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HomeMy WebLinkAbout12/03/1996, 3 - APPEAL OF THE DIRECTOR'S DETERMINATION TO REQUIRE A FOCUSED ENVIRONMENTAL IMPACT REPORT FOR A 42-ACRE ANNEXATION AND WAREHOUSE RETAIL DEVELOPMENT PROJECT PROPOSED ALONG LOS OSOS VALLEY ROAD BETWEEN MADONNA ROAD AND HIGHWAY 101 (FROOM RANCH council 7Z� j ac,Enoa Report CITY OF SAN LUIS OBISPO FROM: Arnold Jonas, Community Development Director) Prepared By: Whitney McIlvaine, Associate Planner SUBJECT: Appeal ofthe Director's determination to require a focused environmental impact report for a 42-acre annexation and warehouse retail 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% to cover City administrative costs. REPORT-IN-BRIEF In February 1996, the City Council upheld the Director's determination to require an EIR for a similar but larger commercial project on the Froom Ranch site. In June 1996, the applicant submitted a revised project description with the goal of eliminating the need for an EIR. The original proposal was the development of a big box retail center along Los Osos Valley Road, roughly the size of the Central Coast Mall and the Madonna Shopping Plaza combined (700,000 SF of leasable floor area). The revised project is essentially phase one of the original project with an additional 60,000 SF of floor area and is described in more detail in the following section. Mr. Madonna is being represented by Ben Maddalena and Dennis Schmidt of Central Coast Engineering. Planning staff and other responsible agencies reviewed the revised project, prepared a second initial study, and again concluded that an EIR will be required to evaluate the potential impacts of the revised project and identify appropriate mitigation. The appellant maintains that the project should be granted a mitigated negative declaration of environmental impact. The appeal statement, filed by Mr. Schmidt, is attached. d "t Council Agenda Report - Froom Ranch Appeal Page 2 DISCUSSION Original vc Revised rMJect The revised project as compared to the original project specifically requests approval for: ■ Annexation of 42 acres of property to the City limits. The original project proposed 66.6 acres for annexation. ■ Prezoning 42 acres of the site Retail-Commercial (C-R). The original project proposed 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. ■ Preliminary Development Plan showing 360,000 square feet of big box retail housed in 3 building of 120,000 SF each and 42 acres of open space easement on the hillside outside the proposed annexation boundary. The original project proposed 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. An open space easement covering 28 acres was proposed in the hills outside the annexation boundary. CSA Requirements 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 used either to support the Negative Declaration finding that a project will not have a significant unmitigated environmental impact or to focus the content of the EIR. For each area of concern listed in the environmental checklist form, the initial study prepared for this project concludes that either.- The ither.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 specific mitigation and/or further 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 v2- Council Agenda Report - Froom Ranch Appeal Page 3 the project will have no sigmficant 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 ofpotential project issues and work tasks that need to be performed 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 ofproject-generated traffic on existing street systems, local air quality and noise impacts resulting from increased traffic; biologic and botanical impacts; water supply impacts; and aesthetic impacts. 3. If there is disagreement between experts over the significance of an effect 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. The City has developed a workscope for a traffic study that would evaluate impacts of the DePaul residential project as well as the Froom Ranch project and has selected a consultant to prepare the study. Developers have not yet agreed in writing to fund this study. Without such a study the significance of traffic impacts can not be adequately evaluated. Other areas of disagreement include noise, geology, and aesthetics. 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. Potentially Significant Impacts 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. 33 Council Agenda Report - Froom Ranch Appeal Page 4 The workscope(at the end of the initial study)identifies those issues for which information submitted is not sufficient to adequately analyze potential environmental impacts, as in the.case of geology, secondary drainage imps, air qty, traffic,biological and botanical resources, soil contamination, noise, wastewater treatment, and aesthetics. The workscope also identifies the need for independent analysis where studies submitted (specifically traffic, geology, noise, and aesthetics) 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: Water Sun_nly: 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 300 acre feet of water available from retrofitting can be applied to annexation areas. This project will be competing for available water credits with two recently annexed areas - the TK Annexation and Goldenrod - and possibly with other proposed annexations, including DeVaul, Dalidio, Prefumo Canyon, and the remaining area covered by the Edna-Islay Specific Plan. 