Loading...
HomeMy WebLinkAbout04/12/1996, 1 - SAN LUIS OBISPO AREA PLAN UPDATE - CONSISTENCY WITH CITY GENERAL PLAN C D PY �ill�ll�llllll�ll������;��IIIIIIII�III1111lIIlI� III cityof sAnoaspoX15 990 Palm Street, San Luis Obispo, CA 93401-3249 January 2, 1996 County Planning Commission County Government Center San Luis Obispo, CA 93408 Subject: San Luis Obispo Area Plan Update - Consistency with City General Plan Honorable Commissioners: We appreciate the opportunity to review and comment on your draft update. Citizens of San Luis Obispo will feel the effects of land use decisions made by County government. The City is committed to achieving consistent plans for our two agencies. Our staffs have been working for several years to do so. Your draft area plan update and the City's recently revised General Plan are very similar--more so than our agencies' previously adopted land use plans. However, your draft area plan update and the City's adopted plan have evolved through draft revisions and the public hearing process, so that there are some significant differences between them. The significant differences concern potential development within the City's designated greenbelt. The greenbelt is intended to protect natural resources and to keep sprawl from connecting San Luis Obispo with other developing communities. Residents of this city, who are also residents of the county, have expressed through our adopted General Plan their vision for future development and open space protection. To the extent that the County allows development inconsistent with the City's plan, that vision cannot be achieved. The following items identify, when appropriate, the land use designations or text changes which would make the County's plan consistent with the City's. We urge you to modify the draft so that the version you recommend to the Board of Supervisors will be consistent with the City's plan. In the following discussion, "the City's plan" means the current City of San Luis Obispo General Plan (including the Land Use Element and the Open Space Element revisions adopted in 1994). "The draft area plan" refers to the San Luis Obispo Area Plan Public Review Draft (January 29, 1993). Specific inconsistencies are noted in the attached lists. We have grouped similar items together. Groups A through D primarily involve consistency of land use designations and other mapping concerns. Group E involves consistency of text policies. Group F is a list of technical items which may be helpful mainly for your staff. V�re, The City of San Luis Obispo is committed to include the disabled in all of its services, programs and activities. Telecommunications Device for the Deaf(805)781-7410. County Planning Commission SLO Area Plan Update Page 3 The City's .Public Works Department is providing_ separate comments on .the draft area plan Circulation Element (Chapter 4): Please contact Glen Matteson of this department (781-7165) if you have questions on the items covered in this letter. Sincerely, Arnold B. Jonas Community Development Director copy: John Dunn, City of S.L.O. CAO Comparison of City and County Plans Page 1 • h - ti • . :- • '. . ¢.•-'r at �Itw:�ti%I,�• •.•~•• � /•' _ i _. r l�l••�.•�/•`a:. j��k u rLL�_.:6..... -0k:'' `may'` � � , `,�E{!I� ti::tiff•:'•• '♦ �•. ' \r. i rff}r}ffn. }• I.r• a7 t�\ ,�'i - V f IL v°q�f• ••••• 'f0. •'•yffff� ''rii.:y '::. ji ••••• .. �. •'. v::;• •::?r......:{....ff'} ' _ •i i• O 04 O O O O O • Ji••• .. 4444404 :moi.[ r' •••••••••••.••••••••••�•• • ••. .a'. r ......... .•..••....... . ..• •. Ji �� /� ••••••• •••••••••••••• •••• +"r , `�'l• •: • i i i i i i i i i• i•i i i i ii iii e iii• :" •••••• ••••••••••••••• 060 � ••••••••• • ••: 11' x' • iiiiiii.i.0X.- •i i•• ii• iiiiiiii r fir' ••e•••••••• •••• •••• •�• •a••�i i i�i i r •••••••••••••• • ••.00•• O O 40 • e... a•• � O i iii• •ii•i Comparison of City and County Plans Page 2 Map Items The following items involve location of the urban reserve line and land use designations. The first group is numbered on Map A, which is taken from a map in the County's draft area plan, titled "Land Use Categories," an unnumbered fold-put page which shows the entire, immediate San Luis Obispo area. Where the City's urban reserve line location differs from the County's draft area plan, inside the city, the City's line is shown dotted. The County has a convention of not locating an urban reserve line inside the corporate limits of a city. San Luis Obispo's urban reserve line is defined as the outer boundary of eventual urban development, which in some areas does not extend to the city limits. This difference is not seen as a major policy conflict. The City's urban reserve line location has been shown for your information. A.1 Santa Lucia Foothills Here, the City's urban reserve line differs from the draft area plan for areas outside the city. The City's urban reserve line in this area results from the "hillside planning program" and is based on steepness of slope and water service elevation. The City's plan shows the area outside the urban reserve line as Open Space. Draft area plan designations are Residential Single Family and Public Facilities. A.2 Orcutt Area The City's plan excludes land east of Orcutt Road from the urban reserve, while the draft area plan shows it within. The draft area plan shows the included land as Residential Single Family. The City's plan designates it Residential Suburban. A.3 Broad Street Annexation (Airport area) This annexation has been completed, so the County will not designate land uses. A.4 Stoneridge Annexation ' This annexation has been completed, so the County will not designate land uses. A.5 T-K Annexation (Airport area) This annexation has been completed, so the County will not designate land uses. A.6 Froom Ranch (Irish Hills area) The City's plan shows the urban reserve line enclosing some additional land, opposite Auto Park Way, designated General Retail. ry -,� M FA id HIRE IWOFA ��'►`�11A�o � Mama pp . 4 Comparison of City and County Plans Page 4 A.7 Froom Ranch (Irish Hills area) The draft area plan shows this area as Residential Single Family. The City's plan designates it as General Retail. The closest County designation would be Commercial Retail. A.8 Devaul Ranch (Irish Hills area) The draft area plan shows this area as Residential Single Family. The City's plan designates it Medium-Density Residential. The closest County designation would be Residential Multiple Family. A.9 Madonna Inn (Cerro San Luis area) The City's plan shows the urban reserve line enclosing additional land between Cerro San Luis and the rocky hill east of Laguna Lake, designated Tourist Commercial. Appropriate development for this "special design area" is described beginning on page 81 of the City's plan. The draft area plan shows it as Agriculture. The County designation closest to the City's plan would be Commercial Retail/Visitor Serving (Table 7-1 of the draft area plan). The following items involve,land use designations in the Airport Area. This group is numbered on Map B, which is taken from the County's draft area plan map titled "San Luis Obispo Airport Area - Proposed Land Use Categories," an unnumbered fold-put page. The cross-hatched areas have been annexed by the City and need not have County designations. B.1 Sunderland Property - Highway 227 at Buckley Road The draft area plan shows this site as Industrial. The City's plan shows it as Open Space. The closest County designation would be Agriculture or Rural Lands. It is our understanding that several years ago the County