be evaluated consistent with Land Use Element Policies 1.13.2 and 1.13.3, both of which require an analysis of needed capital facilities and their financing. Expected Work Products Drainage and Hydrology Study addressing the issues outlined above and outlining alternatives to the drainage plan proposed with the project Drainage Master Plan for the project as described above Restoration Plan for the wetland area, in the event a levee is approved and fails Flood damage calculation in the event a levee is approved and fails Fllod Insurance Rate Map information and an application for map amendment Available Information City of San Luis Obispo Flood Management Policy (June 1983) City of San Luis Obispo Damage Prevention Regulations (Municipal Code Chpt. 17.84) San Luis Obispo Flood Insurance Rate Map (7-7-81) Draft EIR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Froom Ranch Drainage Report prepared by Central Coast Engineering, October 1995 Transportation/Circulation An independent consultant should review the traffic analysis, provide additional evaluation as required by the City, and develop clear statements of impact and specific mitigation. The review should include an Executive Summary that identifies all assumptions, impacts, and recommendations, and addresses all area of concern listed in the initial study (sections 6 and 11) to the satisfaction of the City, Cal Trans, and the County. The applicant should provide the City with a disk copy of the computer analysis so the information can be independently assessed. Without access to this data the modeling assumptions and analysis techniques cannot be easily evaluated. Exoected Work Product Report evaluating the traffic analysis submitted with the application, addressing issues specified above, and including recommendations for project mitigation with a cost estimate for all recommended infrastructural improvements. 33 4�3 The traffic report should: ❑ Clearly define existing traffic conditions based on field observations and traffic data collection for Los Osos Valley Road, affected intersections and the Route 101-Los Osos Valley Road interchange. In completing this task, the traffic consultant should work with Caltrans and the City traffic engineer to establish an acceptable methodology for defining existing conditions. The consultant'should prepare a 'technical memorandum' that defines these conditions and submit it to the City and Ca/trans for approval before proceeding with the rest of the evaluation. ❑ Identify changes to the area's circulation system that are needed to mitigate existing substandard conditions. /n determining substandard conditions, level of service (LOS) standards specified by the City's Circulation Element should be used as a guide. ❑ Identify the impacts of the proposed project on the area's circulation system and define those parts of the system that will be operating at substandard levels after the project is constructed. The environmental review of this project shall consider the impacts of construction the first phase of commercial development and full build out of the annexation area consistent with the City's General Plan Land Use Element. The report must clearly identify all road segments, intersections and components of the Route 101 interchange where leve/of service will degrade to substandard levels. - ❑ Identify specific mitigation measures needed as part of constructing the first phase of the project's development to maintain level of service standards. Identify the scope of any further studies needed to clearly define what these measures need to be. The impact analysis should indicate the level of improvements to Los Osos Valley Road needed upon opening of the proposed Phase / shopping center, changes need to existing or proposed intersections and modifications to the Route 101-LOVR interchange and bridge. /t is anticipated that the preparation of a Project Study Report will be necessary to establish the preliminary design of changes to the Route 101 interchange. ❑ Recommend an equitable mitigation and financing plan that ensures the timely installation of circulation improvements that will avoid the creation of substandard traffic conditions. The mitigation plan needs to specifically address the timing and financing of circulation changes, the responsibility for implementing these changes, and how the installation of circulation improvements relates to the phased implementation of the project. Available Information Circulation Element (November 1994) Bicycle and Transportation Plan (October 1993) City and County Engineering traffic counts ITE Trip Generation Standards Forecasted traffic models (MINUTP) Traffic Impact Analysis for the Froom Ranch, prepared for Central Coast Engineering, by Stephen Orosz, Penfield & Smith, November 1995 Comments submitted by Caltrans, County Engineering, and Public Works staff 34 Bioloaical Resources A biological study should identify potential impacts on the burrowing owl and other species as a result of proposed modifications to the banks of Froom Creek and changes to the existing drainage pattern. The report should include recommended mitigation measures where impacts may be significant. An additional botanical survey should be done in the Spring to better determine the full range of plant species that inhabit the site. That survey should include the entire project area and the adjacent wetland since modifications to the wetland area are proposed as part of the drainage plan. Any additional potential impacts identified as a result of the second survey should be documented together with recommended mitigation. Exnected Work Products Biological Study analyzing issues outlined above. Botanical Study amendment, completing the analysis of botanical resources begun by V.L. Holland in his report submitted with the application. Available Information Botanical Survey prepared by V. L. Holland for 50 acres of the project site, July 30, 1994 Draft EIR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Noise The proposed site planning and design of the road widening and center median should be reviewed by an independent acoustical engineer to determine appropriate noise attenuation measures, which may include buffer areas, earthen berms, sound walls, or a combination thereof as necessary to lessen impacts on nearby residential areas. Exnected Work Product Noise Analysis of project construction and operation Available Information Noise Element (September 1975) Environmental Impact Report for the Land Use and Circulation Elements, prepared by Fugro-McClelland(West) in January, 1993 Utility and Service Systems Wastewater calculations reflecting the ultimate development of the site must be established so that the City can make a determination as to whether or not downstream facilities can adequately handle the additional flow. Available Information Project comments received from the Utilities Department dated December 18, 1995. Exnected Work Product Wastewater generation estimates based on development of the entire annexation site. Determination of whether the City's wastewater treatment facilities have the capacity to handle the additional flow. Recommended 35 y-�S mitigation in the event facilities do not have sufficient capacity. Aesthetics An independent visual analysis of the project should be prepared. The analysis should identify potential impacts on views of the Irish Hills and recommend mitigation. Expected Work Product Visual exhibits for use in public hearings that depict a realistic interpretation of the project superimposed on the backdrop of the site consisting of on-scene photography and/or video, 3-dimensional computer-aided design (CAD), architectural models or other acceptable visual simulation techniques to the approval of the Community Development Director. Available Information Circulation Element (November 1994) 36 �z _-.......::;::::.:_ - :ii ==: � r I � E I i I I r� !°� n �y d[" iO =" g 6 2 z o e3 aoa c � f� �_ �' y y � ° o E� != c ® i es SeeO egsys`� � Cao C. or to c� 2 0 � sgfe � E = 2va �geSM E ? SEe � r � r i If ZeL V \f v t • Jl i _ ` � V r T •--r. F1 !09 0309 VAILlyaD' o` I y 2d 3 ' 802 baa P :IL o p >S o ga. 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BOX 8114 SAN LUIS OBISPO, CA 934038114 TELEPHONE: (805) 5493111 TDD (80S) 5493259 `" January 3, 1996 5-SLO-1 01-25.91 Froom Ranch Revised Traffic Study Ms. Whitney Mcllvaine City of San Luis Obispo Planning P.O. Box 8100 San Luis Obispo, CA 93403-8100 Dear Ms. Mcllvaine: Caltrans District 5 staff has reviewed the above-referenced document. The following comments were generated as a result of the review: a. (Reference Figure 4, Project Traffic Percentage Distribution) - As was pointed out in my letter of July, 28, 1995, District staff believes it is unreasonable to assume only 5% of the trips to this development will originate on Route 101 north of the Los Osos Valley Road Interchange. Directional split information should be substantiated with some empirical data such as a marketing study. b. For reasons having to do with safety and operations, Calle Joaquin should be realigned so that it connects well north of the Los Osos Valley Road (LOVR). Interchange. Additionally, because of its close proximity to the interchange, it is doubtful that the signalization of this intersection would ever be appropriate. C. Caltrans does not accept the use of the Planning Methodology for existing signalized intersections. d. (Reference Page 2) - Caltrans is not currently studying improvements to the LOVR Interchange. You should be aware that a meeting is being arranged to discuss funding a Project Study Report (PSR) to identify deficiencies,' alternative improvements, cost estimates and funding sources for this location. DMINCT 5-PROVIDING ouALrTY TRANSPORTATION ON THE CENTRAL COAST — y_�j Whitney Mcllvaine January 3, 1996 Page 2 d. District staff found the Technical Appendix to be inadequate for the following reasons: 1. Much of the data is not consistent with what is shown on the document: 2. The use of inconsistent cycle lengths. 3. Lack of provisions for pedestrian facilities. 