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) Geology: The two-page letter from a Earth Systems Consultants, based on a visual survey without any sample borings and submitted in lieu 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.) Secondary Drainage Impacts: City Public Works staff agreed with the applicant's representative that no significant impacts to storm drain facilities would occur if current storm water runoff is not increased as a result of site development. The applicant's representative proposes to achieve this objective by installing detention basins on-site and off-site in the wetland area southeast of the proposed annexation area. Sufficient detail regarding this plan has not been provided to evaluate the potential secondary biological, botanical, and archaeological impacts on these wetland areas. Council Agenda Report - Froom Ranch Appeal Page 5 Air Ouali : The Air Pollution Control District reviewed the revised project and submitted a letter, dated July 29, 1996, outlining concerns with this project's long term impacts on air quality. APCD staff recommend preparation of an EIR to enable an adequate assessment of the source, type, and magnitude of impacts and identification of mitigation that could reduce those impacts to a less than significant level, including evaluation of alternative projects that would reduce the number of vehicle trips and associated emissions. Transportation/Circulation: Preliminary estimates indicate that traffic generated by this project would double average daily trips along Los Osos Valley Road in this vicinity (18,000 to roughly 36,000). 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 party. A traffic 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, a determination of which improvements are eligible for Transportation Impact Fee credits, and a determination of 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.) Big!QU: The Open Space Element identifies both wetlands and grasslands as important wildlife habitat. More detail regarding the detention basins, drainage swales, and correction of the From Creek breaching is necessary before impacts to the off-site wetland habitat can be evaluated. Of specific concern are the burrowing owls, which are designated as a species of special concern. The loss of the grassland habitat was noted but no analysis of that impact on wildlife was provided. Consistent with adopted Open Space Element polices, the biological study should identify an appropriate habitat buffer to protect species most sensitive to development disturbances and compensate for project impacts on existing habitat. Botam:' A follow up botanical survey was conducted for the revised project in April and May 1996, and the results are reported in the botanical survey prepared by V.L. Holland and dated July 1996. It notes the project will result in the removal or destruction of the Coastal Valley Grassland and possibly hillside wetlands as well if grading is not confined to the flatter base of the Irish Hills. The survey does not address potential impacts on the off-site wetlands as a result of the project's drainage plan. �'s Council Agenda Report - Froom Ranch Appeal Page 6 Soil Contamination: Soil borings preformed as part of the soils and geology engineering reports should be analyzed for toxic substances typically associated with agricultural and mining operations similar to those that have occurred on this ranch. 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 letter from a consultant in environmental noise, dated March 1, 1996, was submitted for this project. It concludes that despite an increase in noise exposure - in excess of acceptable thresholds identified in the Noise Element-for residences along the frontage road between Madonna Road and Garcia Drive, no significant impact will result. It was not accompanied by any supporting technical data, explanation of methodology, or cross sectional diagrams showing the physical relationship of noise sources to sensitive receptor sites. The submitted letter does not meet criteria outlined for noise studies in the 1996 Noise Element(page 29, Noise Guidebook). For these reasons, and others noted in the initial study, the letter submitted is not an adequate substitution for an independent noise study. 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. Aesthetic : The Circulation Element designates Los Osos Valley Road between Madonna Road and Highway 101 as a roadway with moderate scenic value. The visual analysis provided by the applicant evaluates residential development of the site rather than the commercial development now proposed. 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. ConMuences of Not Taking the Recomm nd d 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 EIR, staff would have difficulty fitting this project into its existing workload without impacting processing time for other applications. Applicants with other projects subject to planning review would likely experience delays. The cost of staff time necessary to complete the environmental review would exceed application fees. In addition, staff would need to hire 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. Council Agenda Report - Froom Ranch Appeal Page 7 CONCURRENCES Other City Departments and affected agencies were routed project plans and materials and prepared written comments that were used in identifying issue areas and developing the workscope. FISCAL IMPACTS 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 borne 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. ALTERNATIVE 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. Attachments: Draft resolutions Appellant's statement Initial study Project comments _ 3'7 RESOLUTION NO. (1996 Series) A RE-SOLUTION 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 42-ACRE ANNEXATION AND DEVELOPMENT PROJECT PROPOSED ALONG LOS OSOS VALLEY ROAD BETWEEN MADONNA ROAD AND HIGHWAY 101 (FROOM RANCH) ANNXR/ER 80-95 BE IT RESOLVED by the Council of the City of San Luis Obispo, as follows: SECTION 1. Fines. 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 Allen Settle ATTEST: Bonnie Gawf, City Clerk Draft resolution denying the appeal ER 8o-95 — Pagel APPROVED AS TO _ORM: . e_ en, _ orney t 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, RAPACT DEPORT FOR A 42-ACRE ANNEXATION AND DEVELOPMENT PROJECT 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. Fin`dingc4. 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): SECTION 2. bion. 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 Allen Settle ATTEST: Bonnie Gawf, City Clerk i Draft resolution upholding the appeal Page 2 APPROVED AS TO FORM:- Jeff Jorgensen, City Attorney 1: �►�ii��iiiiuii��illlllil►111111 p�iiilii►�� • • 111111 it city of sAn tuis oBispo APPEAL TO THE CITY COUNCIL In accordance with the appeals procedures as authorized by Title, 1, Chapter 1.20 of the San Luis Obispo Municipal Code, the undersigned hereby appeals from the decision of L!