changed the designation of this site from Agriculture to Industrial to accommodate a grading business that had been improperly established in the Agriculture designation. B.2 North of Aero Loop (APN 076-401-038) The draft area plan shows this site as Commercial Retail/Visitor Serving. The City's plan shows it as Services and Manufacturing. The closest County designation would be Commercial Service or Industrial. The City determined that adequate space for visitor- serving development could be provided by the adjacent land to the south, which the City's plan shows as Tourist Commercial. �-O Comparison of City and County Plans Page 5 B.3 "Hidden Hills" area The draft area plan shows this area as Residential Multiple Family. The City's plan shows it as Services and Manufacturing. The closest County designation would be Commercial Service or Industrial. At one time, the City's draft Land Use Element update also showed this area as residential. This designation was seen as a way to help tenants of the existing mobile home park become owners, and to provide additional residential capacity that would improve the areawide jobs/housing relationship. In adopting its update, the City determined that, considering noise and traffic exposure, the area should not be residential. B.4 Margarita Area (Garcia Ranch) The indicated boundary between residential and recreation designations would more closely reflect the boundary shown in the City's plan and the most recent draft of the Margarita Area Specific Plan. B.5 Margarita Area (Martinelli property) The draft area plan shows this area as Commercial Service. The City's plan shows it as Open Space. The closest County designation would be Rural Lands. The City's designation reflects wetlands. B.6 "Log Cabin" area The draft area plan shows this area as Commercial Retail. The City's plan shows it as Services and Manufacturing. The closest County designation would be Commercial Service or Industrial. City policies call for retail uses to be grouped in other areas. The following items involve map designations outside the urban reserve, as reflected in the draft area plan. This group is numbered on Map C. The following are not consistent with the City's plan, which says development potential for area outside the urban reserve —the greenbelt— should be increased only as part of a cluster approach involving permanent open space protection. The City requests that the County not intensify residential entitlements or designate new village area within the greenbelt. C.1 Rolling Hills area The draft area plan refers to this area on pages 5-8 and 5-9 (Figure 5-1), where it is identified.as a potential future Residential Rural designation. C.2 Bear Valley area The draft area plan refers to this area on page 5-20 (Figure 5-4) and 5-21, where it is identified as a potential future City residential expansion area. �- 9 Comparison of City and County Plans page 6 § a x � r C ` } Y i •{ 5 E{ L L k r a42 C r fx Z ,st � 8•, ::t F ry K's• a t s.. s f d yY •: L .{ : F F �ii :i.S Cf3 : a to� f x i • { L f C x t i i �a f aAf.+wax(m'w. f r ' IM } r R . •L. F E. r • [ k c F c xx y s r s 3 d < s f F L r � f rt�9' s G3L CY Lh \Q 3 k k a s1 C f RYE `' 7sv�- ti `y rtrssi 4 5 O w \ _ r� kY3 E �f ?7�� ' 7F.f• Y L..23 A s'� .. T b x � 2 r 3.L seg x' x�z. R rtf F _ �+ ... k x�§ �..f 2 N Ya g 3 SAN LUIS . iL OBISPO f F •acQ� � tx yr,E s x 2 y w F<�ax�` x"r. �.u}x•�CY7��,��tr�'� Lf wis $•''�}'�°cxi3k QSi �. I+D.�xy F 5, E 33 k S s � t s#� A�kkS.<F4' xiatLj lY ua�ceSyY fy rE ri 3 } �'z 227 s + c > v a a xa�f # ,k k s ss k a F 8 �.t'.n �r S c � ak w'S�^rL�r Lo•3'rl = 4 x� rs,... :. {"�. NL �\' Q \V£+ hb5. fRFaf LF YL' fC � _ L s NsaF 7sf3,^a sF kA�ttA }a E3, ) FR2 M f ri'Su ? A a 3 i RL. c >fyb..y w, x Rv . 'k'.x^. [a QLyF. 4 .Q2 ,+,�� 3' < , ,. R y C 2• SCH.EnLtLI . ;Ere �' sk s =� �Qf;�kyr5�sef a� r � B1rACH : f Fr.. L r �,.�� Z S3 � f � • '1 w. PACIFIC s'RF 5 ` xi n a OCEANPICCS..M�++O a � r £ ysa L' rtw SAN LUIS OBISPO PLANNING AREA clay Of SAN LUIS OBISPO san Luls Os1spO PLANNING BOUNDARY 9/9/94 Comparison of City and County Plans Page 7 C.3 O'Connor Way area The draft area plan refers to this area on pages 5-7, 5-9, and 5-20 (Figure 5-4), where it is identified as a potential future City residential expansion area. While the possibility of more intense "village" development was considered during the City's Land Use Element update, the City's adopted plan reflects only the Residential Rural and Residential Suburban designations of the County's adopted plan. CA Los Nomadas The draft area plan refers to this area on page 5-12 (Figure 5-2), where it is identified as a potential Recreation designation. The proposed project, described in the highlighted text, would not be consistent with the County's Goal #1 (page 5-2) or the City's intent for the greenbelt as described in the Land Use Element and the Open Space Element. C.5 Righetti Ranch area The draft area plan refers to this area on pages 5-20 (Figure 5-4) and 5-21, where it is identified as a potential future City residential expansion area. The following items are map amendments being considered with the area plan update, though they were not proposed by the County and do not appear in the Public Hearing Draft maps. This group is numbered on Map D. The following are not consistent with the City's plan, which says development potential for areas outside the urban reserve --the greenbelt-- should be increased only as part of a cluster approach involving permanent open space protection. D.1 Bunnel property covering the northeast section of Bishop Peak: 200 acres from Agriculture to Residential Rural (citizen request site #39 in area plan update EIR). D.2 East airport area, between Highway 227 and La Lomita Ranch: 85 acres from Agriculture to Commercial Service, and 52 acres from Agriculture to Residential Suburban (area #19 in area plan update EIR). D.3 Bryn, Forest & Martinelli property, between the airport and the Los Ranchos area: 63 acres from Agriculture to Residential Suburban (area #26 in area plan update EIR). DA Maddelena property, south of the airport: 81 acres from Agriculture to Industrial (area #28 in area plan update EIR). D.5 Los Ranchos Associates property, southwest of Los Ranchos development: 214 acres of Agriculture and 80 acres of Rural Lands to Residential Rural (area #27 in area plan update EIR). Comparison of City and County Plans Page $ fi \ ; a = k 5 Q ,f k # t _ c . • 'x s r x' k � s 5 Y 3L 1�1 Q i 3 C V Q x ti. •f k < C R ssE' y ti d � # •5 � 3C L rc z = 3 f h s sr a x's 15100, r s R s u" ` #nl _ n Or YA q f _ a x ^ i. s : SAN LUIS s OBISPO ,uw 3 3 x+ 6a �' .:y0c,.P.....`meeQm�e...r.9,..,........u. 's Rn: X• = i..Q:r..xc�fis�+.: .+vs: ..x:..:.R:.o . ',r�„ _ $✓ao�fi �^° '.•�snF�n�as xg,. n,s• a ,C`'s`� 6 � �Q 3'm.a. x, �# n-g :. 2 xc x wF wQa,.n rqM- "Y w m a '3F Q $ G falx • qx..}R� i 6r�. � `L��•a�i� hatz�`�`��a swL � #'z��. Q ,.. s• 5' .3 'c:. 