4. Lack of adjustment for the saturation flow rate. 5. The input and output data for passer II calculations was not included. e. Caltrans supports the transit/bicycle and pedestrian facilities that are proposed for this development. However, given the fact that this development will generate in excess of 17,000 trips per day, it would be unreasonable to expect these measures to offer any appreciable degree of traffic mitigation. It appears that many of the issues brought up in our July, 28, 1995 letter have not been dealt with adequately. Please know that Caltrans staff is available to meet with the City and the consultant to discuss this project. We appreciate the opportunity to comment and encourage you to contact us with your questions at (805) 549-3683. Sincerely, Newland District 5 Intergovernmental Review Coordinator cc: Ron Di Carli, SLOCOG S Strait, D Heumann, A Delgado, C Sanchez, S Sandeman TL Rochte, L Gorman, SJ Chesebro SL0-101-25-91.TS DISTRICT 5-PROMDWG QUALITY TRANSPORTATION ON THE CENTRAL COAST / /� STATE OF CAUFORNL6,—BUSINESS,T/ SORTATION AND HOUSING AGENCY PETE WILSON, Govemoi DEPARTMENT OF TRANSPORTATION ' P.O. BOX 8114 SAN LUIS OBISPO, CA W403-8114 RECEIVED TELEPHONE: (WM 5493111 TDD (805) 5493259 AUG 7 1995 CITY OFSANLUISOBISPO oo�slNrrY oEtrELOPA1Elrr July 28, 1995 5-SLO-101-25.91 Froom Ranch Ms. Whitney Mcllvaine City of San Luis Obispo Planning P.O. Box 8100 San Luis Obispo, CA 93403-8100 Dear Ms Mcllvaine: want to thank you for inviting Caltrans to the planning and public works staff meeting on Thursday, July 28, to discuss the Froom Ranch development. The following comments are based on our analysis of the Froom Ranch documents and what was discussed during this meeting: a. The environmental document for this development should include a discussion of the timing of specific traffic mitigation measures as it relates to the phasing of the project. Caltrans would prefer that all traffic mitigation measures be in place prior to any opening of business. At a minimum, District 5 will condition our encroachment permits that each phase of this project must have its respective traffic mitigation measures in place prior to the issuance of an occupancy permit. We would expect the final conditions for this project to state this in a forthright manner. b. At the present time Caltrans does not have available design conceptions or studies that outline what the long range highway improvements should be in order to mitigate the buildout traffic in this .area of the City. It is the responsibility of the developer and or the City of San Luis Obispo, to conduct the necessary studies that will identify the short and long term improvements that will be needed. District staff recommends that a Project Study Report (PSR) be done to accomplish this. We believe you would find that much of the groundwork for such a study has been started with the ongoing Prado Road PSR. DISTRICT 5-PROVIDING QUALITY TRANSPORTATION ON THE CENTRAL COAST '`�/ J Whitney Mcllvaine July 28, 1995 Page 2 C. While the traffic study dated June 1995 was informative, it was by no means broad enough in scope to address all of Caltrans concerns. For example: 1. This study did not address mainline Route 101 impacts sufficiently. Because large discount retail stores (so called box stores) have significant interregional and intraregional draw, any future traffic analysis should include impacts to mainline Route 101 between Madonna and Los Osos Valley Road in addition to intersection analysis. 2. District staff would like to see a more project specific based .. discussion of pass-by trips as opposed to the generic discussion of a pass-by factor and estimates found in the ITE Manual. For details on addressing pass-by trips please refer to the recommendations made in the ITE Trip Generation, 5th Edition, Page 1-29. 3. (Reference figure #4, Project Traffic Percentage Distribution) District staff is of the opinion that some of these figures are underestimated. For example, it is highly unlikely that only 50/0 of the trips to this development will originate on Route 101 north of the Froom Ranch area. Caltrans staff would like any further directional split information substantiated with some empirical data, such as a marketing study. d. For safety and operational reasons, the southern portion of Calle Joaquin should be realigned well north of the Los Osos Valley Road/101 interchange. e. Future traffic analysis should include a section that is devoted to a discussion of assumptions. For example, does the analysis assume the Prado Road Interchange is built, auxiliary lanes, Dalidio expansion etc? f. Prior to the beginning of any traffic study, please have the consulting traffic engineer submit a formal scope of work for District review. DISTRICTS-PROVIDING QUALITY TRANSPORTATION ON THE CENTRAL COAST gym= IF Whitney Mcllvaine July 28, 1995 Page 3 g. As suggested in the meeting, there should be some early discussion of the project hydrology as it relates to State facilities. You should know that Caltrans has great concerns about the additional runoff that may occur as a result of this or any development in the Laguna Lake/Froom Ranch area. District Hydraulics staff had the following comments: 1. (Reference Note #1, Exhibit Sheet F7.21) - Please provide substantiation for this statement. 2. (Reference Exhibit F7.21) - it appears that the majority of the runoff. generated by this development will be dealt with using detention basins. Given what is known about the height and location of the water table in this area, we have doubts about the effectiveness of these basins. Please substantiate that there will be enough freeboard for detention basins to be functional. 3. Please be aware that Caltrans will not Issue an encroachment permit for this or any project that does not fully mitigate to the satisfaction of the District Hydraulics engineer, the flow caused by this or any development. Caltrans would expect the final environmental document or any conditions of approval for this project, to specify in clear language the drainage mitigation measures that shall be in place prior to any occupancy permit issuance. If it would be helpful, District Hydraulics staff is willing to meet with City engineering and planning staff to discuss the greater Perfumo/Froom Creek drainage basin as it relates to this and all futuredevelopments in this area. hope this letter gives you a better understanding of Caltrans concerns with a development of this sort. If you have questions or wish to arrange further meetings please contact me at (805) 549-3683. Thank you for the opportunity to comment. Z ly, ewland District 5 Intergovernmental Review Coordinator DISTRNCT 5-PROVIDING QUALITY TRANSPORTATION ON THE CENTRAL COAST G3 SRO LUIS OBISPO COURT9 DEPARTMENT COUNTY GOVERNMENT CENTER • ROOM 207 • SAN LUIS OBISPO,CALIFORNIA 93408 TIMOTHY P.HANSON PHONE(805) 781-5252 FAX(805) 781-1229 COUNTY ENOINEER GLEN L PRIDDY DEPUTY COYNR ENOINNIR DUNK1I2UNI SERVICES NOEL KING ROADS DEPUTY CCUNTT ENGINEER ADMINISTRATION SOLID WASTE FRANCHISE ADMINISTRATION WATER RESOURCES COUNTY SURVEYOR January 22, 1996 SPECIAL DISTRICTS Whitney Mclivaine City of San Luis Obispo Community Development Department P.O. Box 8100 San Luis Obispo, CA 93403-8100 Subject: Froom Ranch Traffic Impact Analysis, December 1995 Dear Ms. Mcllvaine: Thank you for the opportunity to review the revised traffic study dated December, 1995. It is clear that many of the concerns raised by me, and by other reviewers, have been addressed and clarified in the revised report. However, there are still two major concerns with its conclusions, as follows: 1. Roadway Level of Service (LOS). The report states on page 4 that current traffic represents LOS C on the two-lane section, except that the overcrossing is LOS D; these are acceptable levels. However, on page 25, the report incorrectly identifies the widening of Los Osos Valley Road as needed to mitigate existing poor operating conditions. The next step should be to evaluate existing-plus-project traffic on the existing roadway configuration. Table 1 shows the amount of traffic, but nowhere is this volume evaluated on the existing roads. Nevertheless, I am sure that a volume of 25,700 daily trips on a two-lane road will be an unacceptable LOS. Conclusion: This is a project impact,and the recommended mitigation should be a condition of the proposed project. 2. Intersection LOS. Page 6 of the report identifies LOS C for the intersections at Auto Park Way and at Calle Joaquin with current traffic;these are acceptable levels. Again, the report incorrectly identifies the installation of traffic signals at these intersections as mitigation of existing poor operating conditions. Page 6 does evaluate existing-plus-project traffic at these locations, reporting LOS F in both cases. Conclusion: This is a project impact,and the recommended mitigation measures should be conditions of the project. (Note: It should be clarified that although these intersections meet signal warrants with current traffic volumes, the County does not accept this as a way to determine significance of traffic impacts on County maintained facilities, which includes this portion of Los Osos Valley Road.) 4�' These are the fundamental flaws in the conclusions, from the County's point of view. I imagine the City and Caltrans have additional concerns regarding impacts to their facilities; I have not considered these in my review. Please call me at 781-5280 if you have any questions or need additional information. Sincerely, RICHARD MARSHALL Development Services Engineer File: Planned Developments- Froom Ranch m:\luann\rem\mcilvaine.ltr y-6s' H 0 LUIS 0BISPO co U Rig DEPARTMENT COUNTY GOVERNMENT CENTER • ROOM 207 • SAN LUIS OBISPO, CALIFORNIA 93408 TIMOTHY P.HANSON PHONE(805) 781-5252 FAX (805) 781-1229 COUNrn ENGUGER GLEN L PRIDDY DDNR COUNT'INGINIIR INGINnRING SE MCIS NOEL KING DOM COUNTY INGOQ@ o ROAD: ADMONSIRATION SOLID WASTI RECEIVED FRANCHISE ADMINISTRATIOF June 28, 1995 WATER RESOURCEI JUL J 1995 COUNTY SURVEYO; SPECIAL DISTRImI CITY OF Whitney Mcllvaine NmnFvELoa'� City of San Luis Obispo Planning Department PO Box 8100 San Luis Obispo CA 93403-8100 Subject: Froom Ranch Traffic Analysis , Dear Ms. Mcllvaine: Thank you for the opportunity to review the subject report. I have the following comments: 1. On.Page 8, there is an incomplete reference to a possible future connection toward Madonna Plaza. The description of this connection and its location on Los Osos Valley Road need to be completed. 2. On Page 9, mitigation measure E-1 recommends widening Los Osos Valley Road to four lanes between Madonna Road and Auto Park Way. However, the Circulation Plan included in the "Pre-Zoning and Annexation Exhibits" does not show four lanes between Madonna Road and Garcia Drive. The improvement of this segment will be critical to the flow of traffic in the project vicinity, and must be considered a necessary mitigation of the impacts of the Froom Ranch development. 3. Also on Page 9, improvements to the Auto Park, Calle Joaquin and southbound 101 ramp intersections are listed as mitigation measures for "existing conditions." However, this report's own analysis, summarized in Table 2, shows that none of these locations are currently at an unacceptable level of service. These should be moved to the "Existing Plus Project" category. 