�IIuizlt rendered on 4) '1 "47 T69 which consisted of the following (i.e., explain what you are appealing and the grounds for submitting the appeal. Use additional sheets as needed.) The undersigned discussed the decision being appealed with: WRI T N?i f' N6-( i VPdrue I t��fti�f on 6' , OCT I ((°i k Name/Department ` (Date) Appellant: M(�(JCI�I f�l�t- C'C'Iu�%► . � P;�� t,Zl G�. Name/Title Mailing Address (& Zip Code) -- !.A Home Phone Work Phone Representative: f 1�,r�!�j'�J �: ;t. .�i` )XGA RL CIL,C`i it"CFi0 1'2L:0, LA- 'C97 1C I Name/Title Mailing Address (& Zip Code) For Official Use Only: Calendared for Date & Time Received: c: City Attorney City Administrative Officer Copy to the following department(s): r%�sr�1< U- Original in City Clerk's Office ^/� ►►I►o�hll�llllll�llllllll�������������►IIIlillll �� city of san lues 990 Palm Street, San Luis Obispo, CA 93401-3249 Ma/lid 9Ia7 September 25, 1996 Mr. Alex Madonna Madonna Construction Company P.O. Box 3910 San Luis Obispo, CA 93403 Re: Froom Ranch Environmental Analysis (ER 50-95) Dear Alex, Attached for your information and reference is a copy of the environmental initial study which Community Development Department staffhas prepared for your revised 42 acre Froom Ranch development proposal. This analysis concludes that there could be significant environmental impacts associated with the project, and that a focused Environmental Impact Report (EIR)is required to evaluate and develop appropriate mitigation measures for those impacts. After detailed consideration of the Initial Study I find that I agree with its conclusions, and have determined that an EIR is required. I appreciate that you and your representatives have made sincere effort to anticipate specific areas of concern, and provide sufficient advance information to avoid the need for EIR preparation. However, given the cursory nature of some of the submitted technical reports, and the absence of additional information in some of the subject areas, there remain unresolved issues that city staff feel are best dealt with in the context of the EIR process. And, considering the number of governmental agencies involved and the high level of public interest in your project, that also remains the best way to minimize the potential for environmental challenges to any future City approvals. The EIR need focus only on those items recommended in the proposed EIR work scope contained in Section 20, page 31 of the Initial Study. We are prepared to send out requests for proposals (RFPs)to qualified environmental consultants who have expressed interest in preparing EIRs for the City. Submitted proposals will be evaluated by a City committee and the most qualified consultants asked to participate in an interview process that will determine who will be awarded the EIR contract. We anticipate that the entire EIR process will take approximately 12 months from the date we receive your authorization to proceed with the work. To the extent possible, we will continue to process project applications concurrent with work on the EIR. That should help minimize the overall amount of time required to get to the ultimate City Council decision. The City of San Luis Obispo is committed to include the disabled in all of its services, programs and activities. [ `� City policy requires that the applicant pay for preparation costs associated with the EIR, including a 301/o administrative fee to cover City costs of managing the consultant contract. That amount would be required to be deposited with the City, or adequate security provided, prior to the consultant being authorized to begin work. As you know, this decision may be appealed to the City Council. In such event, we would attempt to place the matter before the Council at the earliest possible date for resolution. Please let us know your preferred course of action in writing at your earliest convenience. If you have any questions regarding specific aspects of the environmental assessment, please feel free to contact Ronald Whisenand, Development Review Manager, at 781-7177 for assistance. Sinc ely, � n _ 11 Arnold Jonas Community Deve opmentDirector c: John Dunn, City Administrative Officer Ronald Whisenand, Development Review Manager Whitney McIlvaine, Associate Planner Dennis Schmidt, Central Coast Engineering �'�7 INITIAL STUDY ENVIRONMENTAL CHECKLIST FORM 1. Project Title: Froom Ranch Annexation (Annx/R/ER/LLA 80-95) (Revised 5/31/96) 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: 42 acres Retail-Commercial 8. Description of the Project: The applicant proposes to annex 42 acres of land currently under County jurisdiction to the City of San Luis Obispo, with a prezoning of Retail-Commercial. In addition, the applicant proposes to grant an open space easement over 42 acres of land outside of the annexation boundaries. The applicant intends to develop the property with retail commercial uses totaling 360,000 square feet. A preliminary development plan submitted with the application for annexation and pre-zoning show the retail development contained in three "big box" style warehouse stores of 120,000 square 1 feet each. In addition, the project will involve developing access from Los Osos Valley Road and on- site parking, landscaping, and lighting improvements. Finally, the development will require off-site improvements including but not limited to drainage, utilities, and traffic improvements (roadway infrastructure and traffic control devices). 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 as part of this 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: Beyond 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 DeVaul property, recently farmed with row crops, but planned for future residential development by both the City and the County. An application to annex and develop the DeVaul property is currently in process with the City. 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 Engineering Department - 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 Planning Area 6. Caltrans - Encroachment permit for right-of-way that may be necessary at the freeway interchange. 