227 44 F fi Q BEACH a k , Rl f �'::A, ""# L' � : L \ hf Z < SHELL r 5 x„ N . BEACH b L x 'S As L u 5T x PACIFIC\ PISMo2 Y 4 5bY 3 v k f u F OCEAN R BEACH x � , SAN LUIS OBISPO PLANNING AREA 14J.1 ti;; SAN LUIS OBISPO san LUIS owspo ---- PLANNING BOUNDARY 9/9/94 Comparison of City and County Plans Page 9 D.6 Avila Ranch, south of "TK annexation" and airport area: 60 acres from Agriculture to Industrial (area#30 in County's S.L.O. Area Plan update EIR). Note: this proposal was later revised to change 10 acres to Public Facility and 170 acres to Industrial. Neither proposal is consistent with the City's designation as Open Space. (The draft area plan EIR did not evaluate the enlarged proposal.) D.7 Polin/Caltrans site, west of the Buckley Road-Vachell Lane bend: 10 acres from Agriculture to Commercial Service (area #29 in area plan update EIR). D.8 Filiponi Ranch, west of Highway 101 and south of Calle Joaquin: 91 acres of Rural Lands and 100 acres of Agriculture to Residential Rural (area #31 in area plan update EIR). D.9 Madonna/Froom property, west of Los Osos Valley Road and Calle Joaquin: about 80 acres from Agriculture to Commercial Service (area #33 in area plan update EIR) —this is in addition to area shown for development in the City's plan. D.10 Emerald Hills flatlands, west of Los Osos Valley Road and north of the city limits; this is also the site of a previous County application (area #32 in the area plan update EIR). D.11 Stoyka property, between O'Connor Way and the northern flanks of Bishop Peak: 132 acres from Agriculture to Residential Rural (area #36 in the area plan update EIR). D.12 Madonna/Foothill area, between Foothill Boulevard and San Luis Mountain: 30 acres from Agriculture to Residential Multiple Family (area #37 in the area plan update EIR). Text Items The following items involve text policies. E.1 Page 5-15, item 2; and page 5-17 (Figure 5-3); page 5-28, item 4: The City's plan does not include an equivalent phasing approach for annexations. Completed annexations have occurred in the first and third categories, and are pending in all three. If Figure 5-3 is kept, it should be revised for consistency with the City's urban reserve line and completed annexations (items A.1 through A.6 and A.9 above). E.2 Page 5-15, item 2 and item 3.a last sentence: The City's plan does not have a horizon date. In anticipates build-out would occur around the year 2022. E.3 Page 5-18, paragraph 4, first sentence: A statement consistent with the City's plan would be "Urban expansion areas within the urban reserve line include land designated for commercial and industrial development, and for residential neighborhoods composed of a range of housing types and supporting uses such as schools and parks." (Reference City Land Use Element Figure 2 and policy 2.3.3.) /-�3 Comparison of City and County Plans Page 10 EA Page 5-19, paragraph 2: The policy relationship between annexations and service capacities is difficult to summarize, so the reference to "city service capabilities" is best deleted. The ideas stated in items a, b, and c are still the basis for such minor annexations, but the term "minor expansion areas" and the listing of these three criteria have been deleted from the City's plan. A statement consistent with the City's plan would be "The city's General Plan can accommodate annexation of relatively small areas at the city's edge, within the designated urban reserve or minor extensions of it, when the resulting projects provide open space protection or other public benefits." E.5 Page 5-19, last paragraph: Note that the reference to Commercial Retail is not consistent with the City's plan map (item B.6 above). E.6 Page 5-21, paragraph 2: For awhile, the City's Land Use Element update considered identifying potential residential development areas beyond the designated urban reserve. This approach was not included in the adopted plan. The areas shown on draft area plan Figure 5-4 (page 5-20) are part of the City's designated greenbelt, where the City's plan says development potential is not to be increased, except as part of the prescribed clustering approach. The draft area plan would be made consistent with the City's plan by deleting the shaded paragraph. E.7 Page 5-21, paragraph 4: The area described in this paragraph has been annexed (and the development proposal has changed), so it can be deleted. Also, "additional" could be deleted from the beginning of the next paragraph. E.8 Page 5-24, paragraph 3: According to the City's plan, the County functions listed in paragraph 2, along with administration and voter registration, should remain in or close to the downtown Government Center. Therefore, to be most consistent, the paragraph referring to the Prado Road site should have a limitation on "other uses" that could be relocated to Prado Road. E.9 Page 7-9, item D.La: The reference to nonagricultural development on the La Lomita Ranch is not consistent with the City's plan (item C.4 above). E.10 Page 7-21, items E.La and b: The City's General Plan and Municipal Code do not allow City water or sewer service to properties outside the City, except for those with prior agreements, so it is not consistent to suggest that "developments not projected to be annexed into the city prior to 2013" be provided these services "through the city." The following are suggestions for technical, grammatical, and style changes to make the document more accurate and more clear. F.1 Page 1-2, paragraphs 2 and 3: "quality jobs" needs an adjective, presumably "high." Comparison of City and County Plans Page 11 F.2 Page 1-2, paragraph 3: Unless there are state and national conditions which would not allow local agencies to at least influence the future of the area, consider rewording the fust sentence. F.3 Page 1-2, paragraph 3: The sense of "stall" in the last sentence is not clear. Economic health can exist at various levels of activity. If the natural environment is to be protected, at some point we will reach a state of sufficient economic activity. Consider expanding this discussion to include the concept of sustainability. F.4 Page 1-3, item 7: Reword to read "Focus employment and housing within the San Luis Obispo urban area, so workers can be near affordable housing that allows getting to work by walking, biking, riding the bus, and carpooling." F.5 Page 3-2, paragraph 2: Suggest the first sentence read "Incorporated cites are responsible for land use planning and providing public services to all j&§IN areas within their city limits belies." F.6 Page 3-4, paragraph 5: The state water allotments can be updated. F.7 Page 3-5, paragraph 4: The summary of the City's water situation can be updated as follows, based on the adopted Urban Water Management Plan: "At the expected long-term consumption rate of 145 gallons per capita per day, the 1995 City population needs about 7,130 acre-feet per year. The 1995 combined safe yield of surface and groundwater sources is 7,725 acre-feet per year. The anticipated City build- out population of 56,000 would result in a water demand of 9,096 acre-feet per year." F.8 Page 3-6, paragraph 1: Under what circumstances will expansion of existing land uses be required to prepare water management plans? Within the City, additional development is contingent on obtaining additional water supplies or offsetting added demand through retrofitting existing water users. F.9 Page 3-6, paragraph 2: Update to reflect rejection of state water by the City, and the expansion of CSA 22 powers to include water service. F.10 Page 3-7, paragraph 1: spelling "assigned." F.11 Page 3-9, paragraph 1: spelling "school." F.12 Page 3-9, paragraph 4: Update to reflect increasing college enrollment. F.13 Page 3-11, paragraph 2: "its" in place of "their," and spelling of "time." F.14 Page 4-1, paragraph 2, last line: covered. Comparison of City and County Plans Page 12 F.15 Page 5-1, paragraph 5: Suggest the next to last sentence read "Additionally ... housing in the city being more expensive than in suffeending RNMW communities." While Los Osos and north county housing remains less expensive, other county coastal towns are about equal to San Luis Obispo. F.16 Page 