4. Also on Page 9, recommended Mitigation Measure B-1 is to signalize the Garcia intersection. This seems to be contrary to the discussion on Page 8 about the spacing of signalized intersections. This should be clarified. �-G G 5. On the Circulation Plan, I would suggest adding the "B" designation at the Auto Park and Calle Joaquin intersections. Also,the definition of designation "C" is "righttleft turn intersection." This is contrary to the text which recommends eliminating left turns at these locations. In general, I am satisfied with the analysis method used and the conclusions reached. If there are any questions, please call me at 781-4463. Sincerely, RICHARD MARSHALL Transportation Planning Engineer File: Traffic Studies General m\leanne\rem\mcilvaine.ltr January 22, 1996 TO: Whitney McIlvaine, Associate Planner VIA: Jerry Kenny, Supervising Civil Engineer FROM: John Rawles, Traffic Engineer, Terry Sanville, Principal Transportation Planner LJ:r7 SUBJECT: Critique of the Traffic Impact Study for The Froom Ranch (December, 1995) 1. (Existing Conditions; page iii) In the second paragraph the report states that all of the intersections operate at an LOS C during the PM peak hour and that this is-one level lower than the overall corridor LOS. This is in conflict with the earlier statement that the segment across US 101 is operating with an LOS of D. Also previous discussions with regard to the LOS over the freeway indicated that due to a PM peak hour travel speed of approximately 40MPH over the bridge the methods for determining the LOS needed to be adjusted to reflect a clear- understanding of traffic at this location. 2. (Future Planned Improvements; page iii, last paragraph; page vi, paragraph, E-3 & E-4) The report indicates that the widening of Los Osos Valley Road is accounted for by the City's traffic impact fee program. It is not! Adjoining development (The Froom Ranch Project) has the responsibility to widen the roadway and provide frontage. improvements consistent with the Circulation Element. 3. (Project Description; page iv, paragraph 2) Unless the applicant is prepared to provide intra- shopping area shuttle service, it should not be included in this section which is entitled "Project Description." Adopted City transportation plans do not suggest inter-area shuttles at this time. A similar comment applies to the discussion of park-and-ride lots. The applicant needs to decide whether these two features are part of the project description and not just potential solutions — then the traffic study should critique their effect on project traffic impacts.. 4. (Project Description; page iv, paragraph 3) The report states that the provision for pedestrian facilities is consistent with the intent of the City's Circulation Element. The Circulation Element includes the following pertinent policies: 4.2 The City should complete a continuous [emphasis added] network of sidewalks and separated pedestrian paths connecting housing areas with major activity centers [emphasis added] .... 4.3 New development shall provide sidewalks and pedestrian paths consistent with t,,Ly policies, plans, programs and standards. To be consistent with these policies, the Froom Ranch project must provide sidewalks that link with surrounding residential areas. Providing sidewalks only along the project's LOVR frontage does not satisfy this requirement and is not consistent with the intent of the Circulation Element. Sidewalks must connect surrounding housing areas with the proposed shopping center which will involve off-site improvements along LOVR north and west of the project site. 5. • (Project related Ti-affic; page iv, last sentence) The report should identify at this point the three intersections that will be adversely impacted by the project. 6. (10 Year Traffic Conditions; page v) What is the first paragraph saying? 7. (Paridng Shortages; pave v) Is the 900 space identified shortage based on non-compliance with City parking requirements? Also, what is the report referencing when it refers to shortages at "peak times?" Is this during the Christmas shopping season? weekends? What is the frequency of the impact and how might parking shortages effect traffic flow on LOVR? Is increasing parking the only solution to this issue? What about travel demand management, inter-area shuttles, reductions in employee parking demand, etc.? These types of measures will also be needed to address the project's potential air quality impacts that will be assessed as part of the City's environmental review process.. 8. (Mitigation Measures; page v). At the top of page vi the report states that "the following measures are needed to mitigate existing poor operating conditions..." then goes on to list required improvements to the Auto Park Way & Calle Joaquin intersections and the widening of LOVR. However, the reports discussion of existing conditions (page iii) indicates that all links are operating at LOS C or better (except the Route 101 bridge which operates at LOS D). This report section concludes with "Therefore, the corridor as a whole operates within acceptable levels of service." Why then are the intersection improvements and road widening mentioned above listed as required improvements for poor existing conditions? If LOS is the criteria that the report uses to used to determine the need for improvements, signal warrant studies done by the County are subservient to this criteria. The report identifies the Auto Parkway and Calle Joaquin intersections as meeting traffic signal warrants and uses this to conclude that signals are needed for existing conditions. This is not true. Many intersections that meet traffic signal warrants may never be signalized. Traffic signal warrants are a set of indicators that are used to determine the current conditions. For example, if an intersection is operating without meeting the warrant for accidents, it may never be signalized. The fact that an intersection meets warrants does not indicate that the intersection is operating poorly. Again, this edition of the report fails to clearly identify: 0 Improvements (if any) that are needed to mitigate existing substandard conditions. ❑ Improvements needed to mitigate substandard conditions that are the result of proja traffic impacts. ❑ Improvements needed to mitigate substandard conditions associated with full buildout of the Froom Ranch property (since part of the "project" is the annexation of greater territory than the first phase of retail commercial development). ❑ Improvements along the corridor associated with other area development or overall built of the City. ❑ Existing Conditions A table should be presented in the summary that clearly identifies the improvements, who's responsible for installing them, and the traffic problem that they mitigate. 9. (Project Specific Conditions; page vi) If the Route 101 bridge is operating at LOS D under current conditions, is it the reports conclusion that the addition of a major shopping center will not degrade LOS on the bridge? The report needs to clearly determine the post-project LOS conditions on the Route 101 bridge. If LOS exceeds standards, then the widening of the bridge needs to occur as a condition of the shopping center's development and not wait years until TIF fees or other revenues can be accumulated. The City would establish a reimbursement program. Local and regional travelers should not be subject to these substandard conditions awaiting improvements. Also, if LOUR is operating at LOS C, what is the resultant LOS 'after the project is comple given the level of road improvements shown on the project plans? Will any of the road segments exceed LOS D? More specifically: ❑ What will be the resultant LOS (existing + project) for the segment of LOVR between Madonna Road and Garcia Way. Since the project does not propose to add travel lanes to this segment, it should be evaluated as a two-lane road. ❑ What will be the resultant LOS (existing + project) for the segment of LOVR between Garcia Way to the southern edge of the project site? Will the single westbound through traffic lane be sufficient to handle traffic since two tum lanes into the project are proposed? ❑ What will be the resultant LOS (exiting +project) for 2-lane segments of LOVR southeast of the project site. ❑ The report proposes that the intersections at the project's northerly and southerly access points be closed to left tum traffic. What effects will closure have on the residential areas and the schools north of LOUR? Will the Madonna/Periera intersection become overloaded? What effect will closure have on the signalized intersection at the middle access? Will closure degrade corridor progression? The traffic report does not provide a clear picture of when traffic conditions war improvements, the timing of the improvements, the responsibilities for providing them, and ...a �1D shared responsibility for funding them. It seems clear that installing traffic signals at the major project entrance, Auto Park Way and Calle Joaquin, and widening the Route 101 bridge can all be justified as mitigation measures for project-related traffic impacts. The extent of widening LOVR to four lanes to avoid substandard LOS associated with project impacts is unclear since the report does not present this information. A third-party analysis is needed to sort this issue out. 10. (LOVR Comdor Improvements; page vi) Table 2 on Page 6 indicates that the LOS of three intersections along LOVR degrade from LOS C to LOS F after the shopping center is built. Why doesn't the report identify improvements to these intersections as "project specific improvements" and why are they assigned to the "10-year plus project" condition? While the applicant may receive TIF credits for off-site signal installations (not including the new signal at the project entrance), the applicant should be responsible for installing improvements as a condition of shopping center development with reimbursement provisions and/or TIF credits provided by the City. 11. (Existing Conditions; page 1) The posted speed is 35UTH south of Calle Joaquin 12. (Table 1; pane 3) This table should be expanded to also identifyy changes in link LOS for each link and include the existins + project benchmark. The way the table is currently drafted, existing + project is not shown and the next benchmark (10-year base + project) assumes-that LOVR will . be widened to four lanes. The project impacts on LOS for existing plus project has not been included . Also, the table lumps the LOS for the Route 101 bridge under the current LOS "B" condition for the entire corridor. If we know that the bridge is currently operating at LOS D, then it is likely that it will degrade to LOS E or F with project impacts, thereby necessitating project mitigation. 13. (Future Planned Improvements; page 4) The funding source for widening LOVR from 2 to 4 lanes is not the traffic impact fee program. It is not one of the listed projects for which TIF funds can be used. The Circulation Element states that "development" has primary responsibility for funding this widening project -- over and above any impact fees that are paid. 14. (Traffic Signal Warrants, pace 7) The statement that traffic signals have been delayed due to funding constraints is not accurate and should be deleted. The report states that signalization of the Garcia intersection would improve operation and safety. Why doesn't the report recommend signalization? 