5-3, Goal #3: This statement is consistent with the City's statements (goal #16 and policy 1.4). However, depending on the map changes which are eventually agreed on, the following description of jobs and housing conditions may not be accurate (note mainly items A.7 and B.3 above). F.17 Page 5-7, paragraph 1: Consider referring to County "stewardship" rather than "operation" of the top of Bishop Peak. F.18 Page 5-7, paragraph 4: Note redundant phrase concerning rural character. F.19 Page 5-14, throughout: references to using state project water can be deleted. F.20 Page 5-16, item c: It is not clear what area is meant by "the remainder of the urban reserve." This could be taken to mean areas which have not been annexed, or to imply that there are areas not shown in the annexation phasing map. F.21 Page 5-18, paragraph 2, last sentence: Add "be" after "should" and delete "more" after "other." F.22 Page 5-22, paragraph 1, line 2: "and someofficesl are... 5..:,....... F.23 Page 5-25: The discussion of Cal Poly enrollment has been outdated by further changes . in the State budget, with enrollment expanding again. It's probably best to refer to approved campus master plans for future enrollment. F.24 Page 5-29, item 6: Should the reference be to Table 5-3? F.25 Page 6-3, paragraph 1, sentence 2: "These areas ... identification of groups c 'trees and individual trees ... such farm houses and barns." F.26 Page 7-4, item 2, sentence 2: "The primary purpose ... important views; natural landmarks and scenic backdrops, leeatiens e€important ..." F.27 Page 7-8, new text below Figure 7-2: It appears this should be item "f' rather than "e." Also, shouldn't the title refer to the southeast city limits?" F.28 Page 7-22, item h: spelling "textile products." APU-LUE.LTR GM 12-12-95 ��IIIIIIIIII�IIIIIII�II���I��;����llll�IIIIIIII IIIII City Of $An tuiS OBISPO 955 Morro Street • San Luis Obispo, CA 93401 January 9, 1996 Mr. Dana Lilley, Senior Planner County Planning and Building Department County Government Center San Luis Obispo, CA 93401 Dear Mr. Lilley: On behalf of the San Luis Obispo Public Works Department, I have reviewed the public review draft of the San Luis Obispo Area Plan (dated January 29, 1993). My comments are listed below. If you have any questions or need clarification of the comments, feel free to contact me at 781-7178. 1. (Page 4.2, paragraph 2) The draft plan states that SLOCOG will be preparing the State-required congestion management plan, as well as trip reduction ordinances. Given the enactment of recent State Law, it is unlikely that the COG will be preparing trip reduction ordinances. 2. (Page 4.3, Goal 2, last sentence) The terminology"trip reduction ordinances" should be changed to be consistent with the new terminology used in the Clean Air Plan Update. 3. (Page 4.5, Objective Lb) In residential areas throughout the County people have expressed concern for excessive traffic speeds and, in some cases, traffic volumes. Objective Lb should be modified as follows: b. Mitigate or avoid traffic impacts to residential or other sensitive land uses by establishment of appropriate truck and bus routes, speed limits and traffic calming measures. safety and sound barriers, lighting and landscaping, and residential street design standards applicable to new development that achieve.{ vehicle speeds 121 25 mph or less. 4. (Page 4.5, Objective 3.a) The City has adopted a transportation impact fee program that applies to all new development. The amount of the fee was based on how new development within the City's Urban Reserve contributes to traffic growth and the cost of transportation projects needed to serve new growth. /O The City of San Luis Obispo is committed to include the disabled in all of its services, programs and activities. ® /—/7 r Telecommunications Device for the Deaf(805)781.7410. In general, within the.City, developers are required to install frontage improvements or build roads needed to serve their projects and pay the traffic impact fee to support off-site improvements to the transportation system (including traffic signals, transit and bicycle improvements). The County should consider a similar strategy applicable to development within the City's Urban reserve, if it occurs prior to annexation to the City. The "proportionate share" strategy suggested by Objective 3.a can be cumbersome to establish and administer. An alternate simplified objective might look like the following with the details to be worked out later: a Based on an agreement between the City and County, the County should establish and administer a transportation impact fee program applicable to all unincorporated areas within the City's General Plan Urban Reserve Establishing such a joint program is appropriate since traffic from development within the unincorporated urban reserve area (especially within the airport area)will impact City areas and vice versa. 5. (Page 4..6, Objective 4.c) Both SLOCOG (as part of the Congestion Management -Plan) and the City of San Luis Obispo are involved in computer-based modeling techniques. Objective 4.c might be changed to suggest a cooperative effort between these three agencies. For example: C. The County, SLOCOG. and the City of San Luis Obispo should jointly develop an integrated program to utilize computer-based modeling techniques to project future service levels.... 6. (Page 4.6, Road Improvements, Paragraph 2) I couldn't find Table C referenced in this paragraph. Also, since the timing of transportation projects constantly changes based on political priorities and the availability of funding, it may be desirable to create a separate capital planning document that is part of the County's budget rather than including a specific schedule within the Area Plan. 7. (Page 4.7, Changes to Principal Arterials) The following are differences between road changes recommended by the draft plan and the City's Circulation.Element, along with City staff comments: Route 101 and Route 227: The draft plan suggests that Route 101 be widened to six lanes from Avila Road to Madonna Road,while the City's Circulation Element does not. The County may want to wait for the completion of the Route 101 Major Investment Study (MIS) being prepared for SLOCOG before including specific recommendations for changing Route 101 or Route 227 in the draft plan. Los Osos Valley Road: The draft plan suggests that LOVR be widened to four lanes. The City's Circulation Element does not address segments of LOVR outside the urban reserve. However, for the segment between Madonna Road and Route 101, the Circulation Element suggests that it be widened to "Parkway Arterial"standards- - four to six lanes. Preliminary studies indicate that six lanes may be needed with full commercial development of the adjoining Froom Ranch property(an annexation and development application is being processed by the City). Prado Road: The draft plan suggests that the segment of Prado Road from the City Limits to Broad Street at Industrial Way include bike lanes. The City's Circulation Element recommends that this street segment be developed as a"regional route" and include Class I bike paths and bridges for wildlife corridors.The City's Element also recommends that Prado Road between Broad Street and Route 101 be designated as State Route 227. . South Higuera Street: The description of the proposed changes are a bit confusing but easily clarified by changing the second sentence to read: The roadway should be maintained as two-lanes with two bike lanes from the proposed intersection