15. (Build Out Analysis; page 18) Why are improvements to the Route 101 bridge tied to "buildout" conditions when project impacts could course substandard LOS conditions? Traffic signals are assumed to' be installed at all major intersections. Does this include Garcia? The southerly entrance? 16. (Access Point Analysis; page 22) The analysis seems to recommend a traffic signal at Garcia, and then goes on to recommend restricted left-turn access. Which left turns are to be restricted? 4-771 17. (Project Traffic Distribution; page 23) The 885 inbound peak hour trips was reduced to 665 tr,, with the pass-by analysis however, the original 885 trips should be used when determining conflicts due to project traffic. This is to say that of the original 885 trips 665 were new to the roadway, but there will still be 885 trips onto the project site. This should be accounted for since it tends to degrade the overall LOS of the project intersections and the efficiency of the corridor. 18. (LOUR-Project Only Improvements; page 27) Provision for new roadway access to a road as yet to be constructed is proposed to link the Oceanaire area neighborhoods with LOVR should left tum access is denied at Garcia. The link to the Oceanaire neighborhood may never be accomplished. How will this affect traffic and circulation if left tum access is denied? 19. Technical Analysis- The technical methods used for this report have been modified by previous agreement between staff and the consultant. This agreement was based on the consultant's recommendation that the planning method of analysis provided a more reliable tool for trend forecasting than the operations methodology. It was staffs understanding that the LOS for existing conditions would be studied, that the planning analysis would be calibrated to fit with the findings for the existing conditions, and that the calibrated planning model would be used to produce future conditions. In fact what has been done is that the existing traffic volumes have been used with the planning methodology to directly ascertain the LOS for the existing conditions. The planning method was not intended to be used as a tool for evaluating existing conditions. This has produced LOS ratip-- for existing conditions that may be drastically different than the actual existing conditions. 71 result is that any reference to service levels for existing conditions cannot be relied upon as an accurate depiction of current conditions. For example, in the computation of the LOS for the Los Osos Valley Rd corridor, the presented analysis uses default values from a general computer program. The actual running time along the section is not known, the ratio of green time for LOVR.and the intersecting streets is not known, the capacity of the lanes is not calculated, the average cycle length for a signalized intersection is not observed, the average delay for sidestreet vehicles is never measured. These real world values are needed to accurately depict the existing conditions on-street, and to provide the average reader of the report with some insight into what should be expected for the future. As presented the technical analysis is essentially useless since it is not valid for existing conditions and therefor can not give an accurate depiction of future LOS. It may however be useful for predicting change in LOS. In conclusion, while the traffic report addressed some of the technical issues previously raised by staff, it continues to fall short in providing a clear impact analysis, the description of mitigation measures, and the assignment of responsibility for these measures. Given the financial interests of the applicant, we believe that a third party evaluation is justified and should be part of a focused EIR. At a minimum, the impact analysis should cle.uiy present: ❑ Existing conditions in terms of traffic levels, intersection and link level of service (LOS). V ❑ Traffic impacts of the project on LOVR and related intersections that clearly indicate what street segments, bridges and intersections that will experience substandard traffic conditions after the project is built. ❑ A critique of the frontage improvements that the applicant proposes to construct as part of the shopping center project to determine their mitigation value. ❑ Additional mitigation measures needed to address substandard traffic conditions caused by the project-- measures not committed to in the project description. The analysis should identify any special studies needed to design these measures -- eg. a Project Study Report (PSR) for modifications to the Route 101/LOVR interchange and bridge. ❑ A schedule for the installation of all ,mitigation measure relative to the opening of the new shopping center project. ❑ The implementation costs of all transportation mitigation measures not committed to in the project description; a determination of which measures are eligible for a traffic impact fee (TIF) credit and which ones are legitimately paid for in their entirety by the applicant, a determination of which measures should involve a reimbursement agreement. cc Mike McCluskey, Public Works Director Wayne Peterson, City Engineer. i:1wp5IVroom2 Dec 11, 1995 Memorandum: To: Whitney McIlvane, Planning From: Jerry Kenny, Engineering Subject: Froom Ranch Annexation Drainage Report A hydrology report by Central Coast Engineering was submitted and reviewed in November 1995 which, in a sense satisfies the requirement to submit a hydrology report. On the other hand we do not agree with the• logic or the conclusions of the report. The report uses inappropriate applications of the city standards that are intended for design of drainage structures to analyze "before and after" conditions in such a way that there is, in effect, practically no change in flows as a result of developing a near flat agricultural field into a shopping center. For one example, the city "Coefficient of runoff" nomograph, that is intended for design of culverts, etc. has a maximum indicated of 0.8. Typically, when engineers use this nomograph for analyzing "before and after" runoff, they normally .eliminate the 0.8 maximum since, logically, it would not be resonable to use this in comparing the difference between 0.8 for "before" and 0.8 for "after". Another error in logic is to assume where design storm flows currently exceed the capacity of certain existing pipes under Los Osos Valley Road and this project does not change these pipes, that "no additional impacts can be associated with the project". In this case these pipes carry only a minor fraction of the flow underground. Staff anticipates considerable increase in flows as a result of this project, therefore the surface flows would increase considerably in areas where there is much existing commercial development and traffic which would be adversely impacted by . greater flows. With these and other minor errors, they arrive at conclusions that are unreasonable and unacceptable for a comparison of before verses after storm runoff. Using County standards, the runoff from the area being developed increases 143% between "before and after" conditions for 10 year storms. (Other storms similar) Staffs determination (Using City standards) , is that the flow increases around 47% for the same storm. The subject report determines an overall increase of only around 4% for a 10 year storm with some areas decreasing. Unless the engineers can revise the report to the City's satisfaction, staff recommends an independant focused analyses be done by an independent engineer. Since the project affects County and Caltrans their concurrence with the result of the report is also necessary. y�y Conditions: Assuming the hydrology is revised to obtain realistic flow increases, as indicated above: 1. The drainage must be designed to mitigate any adverse impacts that may be caused by this development and carry them to an adequate point of disposal in San Luis Creek. This may include detention basins, culvert enlargements, etc. Detention basins may be on or offsite to the project and may be above or below ground. 2. A drainage master plan must be formulated by the applicant and approved by the City, County, & Caltrans, to show how the total property is to be developed including Froom Creek and the area between this development and U.S. Hwy 101. This project must pay an appropriate share towards the work needed to carry out • the improvements shown in this master plan. G:\wp51\DReview\Misc\Froom.Drl RECElVEp OCT 1 61995 October 13, 1995 Cl'l*yMu°F UN furs osispp �toP�nrT MEMORANDUM TO: Whitney McIlvaine FROJerry Kenny SUB Froom Annexation - Public Works Dept. comments on completeness of application. In response to your memo of October 6th the following comments are submitted: This department feels that the application is not yet complete re: the following: 1. Traffic issues - the traffic report. as submitted is flawed and is incomplete in other ways. During the meeting last Wednesday (10-11) with the consultants, the flaws and other issues to make the report more complete, were discussed and the consultant knows what is expected to make the report complete. _ When the report is resubmitted and reviewed by staff, we should be able to write applicable conditions if all of our concerns have been addressed. If we, CalTrans or the County are still not satisfied with the report and/or findings, any unresolved issues could be addressed in an EIR. Traffic Impact Fees will be specifically addressed in the recommended conditions for the project. 2. Drainage issues - The drainage report has not yet been . formally submitted, although staff has discussed the issues with the project engineer. CalTrans and the County Engineer probably have not yet seen the report either. After the report is submitted and reviewed by the respective agencies, the adequacy and/or deficiencies of the report and findings will be addressed as to completeness. Conditions could presumably then be written. Any unresolved matters may be included in an EIR. Portions of the annexation area, along Los Osos Valley Rd. (interim open-space) and along and adjacent to Froom Creek, are subject to 100-yr flooding per the latest County Flood Hazard Boundary Map. Specific flood elevations have not yet been established- on the map, so hydrologic and hydraulic studies will be required to establish the extent of flooding and resulting finished floors elevations. In a new development area like this, staff will recommend elevated pads for any affected structures, in lieu of floodproofing; whereas parking areas may flood. This has another benefit, in that flood insurance would not be required: The first phase area is not affected. Whitney McIlvaine (Froom Annexation) October 13, 1995 Page Two Staff will also recommend a condition that requires the developer to process a FEMA Flood Insurance Rate Map (FIRM) amendment to establish the respective flood elevations that are determined. 3. Lot Line Adjustment - should be postponed until annexation and development is tentatively approved. 4. R/W - Improvements and Dedication requirements - When the traffic report is complete, staff will transmit specific final comments and conditions. The ultimate street section and R/W width for LOUR appears to be adequate, but the transitions and complete buildout limits need to be analyzed after .a satisfactory traffic report is received. 5. Soils/Geology - Where did the information come from that is included in Dennis Schmidt's letter? It would sefjVJ ogical to have a preliminary soils engineering/geology report showing the feasibi- lity of the project and issues to address with the actual building development. Unless the applicant agrees to include mitigation measures deter- mined by the City, County and State to be necessary to mitigate significant impacts caused by the project, based on the respective studies (or as otherwise determined) , an EIR would be needed. c: MB/HB/file Faxed to MM/JR/TS/WP G: \wp51\dreview\misc\FroomCom.mem 77 July 3, 1995 FROOM RANCH PRE-ZONE ANNEXATION DEVELOPMENT Owner/Developer: Madonna Construction Co. Engineer: Central Coast Engineering PRELIMINARY REVIEW OF PRE-ZONING AND ANNEXATION EXHIBIT DEVELOPMENT PLAN 1. . The main entrance driveway should be aligned with a feasible extension across Los Osos Valley Road to be along side the line of existing school and development, rather than centered on this line. 2. On Exhibit F-7.21 Development Plan, there are 3 sedimentation basins shown between the hills and the buildings. On sheet Exhibit F-7.22, called the "Grading and Drainage Plan", no such sedimentation basins are shown. 3. On Exhibit F-7.22, a line is labeled "Provide drainage swale or pipe between the hills and the buildings. " In this area it will be essential to collect water coming off the hills and provide sedimentation as indicated in the previous item above. A pipe without a considerable swale and/or wall would not intercept the flow. 4. On Exhibit F-7.21 the existing concrete lined channel along side the car dealerships fronting on Auto Park Way is shown, but no indication is given as to how much water is flowing through it and whether .tis being added by this project. 5. On Exhibit F-7.21 a quantity of water shown flowing along Los Osos Valley Road up to 398.9 cfs is indicated without an indication of how it is to be carried. On the same sheet, the existing drainage swale is indicated after the temporary detention and sedimentation basin without taking into account an existing pipe in that area. An analysis needs to be made to show that the development proposed will not cause flooding. of the existing buildings in this area. 6. The existing culverts crossing Los Osos Valley Road show a Q of 20 and 13 etc. cfs, but do not indicate which direction the water is to flow. hbl/hoom-prezone by '29 urnzrmsA MEMORANDUM 6. DATE: December 18, 1995 TO: Whitney McIlvaine, Project Plan FROM: Dan Gilmore, Utilities Engineer VIA: Mike Bertaccini, Public Works SUBJECT: Froom Ranch Development Proposal The Froom Ranch development proposal indicates appropriate extensions of public utilities to serve the project. The project site has an adequate water main along the frontage in Los Osos Valley Road. This water main is a 12" cast iron pipe that was originally installed around 1966. No adequate sewer facilities exist in the vicinity to provide the site with sanitary sewer service. The development plan indicates that the project includes a 10" sewer main that would be extended to the existing gravity sewer in the Dalidio property currently leased by Zapata Farms. The proposed plan for sewer service appears to be the best alternative and needs to be developed . further for engineering feasibility. Specific areas of concern include the creek crossing and maintenance of minimum grades. The City does not currently have adequate water supplies to serve new development. Development can occur under the Water Retrofit Program, whereby water allocations can be earned by offsetting the anticipated increase in demand with water efficient fixtures on a two-to- one basis. Currently, 33 acre-feet are available for allocation to annexation areas. Several proposals have been brought to the City that would use some or all of the allocation available through retrofit. Private wells have been allowed only on an interim basis, and only on the parcels that contain the wells. Private well water can not be used to serve other properties in the City of San Luis Obispo. Other restrictions apply to the use of private well water. The Water Allocation Regulation and the Urban Water Management Plan identify these restrictions. The use of private well water does not preclude the requirement of payment of impact fees or the development of a permanent water supply. Both water and wastewater impact fees would be required at the time a building-permit was issued. The developer should submit wastewater generation calculations so that the City can make a determination as to whether or not the downstream facilities are adequate to handle the additional flow. The wastewater calculations should reflect ultimate development of the project. If you have any questions please feel free to call me at 781-7208. wog: rfoommuno 7/ SRO Luis OBISPO COURTY DEPART MENT 11950 COUNTY GOVERNMENT CENTER • ROOM 207 • SAN LUIS OBISPO, CALIFORNIA 93408 TIMOTHY P NANSON PHONE (805) 781-5252 FAX (805) 781-1229 COUNTY OHM" OLIN L PRIDDY DEPUTY COUNTY 111101111111 ENDDm11ND aRVICEs NOEL KING Y D DAIRY COUNTY ENOUWR ROADS ADNIMM'RATIO" JAN 2 6 OLID WASTE 1996 FRANCHISE ADMINISTRATION ENGINEERING 01vISI0N WATER RESOURCES CRY OF SANLUIS O81SP0 COUNTY SURVEYOR January 22, 1996 SPECIAL DISTRICTS Whitney Mcllvaine, Planning City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93401-3249 Subject: Froom Ranch Annexation Drainage Review Dear Ms. Mcllvaine: In response to your request to review the drainage report for the annexation of the Froom Ranch to the City of San Luis Obispo the following comments are made: 1. In reviewing the December 11, 1995 memo from Jerry Kenny from your Engineering Department, we concur with his general conclusions in that realistic drainage flows (to show potential increases) must be calculated to forecast the potential impacts on downstream structures. We would go further to say that these impacts must be addressed to both upstream and downstream conditions within Perfumo Creek and San Luis Obispo Creek. The City of San Luis Obispo, the County Flood Control District, Caltrans and the Corps of Engineers should be included in approving the applicants .recommended project, and final drainage calculations. 2. In reviewing the applicant's drainage calculations, we found that the run-off coefficients were not applied correctly and that increased flows from the development were not developed. It is the County's policy that such increases should be retained or detained within the development and full analysis of downstream and upstream impacts should be evaluated for potential impact. In light of the flooding occurrences in the Avila Valley area (the San Luis Obispo Creek water course between 101 Bridge and Avila), it is most apparent that increases to run off in this water shed will have adverse affects on downstream properties. 3. We would highly recommend that because of these potential downstream impacts, that a full detention type facility be included as a baseline requirement for this project. It is also important to realize that the actual development plans for both current and future projects be incorporated to ensure an adequate detention system is included at the initial onset of project developments. 7— 4. We believe that a cumulative analysis of drainage impacts in both Perfumo Creek and San Luis Obispo Creek ensure that there are no impacts within the water shed both upstream of the project to as far as Laguna Lake at Madonna Road; San Luis Creek at Marsh St; and downstream to the 101 over crossing, Sycamore Mineral Springs and Avila Beach areas. 5. One further point of observation is the cross culverts on Los Osos Valley Road and potential flows entering these existing facilities should not be used to provide credit to skim flows off the developed flows along Los Osos Valley Road unless an analysis is made on the increased flows from the intersection of the new improvements at Los Osos Valley Road to their interface with Perfumo Creek. Based on County standards and the potential impact of such an intensive development, we would require a complete review and analysis of impacts caused by increased runoff using realistic before and after situations in the approval of this project. The County is very sensitive in light of the 1995 storms to additional runoff being added to the water shed south the City of San Luis Obispo. You may be aware that there are several law suits resulting from the flood flows that occurred during both January and March 1995. Additional flows in this portion of the water shed will increase the risk of additional litigation for those involved with not providing the safeguards that our regulations and policies require. If you have any questions or comments, please feel free to contact me directly at 781- 4469. Sincerel OU BSON Hydraulic Planning Engineer Enclosure: Hydraulic Report cc: Jerry Kinney, San Luis Obispo Engineering Flood Control, Zone 9 Committee File: Flood Control, Zone 9 General File m:\luann\lgg\mcilvain.ltr MEETING AGENDA uNCIL FIN DIR DATE -�6_ITEM # CENTRAL 'COrMG o ❑ FIN DIR ENGINEERING � ❑ FIRE CHIEF ORNEY ❑ PW DIR 396 Buckley Road.Suite 1R�RIG ❑ PoucECHF 06 February 1996 San Luis Obispo MTTEAM ❑ REC DIA E1289 California 93401 EAD FILE ❑ UTIL DIA (805)544-3278 f ��__, ❑ PERS DIR FAX(805)541-3137 City of San Luis Obispo City Council Members P.O. Box 8100 RECEIVED San Luis Obispo, CA 93403-8100 Re: Froom Ranch Commercial Expansion Project (ER 80-95) FEB 6 1996 cm courvCIL SAN t oalsPo. CA Council Members... The following comments are in response to the Environmental Determination (dated 04January 1996) prepared for the referenced project. A. Introduction. The CEQA guidelines state that the Lead agency shall conduct an Initial Study to determine if a project may have a significant effect on the environment, and then continues to define the concept of significant effect as a physical change in the environment (changes can be beneficial, as well as adverse). This is key because the Guidelines allow for the preparation of a proposed Negative Declaration, if the Initial Study determines that the project mitigates the identified effects, or if not, the project is revised or the applicant agrees to mitigate the identified effects prior to release of the public report. CEQA Section 15070,Decision to Prepare a Negative