with Buckley Road to Ontario Road.. Price Canyon Road: The text should acknowledge the need to add bike lanes to the eastern segment of Price Canyon Road from the oil field area eastward to Route 227. Calle Joaquin: The draft plan suggests that Calle Joaquin be extended from Madonna Road parallel to Route 101 to connect to Los Osos Valley Road. The City's Circulation Element does not include this project. The City's Circulation Element instead suggests that: As part of any proposal to further develop the Dalidio-Madonna-McBride Area, the alignment and design of a road connecting Prado Road (west of Route 101) with Los Osos Valley Road shall be evaluated and established The City's Circulation Element acknowledges the need for a connecting road but does not specify an alignment or design. The Calle Joaquin alignment is one option that will be considered. However, preliminary studies indicate that extending Calle Joaquin to LOVR could introduce more traffic to an already-congested interchange area and that other alignments for a connecting route may be more appropriate. Other Streets: The City's Circulation Element includes the following street projects located outside current City limits but within the urban reserve that are not shown on the draft Area Plan: -- Bullock Lane: extend as a two lane "Collector Street" between Orcutt Road and Tank Farm Road east of the railroad. 3 -- Prado Road: extend west of Route 227 to Madonna Road through the Dalidio Property as an "Arterial Street". -- Santa Fe Road: extend directly northward as a "Collector Street" to connect with Prado Road (extended). The bend at the northern end of Santa Fe Road would be eliminated and a new intersection location created at Tank Farm Road. 8. (Page 4.9, Other Transportation Modes, Introduction) The introduction might also note the creation of"Ride-On Transportation Management Association" and identify the services that they provide. Also the text should be updated to indicate that CCAT has created a route between San Luis Obispo and Santa Maria. 9. (Page 4.10, Objective lb) This objective suggests that the City provide transit service to the County Airport which is within the City's urban reserve. The City's Circulation Element states that "public" transit service should be provided to the airport-as soon as possible. If the territory adjacent to, and north of, the airport is annexed to the City, it would be a logical step to extend service to the airport. Serving the airport area itself will require a significant reconfiguration of the City's transit routes. Extending transit service to the airport prior to annexation of adjoining areas could cause problems with the City's existing routing and headways. However, funding continues to be the single greatest obstacle to any expansion of service -- especially those beyond City limits. If the County would be willing to support the extension using County TDA revenues, service to the airport might be accelerated. 10. (Page 4.10, Objective Ld, Page 4.11, Objective b) Newly-enacted State law precludes local agencies from adopting employer-based trip reduction ordinances or programs. A rewording of this objective to be consistent with terminology used in the updated Clean Air Plan is appropriate. 11. (Page 4.10, Suggested Added Objective) The City's Circulation Element suggests that within the urban reserve, multi-family and employment-intensive land uses should be located within 1/8 mile of a transit route. This should be included as an. additional objective within the draft plan. 12. (Page 4.12, Bikeways) The following comments identify differences between bikeways proposed by the draft plan and the City's Bicycle Plan: Class I Riparian Route: The draft plan recommends a Class I route along the riparian corridor south from Broad Street to Buckley Road. The City's Bicycle Plan suggests that this bikeway continue south of Buckley to link.with a bike path along SLO Creek south of the City. 4 /-d?0 Route 227: The draft plan recommends Class II bike lanes from Higuera Street to Arroyo Grande. The City's. Bike Plan shows Class II lanes from South Street southward. Further study of the segment of Broad Street between South Street and Higuera Street is needed, since the installation of Class II bike lanes could require the removal of a significant amount of curb parking. Other Routes: The following additional Class I routes that are recommended by the City's Bicycle Plan should be included in the draft area plan: Class I paths along riparian corridors between Orcutt Road (within the City's Urban Reserve) and the Southern Pacific Railroad. Class I paths that links the Margarita Expansion Area over South Street Hill to Exposition Drive. Class I path paralleling the west side of Route 101 between Broad Street and Madonna Road. Class II bi%e lanes on Prado Road (including new segment) from Higuera Street to Madonna Road. 13. (Page 4.14, Rail Service, third paragraph) This paragraph should be updated to recent extension of the San Diegan from Santa Barbara to San Luis Obispo. 14. (Page 4.16, Additional Program) The City's Circulation Element recommends that SLOCOG initiate a Major Investment Study (MIS) for addressing the traffic needs of regional corridors that serve east-west traffic between San Luis Obispo and the coast. This study would evaluate: Reconstructing the Santa Rosa Street interchange to . improve Route 101/Route 1 connections. Widening Santa Rosa Street (Route 1) to six lanes between Olive Street and Foothill Boulevard. Constructing an underpass or an overpass at Foothill Boulevard and Santa Rosa Street to reduce intersection congestion. Constructing a reliever route for Route 1. SLOCOG has included this study in their work program for FY 1997-98 and has suggested that the County, SLOCOG and the City share in the cost. This program should be included in Table 4.1. 5 15. (SLO Circulation Map in Back of Report) Also, the City recommends that the extension of Prado Road from Broad Street west to the City limits be designated as Route 227 which would imply that it would be a "principal arterial .route. Segments for Broad Street north of the Industrial Way intersection may be changed to an "arterial' route once the Prado Road extension is accomplished. We appreciate the opportunity to review the draft Area Plan for San Luis Obispo. Respectfully, Terry Sanville, Principal Transportation Planner City of San Luis Obispo Public Works Department c: Mike McCluskey, Public Works Director Glen Matteson, Community Development Department nAs/sloPlan . 6 l_�� ���o�►������i�ii���������������������►��������� ���� cityo SAn lues oBispoIAN 990 Palm Street/Post Office Box 8100 San Luis Obispo,CA 93403-8100 October 20, 1995 John McKenzie, Environmental Division County Government Center San Luis Obispo, CA 93408 Subject:' Comments on Draft EIR for S.L.O. Area Plan Update (ED. 93-029) Dear Mr. McKenzie: Thank you for making the draft EIR available for our review. Our comments are attached. Nearly all of them address informational items that do not affect the report's overall conclusions. The City's Public Works Department is reviewing the EIR section on transportation and circulation, and intends to provide comments next week. We will send a separate letter, concerning the content of the update itself, to the Planning Division. Please contact Glen Matteson (781-7165) if you have questions on the items covered in this letter. Sincer y, old Jonas Community Development Director copies: John Dunn, City of S.L.O. CAO John Moss, City of S.L.O. Utilities Director Mike McCluskey, City of S.L.O. Public Works Director nThe City of San Luis Obispo is committed to including the disabled in all of its services,programs and activities. City of S.L.O. Comments on Area Plan EIR Page 1 Item Page Par Comment 1. 