Declaration. A proposed Negative Declaration shall be prepared for a project subject to CEQA when either: (a) The Initial Study shows that there is no substantial evidence that the project may have a significant effect on the environment, or (b) The Initial Study identified potentially significant effects but: (1) Revisions in the project plans or proposals made by or agreed to by the applicant before the proposed Negative Declaration is released for public review would avoid the effects or mitigate the effects to a point where clearly no significant effects would occur, and (2) There is no substantial evidence before the agency that the project as revised may have a significant effect on the environment. Although the Guidelines state that the determination of what constitutes significance is not ironclad, it does require that careful judgement must be used in its evaluation. In this case, the preparation of the Initial Study does not carefully judge the mitigations offered by the applicant, or those found In certified EIR's, and instead makes its conclusion that an EIR is required because of (1) lack of money, time and experience, or (2) the type and size of the project, or (3) the threat of a lawsuit. This is not a fair approach and a fundamental diversion from the CEQA process that is suppose to be determining if.there are unmitigated significant effects. Because there is a question about the Initial Study process, the applicant requests the appeal.wps 2 Council to review the data offered by the project and that which exists in previously certified EIR's, and determine whether it mitigates the identified effects to levels less than significant. CEQA Section 15064 (b),Determining Significant Effect. The determination of whether a project may have significant effect on the environment calls for careful judgement on the part of the public agency involved, based to the extent on scientific and factual data. An ironclad definition of significant is not possible because significance of an activity. may vary with the setting. For example,and activity which may not be significant in an urban area may be significant in a rural area. Alternatively, the Council should not require this project to go through the EIR process again because a similar project was subject of a prior EIR which was certified by the County of San Luis Obispo on 09 November 1989. The Guidelines and the Public Resources Code clearly provide that an applicant is not required to duplicate the EIR process, but may rely upon apreviously prepared EIR, under appropriate circumstances. These sections apply directfy to the development project. CEQA Section 15153, Use of an EIR from an Earlier Project. (a) The Lead Agency may employ a single EIR to describe more than one project, if such projects are essentially the same in terms of environmental impact. Further, the Lead Agency may use an earlier EIR prepared in connection with an earlier project to apply to a later project, if the circumstances of the projects are essentially the same. (b) When a Lead Agency proposes use of an EIR from an earlier project as the EIR for a separate, later project, the Lead Agency shall use the following procedures: (1) The Lead Agency shall review of the proposed project with and Initial Study, using incorporation by reference if necessary, to determine whether the EIR would adequately describe: (A) The general environmental setting of the project, (B) the significant environmental impacts of the project, and (C) Alternatives and mitigation measures related to each significant effect. Public Resources Code 21166. Mien an EIR has been prepared for a project pursuant to this division, no subsequent or supplemental EIR shall be required by the Lead Agency or by any Responsible Agency, unless one or more of the following events occurs. (a)Substantial changes are proposed in the project which will require major recisions of the EIR, (b) Substantial changes occur with respect to the circumstances under which the projccr L being undertaken which will require major revisions in Bre EIR, (c) New information, which was not brown and could not have been known at the time the EIR was certified, becomes mwailable. Furthermore, the Guidelines state that the requirement for preparing an EIR for a local general plan amendment are satisfied by using the General Plan EIR if the proposed amendment is consistent with those documents, or supplement document. This section applies directly to the annexation project. CEQA Section 21166,EIR as Part of a General Plan. (a) The requirements for preparing an EIR on a local general plan, element, or amendment thereof will be satisfied by using the general plan, or element document, as the EIR and no separate EIR will be required, if: (1) The general plan addresses all the points required to be in a EIR by Article 9 of these Guidelines, and (2) The document contains a special section or sheet identifying where the general plan document addresses each of the points required. appeal.wps 3 B. Comments. Besides selectively not including information from existing EIR's, other factors have influenced the Initial Study to determine there may be significant impacts associated with project. These are (1) the inability of the review to distinguish between the annexation and development projects, and (2) the failure to use complete, accurate project descriptions. 1. Annexation and Development. Because the Initial Study does not distinguish between the annexation and development projects and confuses the issues, the conclusion of the analysis overstates the significance of the potential impacts. Comment. Separating the study into two separate reviews would help provide clearer views of the mitigations offered by the applicant, or those found in certified EIR's. Not distinguishing between the projects confuses the analysis, and the methodology through the CEQA process. Remember, the Guidelines state that the requirement for preparing an EIR for a local general plan amendment are satisfied by using the General Plan EIR if the proposed amendment is consistent with those documents, or supplement document. This section applies directly to the annexation project. Also, the Guidelines and the Public Resources Code clearly provide that an applicant is not required to duplicate the EIR process, but may rely upon a previously prepared EIR, under appropriate circumstances. These sections apply directly to the development project. 2. Project descriptions. Because the Initial Study complicates the project descriptions by adding a third project, and then chooses not to carefully judge the mitigations offered by the applicant, or those found in certified EIR's, the conclusion of the analysis overstates the significance of the potential impacts. The project descriptions in the applications are: a. 66.6 Acre Annexation. This project is divided into two areas, a 54.5 acre area with requested prezoning as general retail, and a 12.1 acre area with requested prezoning as interim open space (a holding zone in the City). Based on General Plan policies for building intensity, approximately 700,000 sq. ft of building area can be constructed on the annexation area. b. 300,000 square feet of development. This second project consists of two structures, a 170,000 square foot building and a 130,000 square' foot building. Comment. CEQA states there is not an ironclad definition of significant effect, because of this a thorough project description is critical to the Initial Study process. Not only should the basic project be described (eg. a house on a hillside), it should also include (at a minimum) its objectives or mitigations (eg. a house on a hillside with colors blending into the existing terrain), and its vicinity (eg.-atiouse on a hillside with colors blending into the existing terrain surrounded by 10 other homes). appeal.wps 4 C. Mitigations. The determination of whether a project may have a significant effect on the environment calls for careful judgement. The following mitigations offered by the applicant, or those found in the Initial Study, the County certified Madonna General Plan EIR, the City General Plan EIR, and EIR Supplement and corresponding resolution all reduce the identified effects to a level less than significance. 1. Open Space Dedication. General Plan Policy 1.13.5 states each annexation shall help secure permanent protection for designated Open Space, but does not quantify the timing of when the protection is to occur. Timing is addressed in General Plan Policies 1.13.5A, 6.2.6(H), and 8.10.2 (D), all stating that permanent open space protection is to occur with either subdivision or development, not annexation. Furthermore, the definition for development as written into the General Plan (Open Space Element), does not include the term annexation. An neration mitigation. No mitigation required. Development Mitigation. 28-5 acre open space easement above the 150 contour immediately behind project site. No additional mitigation is required. 2. Agriculture Land. General Plan Policy 1.8.2 was written %%ith the statement "or an equally effective method" purposely to allow for open space dedication other than agriculture lands for development projects with designated open space areas. This statement applies to development projects in the Irish Hills area, and is quantified by General Plan Policies 1.13.5 and 6.2.6(H) and the Open Space Element which say that open space dedication for projects in the Irish Hills shall be those areas above the 150 foot contour (non-agriculture land area). Lastly, CEQA states that conversion of prime agriculture land to non-agriculture uses normally is a significant impact that requires a finding that overrides the mandatory effect. This has occurred with the approval of Resolution 8.332 Annexation Mitigation. Overriding finding written in Resolution 8332, no additional mitigation is required. Development Mitigation. Overriding finding written in Resolution 83.32, no additional mitigation is required. 3. _Geology. All potentially significant geological impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Anneration Mitigation The General Plan EIR (pages 6.6.15 to 6.6.17) identifies that all mitigations be applied at the time of development and continues by identifying those programs. They are standard development conditions of approval, and compliance with the Unifornn Building Code. The Supplement EIR (page 37) identifies compliance with the City Seismic Safety Element, as mitigation also at the time of development. No mitigation is required for annexation. appeal.wps 5 Development Mitigation. The General Plan EIR (pages 6.6.15 to 6.6.17) identifies standard development conditions of approval, and compliance with the Uniform Building Code as mitigations at the time of development. The Supplement EIR (page 37) identifies compliance with the City Seismic Safety Element, as mitigation also at the time of development. Standard conditions and compliance with the Uniform Building Code and the City Seismic Safety Element requiring preparation of soils and geolo&ic engineering investigations, and seismic safety include evaluation emphasizing earthquake fault lines, liquefaction potential, landslide potential, subsidence and erosion. All these programs mitigate the identified potential impacts to levels less than significant, and no additional mitigation is required. 4. Drainage. All potentially significant drainage impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Annexation Mitigation. The General Plan EIR (pages 6.9.10 to 6.9.11) identifies that all mitigations be applied at the time of development and continues by identifying those programs. They are standard development conditions of approval, compliance with General Construction Activity Storm Water Permit, grease traps, retention of natural drainages, use of previous avis material, and reparation of an hydraulic study. The Supplement EIR page 36) identifies the use of retention basins and Frown Creek flow channel stabilization as mitigation also at the time of development. No mitigation is required for annexation. Development Mitigation The General Plan EIR (pages 6.9.10 to 6.9.11) identifies standard development conditions of approval, compliance with General Construction Activity Storm Water Permit, grease traps, retention of natural drainages, use of pervious paving material, and preparation on of hydraulic study as mitigations at the time of development. The Supplement EIR (page 36) identifies the use of retention basins and Froom Creek flow channel stabilization for mitigations at the time of development. The CCE Hydraulic study (pages 2 to 4) identifies standard development conditions of approval, detention basins, sedimentation basins, open channels or underground mains, Froom Creek flow channel monitoring program, From: Creek levee (away from existing bank), compliance with Fish and Gmne and Amey Corp provisions, open channel or underground main oversizing and reimbursement as Project mitigations. All these programs mitigate the identified potential impacts to levels less than significant and no additional mitigation is required. 5. Water Supply. All potentially significant water supply impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Annexation Mitigation. The General Plan EIR (pages 6.5.15 to 6.5.16) identifies implementation of current City policies on the Salinas Reservoir expansion, Lake Nacimiento water, and greywater incentive program as programs that mitigate impacts for the build out project. These programs and the City set aside of 33 acre feet of water retroft for annexation projects, mitigates all potentially significant water supply impacts associated to annexation to levels less than significant. Furthermore, because the Supplement EIR (page 2) reviewed a project of less demand than that in the General Plan EIR (residential vs. commercial), service/utility impacts were appeal.wps 6 determined less than significant. No additional mitigation is required for annexation. Development Mitigation. The General Plan EIR (pages 6.5.15 to 6.5.16) identifies standard development conditions of approval, and the project proposes retrofit of 12 acre feet of the available water set aside for annexations for potable use, use of 2 acre feet of private well water for landscape irrigation, and hook up fees as mitigations. These programs and the certified Madonna General Plan EIR (page V.27) finding that no impact is associated to the pumping of a 172 acre feet/year mitigates all potential impacts to levels less than significant and no additional mitigation is required. 6. Transportation and Circulation. All potentially significant transportation and circulation impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Annexation Mitigation. The General Plan Supplement EIR (page 37) identifies the designation of LOVR as a parkway arterial, designation of LOVR as a four lane arterial from SLO Creek to South Higuera as a four lane arterial, and the widening of the Highway 101 bridge to four lanes as acceptable mitigation for approximately 145 acres of commercial development are acceptable mitigations. The applicant offers to participate with other development projects effecting the Highway 101/LOUR corridor in a Cal Trans public services report. This report has no bearing on the transportation and circulation improvements offered as mitigation for the development project. The applicant has also requested revising the circulation element to Incorporate language that would permit a regional transit hub along the LOUR corridor. All these programs mitigate the identified potential impacts to levels less than significant and no additional mitigation is required for annexation. Development Mitigation. The Initial Study (pages 30 and 31) and the project has supplied a traffic study (Penfield & Smith Traffic Impact Analysis, pages v to vi) for the development of 300,000 sq. ft. of commercial retail use that identifies standard development conditions of approval, project frontage roadway improvements, signal installation at 16 acre gap, Auto Parkway and Calle Joaquin, an additional travel lane on west side Highway 101 bridge approach, four travel lane and two Class II bike lane construction on LOVR from Madonna Road to Garcia Drive, transportation impact fees, road improvement oversizing and reimbursement, bus turnout and shelter, and park and ride coordination with Caltrans. Because any future expansion proposal will require its own analysis, all these programs above will mitigate the identified potential impacts to levels less than significant. Because professional traffic engineers all use national standards and methodology, additional study by an independent consultant will not conclude any new world shattering discoveries, mitigations, or alternatives. In this particular case, the City Engineering Department does not disagree with the mitigations in the Penfield & Smith report, they disagree with how and who is to pay for them. Traffic engineering is a number crunch that will always draw the same conclusion, because of this process no additional mitigation is possible. 7. Biology. All potentially significant biological impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. appeal.wps 7 Annexation Mitigation. The General Plan EIR (pages 6.10.14 to 6.10.17) identifies (pages implementation of current City policies as mitigation for build out. Because these programs are in motion, no additional mitigation is required for annexation. Development Mitigation. The applicant offers to create a burrowing owl management program prior to development, if Froom Creek banks are proposed to be disturbed (the Froom Creek levee is proposed away from the existing banks). This program is identified in the Madonna General Plan Amendment EIR (page V.47) as a mitigation that reduces the potential impact to a level less than significant. No additional impact is required. 8. Botany. All potentially significant botanical impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Annexation Mitigation. The General Plan EIR (pages 6.10.14 to 6.10.17) identifies implementation of current City policies as augation for build out. Because these programs are in motion, no additional mitigation is required for annexation. Development Mitigation. The General Plan EIR (pages 6.10.16 to 6.10.17) identifies the use of a suggested planting list for landscaping as acceptable mitigation. The• applicant agrees to performing a spring time survey as identified in the Initial Study. Both these programs mitigate potential botanical impacts to levels less than significant and no additional mitigation is required. 9. Noise. All potentially significant noise impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Annexation Mitigation. The General Plan EIR (pages 6.6.15 to 6.6.17) identifies that all mitigations be applied at the time of development and continues by identifying these programs as short and long term. The Supplement EIR (page 2) identifies noise impacts as less than significant. No mitigation is required for annexation. Development Mitigation (short tem:). The General Plan EIR (pages 6.6.15 to 6.6.17) identifies construction activity limitations, construction equipment maintenance, portable noise barriers, equipment operation restrictions as acceptable programs that mitigate potential impacts to levels less than significant and no additional mitigation is required. Development Mitigation_ (long term). The General Plan EIR (pages 6.6.15 to 6.6.17) identifies standard attenuation measures as acceptable mitigations, and the Supplement EIR identified noise impacts from an approximately 145 acre development project as less than significant. No additional mitigation is required. 10. Utility and Service Systems. All potentially significant utility and service system impacts identified in the Initial Study can be mitigated to levels less than significant with the following data. appeal.wps 8 Annexation Mitigation. Because the Supplement EIR (page 2) reviewed a project of less demand than that in the General Plan EIR (residential vs. commercial), service/utility impacts were determined less than significant. No mitigation is required. De�vel0� ment it igation The applicant agrees with the Initial Study (page 31) mitigations identified as standard development conditions of approval, utility undergrounding along project frontage, sewer and water main construction to the satisfaction of the City, main oversizing and reimbursement, and sewer and water hook up fees mitigate all potential impacts to levels less than significant. No additional mitigation is required. 11. Aesthetics. All potentially significant aesthetic imacts identified in the Initial Study can be mitigated to levels less than significant with the following data. Aimeration MitigatiOIL The General Plan EIR (pages 6.12.30 6.12.32) to identifies that all mitigations be applied at the time of development. No mitigation is required for annexation. Development Mitigation. Site planning and architecture approved by the Architectural Review Commission will mitigate all potential impacts to levels less than significant. No additional-mitigation is required. D. Conclusion. Just because a potential impact can be associated with a development, does not mean the impact is significant (as concluded in the determination under appeal). CEQA outlines specific methodology for how the review process is suppose to occur, these procedures are: 1. Preliminary Review. The agency reviews the application for completeness and also is alert for environmental issues that might require preparation of an EIR, or that may require additional explanation by the applicant. 