2-3 No # We appreciate the EIR evaluating consistency with the City's adopted policies. Concerning inconsistency of Airport Area nonresidential buildout, the reference to the City "retaining control" is confusing, since the City will not have jurisdiction over the area unless it is annexed. A more accurate summary statement would be "Buildout of the nonresidential designated part of the Airport Area could preclude development consistent with the City's planning policies and standards." 2. 2-5 WR-1 Concerning mitigation for groundwater overdraft, there is no requirement or mechanism in place to assure coordination with the City. Authorities on this matter appear to agree that adjudication of a groundwater basin and establishment of a basin-wide authority are the only effective mitigations. for this particular aspect. Concerning alternative surface water sources, the capacity of the State Water distribution system as it is being built limits its potential to serve parties (locations) which have not already contracted for service. 3. 2-8 BIO-2 Concerning runoff water quality, ideally all projects involving toxic & 2-21 materials --not just those adjacent to streams or wetlands-- should be designed to retain spills on site. (Apparently, this is a code requirement but it is not consistently enforced in unincorporated areas.) The situation in areas with undeveloped land between project sites may be less severe than in the city, where spills can quickly move through storm drains to creeks. On the other hand, soil and groundwater contamination could be more likely in areas with less continuous pavement and structures that allow spills to be more effectively controlled with "block and absorb" methods. Concerning the design of retention basins and grease traps, engineers often distinguish between retention basins, which keep flows on site, and detention basis, which avoid or delay peak outflow of storm drainage. Is this measure intended to apply to both types? Also, the measure might be seen as more practical if it were reworded so that basins and traps are "designed so contaminants carried in runoff from the first inch of rainfall from any one storm are retained..." (Grease traps typically skim a small volume off the total volume passing through.) 4. 2-9 No # Concerning wetlands conversion on the Dalidio property, we are not aware of any wetlands on the contiguous Dalidio-Madonna-McBride properties, other than the corridor of Prefumo Creek and the small, unnamed creek east of the Postal Service Facility, which would be protected as open space under the City's adopted policies. City of S.L.O. Comments on Area Plan EIR Page2 Pae Item Comment 5. 2-12 WR-1 See item #2 above. 6. 2-13 b Widening California Boulevard to four lanes is not included in the City's Circulation Element. Also, it is not in the adopted Regional Transportation Plan (which is dated 1994). 7. 2-15 N-11 We are not aware of a 44-acre part of the Airport Area that is proposed to be designated Rural Residential. The mitigation refers to "high density residential." The City's Land Use Element shows open space, park, and commercial designations within the area having unacceptable noise exposure for residential uses due to SR 227 traffic. (A draft of the City's Land Use Element update showed Medium-density Residential for the area to which this mitigation probably refers; the adopted plan shows Services and Manufacturing. We will soon provide in a separate letter additional information on inconsistencies between the City's adopted Land Use Element and the County's Public Review Draft S.L.O. Area Plan update.) 8. 2-18 WW-2 The City's General Plan and Municipal Code do not allow City sewer service to properties outside the City, except for those with prior agreements. 9. 2-19 DWQ-1 See item #3 above. 10. 3-9 thm The completed Stoneridge, Broad Street, and "T-K" annexations will 3-15 modify the maps and tables describing land use designations, but not in ways that substantially change the impact analysis. 11. 3-19 3.5.1 For most readers, the second sentence would be more clear if it said "Thus, buildout in the tiri np r i. rate8 Urban Area would be substantially lower p eF(' °s:qty It s ;c o than one would expect based i! on the eag devel�astet I capacity of the proposed land use designations." Note that the last paragraph on page 3-24, fifth sentence, contradicts this conclusion by saying nonresidential development would be similar under County or City jurisdiction. 12. 3-21 3.5.3 Is the County Operational Center outside the framework of the County's plan for the area? 13. .3-21 3.5.3.1 Fourth and last sentences: Cal Poly apparently will increase enrollment by about 2,000 students over the next three years. Fifth sentence: Does this mean to say that existing or planned campus facilities are adequate for 20,000 students? /r� City of S.L.O. Comments on Area Plan EIR Page 3 Page Item Comment 14. 3-25 3.7.1 This table may understate existing and buildout populations. According to the SLOCOG 1992 Regional Profile, there were 54,161 residents in the S.L.O. planning area in 1990, while this table shows 47,451 for existing conditions. Is the discrepancy due to CMC inmates or other group- housing residents not being counted? 15. 5.1-6 Concerning land use compatibility impacts for the airport area, are there policies in the area plan update that would support the EIR's conclusion that industrial development would be of a kind that supports agricultural k. and airport operations? Except for the airport facilities themselves, past industrial development seems not to be related to agriculture or the airport. 16. 5.1-7 5.1.1.3.a If the area plan update's designations for the Dalidio Area are similar to the City's, about half the area is shown for nonagricultural uses, so it would not remain "largely in its current agricultural state." 17. 5.1-10 5.1.2.4.a The former Los Nomadas resort proposal is no longer active. A development like the previous proposal would not be consistent with the City's General Plan. 18. 5.1-13 1 Perhaps by trying to summarize too much, this paragraph is not accurate. City policy and code require annexation before City sewer service, is provided, so the statement that "sites not slated for annexation must obtain city [sewer] service" has no effect. Also, depending on the meaning of "developments," how would the companion statement, that such sites alternatively "must develop a sewage disposal system with the capacity to serve 50 or more connections" apply to developments of one or two houses? 19. 5.1-13 2 The same concerns stated in comment #18 apply to this paragraph on water supply. 20. 5.1-16 a Concerning landscape irrigation for recreational uses, how will requiring a system capable of serving 50 connections —as an alternative to using reclaimed water-- reduce impacts to water resources? Is it assumed that such a system could not feasibly use groundwater, or are there standards which would prevent doing so? 21. 5.1-21 Concerning availability of transit service for further development in the Airport Area, what policy or mechanism in the area plan update would implement the referenced City policy? City of S.L.O. Comments on Area Plan EIR Page Pan Item Comment 22. 5.5-2 Concerning groundwater yield, adopted City policy is to rely on no more than 500 acre-feet per year. 23. 5.5-3 Last sentence of large paragraph: Concerning residential water usage, the City's factors are 0.21 acre-foot for multifamily and 0.3 acre-foot for single-family on typical urban lots. The pre-drought factors were 0.26 and 0.37. 24. 5.5-5 The City's adopted water usage rate for -long-term planning.results in a "normal" demand from the current population of about 7,100 acre-feet. 25. 5.5-10 5.5.2.3 Concerning City water demand at buildout, the City's adopted number is 9,096 acre-feet per year. This is based on 145 gallons per person per day and a buildout population of 56,000 (excluding the Cal Poly campus, which has separate entitlements). 26. 5.6-1 5.6.1.1 The referenced upgrade of the wastewater treatment plant (for quality of effluent, not overall capacity) has been completed, as has the water treatment plant upgrade mentioned in a previous section. 27. 5.6-4 The text says septage generation would increase by 22,800 gallons per day, while the table shows 8,000 gpd. 28. 7.3-5 Concerning the last statement on this page, while build-out may not occur during the planning period, additional dispersion of development would be likely. 29. 7.3-6 Table 7.3-2 The meaning of the note is not clear. I.v27 ��►�o�������������i �►��IIIIIIIIIIh�����►����i� lill cityo san lues oBispo 955 Morro Street • San Luis Obispo, CA 93401 October 23, 1995 Mr. John McKenzie Department of Planning and Building County Government Center San Luis Obispo, CA 93408 I have reviewed the draft EIR for the San Luis Obispo Area Plan and have focused on the section dealing with transportation and circulation. Here are my comments: 1. The "rule of thumb" capacities presented in appendix 5.2 may overestimate congestion levels. This is illustrated in Table 5.2.1 which shows Los Osos Valley Road (Route 101 to Madonna) as experiencing a "base year" LOS of "E." Recent field review done by the City's traffic engineer of this segment (using the "operations" method for base year conditions) would indicate a LOS rating of B. The City's traffic model would indicate that this link operates in the A to C range. ` r} For critical segments of roadways, where LOS standards are exceeded, field calibrations should be done to develop more accurate base line conditions -= especially if exceeding of LOS standards is the basis for suggesting road widening projects as mitigation. For example, this should be done for all segments showing a LOS D alI .3�VW on Table 5.2-3 and similar tables that follow. My bet is that the capacities need to be adjusted which would reflect on both current year and future LOS readings. 2. (Page 5.2.5, first paragraph) Using LOS C as the standard for rural roadway segments seems excessive and outdated, considering the Regional Congestion Management Plan sets LOS E as the appropriate standard for the County-wide principal arterial and state highway system. I believe Caltrans uses LOS D as a threshold for determining significant congestion problems. In rural areas, I'm not sure that LOS is a good criterion to use. Where rural routes enter urban reserve areas or village boundaries, urban LOS standards should be used (eg. LOS D as specified by the City's Circulation Element.) The EIR should comment on the range of LOS standards that are applied by affected transportation agencies, how the application of these standards could lead to different impact assumptions, and the policy implications for the County when it considers adopting the Area Plan. Maybe the Regional Congestion Management Plan's LOS standards should be applied to the CMP network (since SLOCOG will be responsible for ongoing monitoring and impact mitigation), the City's standards applied to urban reserve areas (since the City will eventually annex these areas), and the County's standards to rural routes. OThe City of San Luis Obispo is committed to include the disabled in all of its services, programs and activities. ® / �� Telecommunications Device for the Deaf(805)781-7410. 3. (Page 5.2-10, paragraph 1) The EIR should also indicate that SLOCOG has included in their workprogram the preparation of a Major Investment Study (MIS) of access options from north coastal areas to San Luis Obispo. This study is tentatively programmed for FY 1997-98 and would be a jointly funded effort between SLOCOG,the County, and the City of San Luis Obispo. See SLOCOG staff for further details. 4 (Page 5.2-10, paragraph 2) The EIR indicates a need to widen Los Osos Valley to six lanes between Highway 101 and Foothill Boulevard. This widening can not be justified for the in- city segments of LOVR between Madonna Road and Diablo Drive (forecasted LOS shown as LOS D) since the City will not consider street widenings until LOS E is reached (reference adopted Circulation Element) and other demand management strategies have been explored. Furthermore, if the segment of LOVR within the SLO is operating at LOS D, it is hard to justify that the segment between the City limits and Foothill Boulevard should be widened to six lanes given the lack of cross traffic and free flow traffic conditions. Also, the suggested widening of the "in-town" segments of LOVR does not seem consistent with the County Engineering Department's recommended LOS for urban areas of LOS "D" (reference page 5.2-12, paragraph 3). In City staffs view, the segment of LOVR between Madonna Road and Highway 101 may warrant six travel lanes -- based on proposals to construct major retail shopping centers within the City's urban reserve. The City is currently reviewing plans for the first phase of construction on the Froom Ranch property. The applicant will be required to establish sufficient rights-of- way to accommodate six travel lanes and initially widen LOVR from 2 to 4 lanes. 5. (Page 5.2-11, Tank Farm Road) Tank Farm Road is a four-lane street between Broad Street and the Southern Pacific Railroad. The Edna-Islay Specific Plan states that between the railroad and Oructt Road, Tank Farm Road should initially be constructed as a two-lane street (which it is) with enough space reserved to allow for a four-lane road. 6. (Page 5.2-14, TCM's in the CAP) The central TCM included in the Clean Air Plan was the mandatory employer-based trip reduction programs. Recent state law signed by the Governor has prohibited agencies in areas that do not exceed federal air quality standards from implementing these types of programs. The Air Pollution Control district plans to. pursue "voluntary" trip reduction programs throughout the county. However, voluntary programs have . limited impact and are hard to sustain. If the EIR counted on this type of TCM to mitigate the impacts of growth, then alternate strategies should be identified in the EIR and an estimate of their effectiveness presented in at least the same detail as the TCM's presented in the CAP. Also, if the effectiveness of trip reduction measures can be quantified, shouldn't the table that compare existing vs. future LOS have a third column which would indicate how sensitive LOS readings are to TCM implementation? In other words the three columns should be: Existing LOS Future LOS (with TDMI TSM mitigation) Future LOS (without TDM/TSM mitigation). x;29 This structure will require the EIR to quantify trip reduction for particular corridors (as opposed to the summary strategy shown on page 5.2-37) and is a valuable method of showing the potential impact of TSNMM. It is discouraging to note that the only mitigation measures that are specifically identified and quantifiable are the expensive