2. Initial Study. The agency determines if the project may have significant effect on the environment with use. a. Determining Significant Effect. Through careful judgement of the project, its programs, or those found in previously certified EIR's, the agency determines whether the potential significant effects have been mitigated. 3. Negative Declaration or EIR If the determination concludes that the mitigations reduce the potential effects to less than significant level, a Negative Declaration is warranted. If the determination concludes there is still significant effect, and EIR is required. appeal.wps 9 Based on the information provided in this document about the mitigations offered by the project, and the mitigations found in the Initial Study, the General Plan EIR, and Supplement EIR, the applicant requests Council to uphold the appeal of the Community Development Departments requirement for a focused EIR, and then give direction to staff to move forward to notice the intent to file a Negative Declaration (mitigated) for the Froom Ranch Commercial Expansion Annexation and Development Projects. Thankx for your consideration... ry y, c Dennis c mi t appeal.wps The following references include programs that mitigate the potentially significant impact identified in the Initial Study to less than significant levels. 1. Open Space Dedication............................................Project Mitigation 2. Agriculture Land.............:..........................................Resolution 8332 3. Geology........................................................................General Plan and Supplement EIR's 4. Drainage......................................................................General Plan and Supplement EIR, CCE Hydraulic Study 5. Water Supply..............................................................General Plan EIR, Retrofit Program and Madonna EIR 6. Transportation and....................................................Supplement EIR, Circulation Penfield and Smith Traffic Study, and Caltrans PSR 7. Biology.........................................................................General Plan EIR and Madonna EIR 8. Botany..........................................................................General Plan EIR and Initial Study 9. Noise............................................................................General Plan and Supplement EIR's 10. Utility and...................................................................Gcneral Plan and Service Sysytems Supplement EIR's, Initial Study 11. Aesthetics....................................................................General Plan EIR ref.wps d f I 'D1 JO J 4NO .U12 F' . U1 MEETING , AGENDA DATE&i ri Em v _ January 31, 1996 B-COUNCIL ^-� I32DD DIR N Whitney McIlvaine, Associate Planner 63-CAO ❑ FIN DIR Community Development Department, City of San Luis Obispo P-ACAO ❑ FIRE CHIEF San Luis Obispo, CA 93401 e"ATTORNE' ❑ PW DIR Q'CLERKCMG ❑ POLICECHF 13MGWrTEAM ❑ REC DIR RE: Froom Ranch annexation and development environmental review. ❑ C READ FILE 13U17L DIR I.[/ ❑ PERS DIR Dear Ms.:McIlvaine, Thank you for submitting the initial study and development plans for the proposed annexation and development of Froom Ranch. According to the information submitted by your office, the project will consist of the annexation and prezoning of 67 acres along Los Osos Valley Rd between Madonna Rd. and Highway 101. Development of the commercially zoned portions of the site will occur in phases with a final planned 600,000 sft. of retail floor space divided amongst several "big boxes" and smaller retail buildings. The applicant is appealing the initial study findings of possible significant environmental impacts and the recommendation that a focused EIR be prepared. We have conducted a preliminary assessment of the potential air quality impacts associated with final completion of all phases of the project resulting from attracted and generated automobile trips. Our assessment is based on the land use impact model URBEMIS5, which determines expected air quality impact levels based on land use categories, ITE trip generation tables, and emission factors and assumptions contained in HMFAC7F. Our preliminary assessment indicates that our significance thresholds will be greatly exceeded. We therefore agree with the findings of the initial study and recommend the preparation of an EIR to provide the public and decision makers with a comprehensive and independent analysis of potential impacts. We do recommend a change to the current proposed focused EIR to include an air quality assessment. The need for an air quality assessment stems from the potentially significant traffic impacts likely to accompany this proposed project. Specific Comments Transportation/Circulatlon Given the number and degree of concems expressed by Public Works Department staff regarding the Penfield & Smith traffic study, we concur with the Initial Study recommendation for independent review of the existing traffic study(as stated on page 16); a focused EIR appears to be the obvious vehicle for such an effort. From.our preliminary analysis,we anticipate attracted and generated vehicle trips to produce emissions of reactive organic gases and oxides of nitrogen (ozone precursor compounds)twenty to sixty times our daily emissions significance threshold. The calculation of 1950 additional parking spaces by the applicant at one space(1) per 150 sfl. of building area(above the 1 per 500 sft. City requirement) indicates the overwhelming automobile dependence this site will afford its clientele and workers. A more refined air quality impact assessment is therefore recommended and should be based on an independent traffic analysis z incorporating current and anticipated vehicle counts on impacted roadways and intersections, marketing strategies of tenant businesses, and geographic and demographic trends(ie distribution of jobs and holding and location of population centers likely to utilize the proposed facility). 2156.Sierra Way, Suite B•San Luis OVspo. CA 93401 • 805-781-5912 • FAX: 805781.1035 SLO -COUNTY RG AND RPCD TEL No .8057811035 Jan 31 ,96 9 : 45 No . 012 P . 02 Lain Use The project description indicates that "the first phase of development would entail construction of two buildings with a total area of roughly 300,000 sft., each to be occupied by a single tenant warehouse retailer...". Warehouse retail outfits tend to be regional attractors dependent on high volumes of customers. On the central coast, populations tend to be clustered in separate, ` comparatively compact communities set against a lower density rural background. Retail centers with regional draw will therefore tend to produce relatively numerous and long'automobile trips. San Luis Obispo, one of the most successful communities on the central coast, has-traditionally provided goods and services to its inhabitants through more neighborhood and community scale development; resulting in shorter automobile trips. We feel that the upzoning of Residential- Single-Family and Agriculturally zoned land to Retail-Commercial,with subsequent incorporation of 300,000 sft. (Phase 1) of warehouse retail with regional influence, unwise . without careful consideration of the impacts, and therefore reiterate our position favoring adoption of a focused EIR. Consistency Analysis An important component of any EIR is a consistency analysis of a proposed project with respect to pertinent planning and environmental guidance documents (ie. general and specific pians, clean air plans, ...etc.). The District's Clean Air Plan (CAP) is such a document, and contains land use policies designed to lessen automobile dependence through greater pedestrian access, increased transit access, mixed use and compact zoning, and balance of jobs and housing. Projects, with potential size and character to impact the assumptions contained in the CAP, can impede the District's attempts to achieve the State ozone standard (the District is a moderate nonattainment area). In addition, the first item mentioned in the City's Overall Transportation Strategy portion of the Circulation Element (page 6)is "l. Managing city and regional growth consistent with the Land Use Element". Therefore, the consistency analysis obtained through the EIR process is very important from a decision making standpoint Thank you for the opportunity to provide comment and review for this project. Please keep us informed of developments or meetings involving this project. If you have any further questions, please do not hesitate to call me at 781-5743. Thank you Barry Lajoie Air Quality Specialist BPL/bpl HtpLAN�BI""�Y1W VSl11PVSVl6F6RRA1.�9e001.BPL `.2 MEETING Q-+o -9G AGENDA DATE � City of San Luis Obispo --ITEM # 990 Palm Street P 0 Box 8100 San Luis Obispo, CA 93403-8100 6092 Lewis Lane 'San Luis Obispo, CA 93401 February 5, 1996 s Dear Council Members : We are most concerned about the proposed development of -the 66 . 6 acres of land..known as the. Froom Ranch Annexation. We support a focused environmental impact report because of the history of foundation failures in many of the homes across from the property. We own two properties in the area: one house on Garcia and one on Pico. Both homes had cracked foundations, and after the pumping of water by the City of San Luis Obispo, the Pico foundation collapsed. We spent thousands of dollars correcting the foundation, and had to re-pour the slab. Since the City has already paid one homeowner on Garcia, as well as settled the Bear Valley suit, we certainly hope that any proposed development of the property would bear in mind that the increased water consumption of a high traffic area might endanger other homes in the area and lead to further culpability. We do hope you will require a thorough review of the area, keeping in mind the new homes in the foothills which have already intensified the water demands in the area. Since ly, C G� JT It COUNCIL CDD DIR Jim & oyce Daly '-jo(CLERKAORIG e�AO 13 FIN DIR O ❑ FIRE CHIEF A�RNEY ❑ PW DIR ❑ POLICE CHFE3MOW TEAM 13REC DIR ❑ C READ FILE C3UTIL DIR � >tLE- aPERS DIR RECEIVED .L FEB 5 1996 CITY COUNCIL WX Ll II$OBISPO.CA II III cit Of SAn tuis oaspo 990 Palm Street, San Luis Obispo, CA 93401-3249 MEMORANDUM MEETING AGENDA DATE�ITEM # TO: City Council Members '4 VIA: John Dunn, City Administrator FROM: Arnold Jonas, Community Development Director ®r , o , BY: Ron Whisenand, Development Review Manag DATE: February 1, 1996 SUBJECT: Staff Report Correction The two words"experience delays." were inadvertently deleted from the end of the last sentence on page 5 of the report for the appeal of the Froom Ranch environmental determination-public hearing item#4 for the February 6 Council meeting. F NCIL DD OIR❑ FIN DIR O ❑ FIRE CHIEF ORNEY ❑ PW DIR RXJ=G ❑ POLICECHF Wr TEAM ❑ REC DIR AD FILE ❑ UTIL DIRI.i'. �� ❑ PERS DIR RICE1VED FEB 1196 96 .. QWV eL?lc: Z SAN LUIS(313ISPO,CA teO, The City of San Luis Obispo is committed to include the disabled in all of its services, programs and activities. Ly Telecommunications Device for the Deaf(805)781-7410.