and"impact generating" road widening projects. Given the largely undeveloped nature of the airport area (and other areas south of San Luis Obispo) and the potential tripling of traffic generation, it would seem that now is the time to apply new land use and transportation concepts that reduce the need for mobility and fosters access. Rather than leading off with capacity enhancing projects as mitigation (which lead to continued dependance on single occupant vehicles and further degradation.of air quality), a clearly defined, quantified, and more integrated mitigation program should be resented in the EIR which includes land use strategies, development standards, alternate transportation programs, incentives programs, transportation control measures, trip substitution programs, and capacity changes. The EIR should identify where within the planning these strategies should be applied and suggest standards -- at least in preliminary form -- that can be incorporated into the Area Plan and agency land development regulations. Also,the policy altemative of the County accepting LOS E as the threshold for considering capacity projects (the current City and CMP standard) should be identified. Land use strategies should not only look at the reduction in development densities and extent as mitigation (which is addressed in the alternatives section) but look at new concepts in residential neighborhood and business park design that foster trip reduction (eg. PODs and TODs). Trip "substitution" strategies should also be considered. In urban areas, it is most often the intersections and the restrictions on "green time" that cause traffic congestion on the approach links of arterial streets. Segments between intersections typically have free flow traffic. The EIR might suggest "targeted" TSM strategies to improve intersection capacity or new intersection designs that increase capacity. For example, the City of Santa Barbara and Vale, Colorado are experimenting with large "traffic circles" as a method of increasing capacity at intersections. TSM measures should be undertaken first before more disruptive road widenings are pursued. Finally, if interregional routes are widened to six lanes, consideration should be given to reserving one lane in each direction as high occupancy vehicle (HOV) lanes. Capacity enhancing project should not continue to facilitate the use of single-occupant vehicles. (A note to County planning: The Area Plan should include policies that establish a prioritized strategy for instituting mitigation measures. Since TDM/TSM programs are often more difficult to conceptualize than road widening projects, it is important to include clear priorities. At the City we have targeted alternative tranVj�ptation programs, trip reduction and education as having first priority (including funding) tb&capacity-increasing projects. The County might consider the same in addition to basic land use strategies that preclude suburban sprawl and fracturing of rural areas.) �-30 IJ 7. (Page 5.2-15, Forecasting Traffic in Airport Area) The City's traffic model assumed that there would be a significant redistribution of traffic between Route 101 and Route 227 connecting with the south county area and that the total travel demand between these two urban areas would be evenly split between these two corridors. This is a very speculative assumption and may tend to overestimate the traffic volumes on Route 227. The Route 101 MIS currently being prepared for SLOCOG should provide a more refined forecast for corridor traffic levels. The EIR consultant should contact SLOCOG and Korve Engineering for the status of this work. 8. (Page 5.2-17,paragraph I & 4) The EIR acknowledges that the City's Circulation Element shows the construction of a new interchange at Prado Road and Roaute 101 and the extension of Prado Road eastward to connect with Route 227. Has the EIR looked at the resultant LOS on Route 227 south of Orcutt Road after the Prado Road connection has been made? Do the LOS readings in Table 5.2-7 reflect these network changes? Will Route 227 south of Orcutt Road still need to be widened to six lanes if this connection is made? 9. (Figure 5.2-4) This figure is labeled "Buildout ADT Volumes" but the numbers seem to indicate existing ADT volumes. 10. (Page 5.2-17, TK Annexation) My recollection of the TK traffic study is that its "cumulative" analysis was based on forecasting traffic generated by future projects and not build out of the City's General Plan. Furthermore, the TK project and development in the.Airport area and areas west of Route 101 contribute to the need to widen the bridge over Route 101 from two to four lanes. 11. (Page 5/2-18, Buckley Road) Why does Buckley Road need to be widened to four lanes? A two lane arterial with shoulders for bicyclists can handle the forecasted 13,650 ADT especially since there is very little cross traffic and few intersections. 12. (Page 5.2-20, California Boulevard) The report indicates a base line LOS of E which seems excessive and may again reflect on the conservative capacity standards applied by the County. The City's traffic model (which involved a year-long evaluation of street capacities with field calibrations)assigned the free-flow segments of California Boulevard a capacity of 3,052 vehicles per hour (2 lanes). If we assume that pm peak hour traffic equals 10% of 24-hour ADT, than the VC ration would look like this V = 18,000 ADT x .15 = 1,800 vehicles; C = 3,052; V/C = 0.59 which is LOS A. Taking a combined reading along the corridor might result in a range of A to D. The City will make available to the EIR consultant its capacity analysis to further evaluate critical corridors within the urban reserve. In gene7ral, free flow segments between intersections have little congestion while approach segments and controlled by signals and experience greater delays. Therefore, a TSM strategy that focuses on "intersection management and enhancement" rather than road widenings would seem more appropriate. Also, I believe that the EIR consultant needs to read the "adopted" version of the RTP. I don't believe that it includes recommendations for widening California Boulevard to four lanes (reference related mitigation presented on page 5.2-24). 13. (Page 5.2-23,paragraph 4) You might check the adopted RTP concerning the options for dealing with Route 1 congestion. My recollection is that the RTP (like the City's Circulation Element) indicated the need to explore access options via the preparation of a Route 101 MIS which would look at all option including widening Santa Rosa Street or building a bypass route. 14. (Page 5.2-28) Again, LOS ratings for Route 227 north of Price Canyon Road seem overrated. Trac growth on Route 227 south of San Luis Obispo is not related so much to residential growth in the rural areas but to commercial growth in the airport area and the use of Route 227 and Price Canyon Road as an alternative to Route 101. The Route 101 MIS should provide some analysis of what future trip distributions between these two routes should be. The EIR consultant should contact SLOCOG staff and Korve Engineering to see if that part of the analysis has been completed. I appreciate the opportunity to review the draft EIR and look forward to the response to comments. If I can provide any additional information or background to your or the consultant, feel free to contact me at 781-7178. Respectfully, Terry Sanville, Principal Transportation Planner Public Works Department City of San Luis Obispo cc Glen Matteson,