2 �p Department of Fish and Game - Streambed Alteration Permit for proposed alterations and grading along the banks of Froom Creek and Prefumo Creek. The Department of Fish and Game is also charged with oversight of projects that may impact habitat for rare and endangered species. Army Corps of Engineers - Section 404 Permit for proposed alterations and grading along the banks of Froom Creek and Prefumo Creek and for site work in the wetland area as proposed in the drainage plan. 3 J1T 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 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. September 25, .1996 ignat re 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 show 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 Impact" 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 ® (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 asues 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 Prezonina: The proposed prezoning of Commercial-Retail is consistent with the General Plan Land Use designation of General Retail. Planning Commission and City Council will determine whether development plans submitted are adequate to enable Commercial-Retail zoning in conjunction with the annexation (Land Use Element Policy 8.10). Onen Snace: The applicant is proposing a 42-acre open space easement outside the annexation area which is equivalent in size to the area proposed for annexation consistent with Policy 1.13.5A of the Land Use Element. 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 and the Army Corp of Engineers. 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. Changes to the project and especially to the drainage plan may be required to ensure consistency with the environmental protection policies of these agencies. As discussed under 4.a., 7.a., and 7.d. , additional information is necessary to determine the potential impacts on botanical and ilogical resources. c) Be incompatible with existing land use in the vicinity? X A project of this size and scope will noticeably impact existing residential and commercial development in the vicinity in terms of traffic, noise, air quality, and alteration of scenic views. Mitigation: The need to develop mitigation for potentially significant impacts related to traffic, air quality, noise and degradation of scenic views is discussed below. Monitoring: 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. d) Affect agricultural resources or operations (e.g. impact to 1,2,4 X soils or farmlands, or impacts from incompatible land uses)? 6 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated The project will remove 42 acres of farmland from agricultural production. According to the USDA 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 policies: ► 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 fo/lowing 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;he/ping 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. ► Open Space Element-Agricultural Land Policy Guide states: Require development to preserve agricultural areas through easements or dedications. As stated above,the project will involve the dedication of an open space easement over land within the City's greenbelt area equivalent to the amount of land to be developed. However, the quality of land proposed for dedication is not as high as that of the land to be developed. The Land Use Element recognized the inevitable loss of a certain amount of prime agricutural land to urban development by allowing small parcels essentially surrounded by urban development to be exempt from any mitigation. the Environmental Impact Report for the Land Use (LUE) and Circulation Elements recognized the impact of that exemption in an overriding consideration. This EIR, 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. P or divide the physical arrangement of an x hed community (including aloes-income or community)7TION AND HOUSING. Would the proposal: ively exceed official regional or local popuX ns? 7 _ 3-�1 issues and Supporting Information Sources sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated See discussion under 2.b. below. b) Induce substantial growth in an area either directly or 2 X indirectly (e.g. through projects in an undeveloped area or major infrastructure? Based on employee counts for warehouse retail stores in the area, this project is anticipated to employee 500 to 600 people. Impacts on housing availability and cost are unknown. 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 areas designated for open space. 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 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 3. GEOLOGIC PROBLEMS. Would the proposal result in or eTmittttts a) Fault rupture? 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. The applicant is proposing that further geologic/soils work will be done at the time of construction. However, CEQA requires that the lead agency gather the necessary data and evidence prior to coming to the conclusion that an impact is less than significant. In addition, the lead agency can not rely on the presumed success of deferred impact analysis and possible mitigation measures that have not been formulated at the time of project approval (Sundstrom v. County of Mendocino). Sufficient information for project decision makers regarding the significance of the potential impacts of geology in the area has not yet been provided. Work Scope issue: An independent geologic engineering report should identify the likelihood of a fault zone at the base of the Irish Hills and should identify all active faults in the area and the potential magnitude of a seismic event on each of the identified faults. Impacts of geologic conditions on the proposed development shall be addressed. b) Seismic ground shaking? 1 X Work Scope Issue: Primary seismic hazards include rupture and ground shaking. An independent geologic engineering report should be prepared for this project which identifies the liklihood and magnitude of ground shaking on the site as a result of seismic events predicted for active faults in the region capable of impacting this site. 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. Policy 5.3 of this element states that no facilities should be permitted in areas of high liquefaction potential without requiring a detailed site investigation which addresses the specific potentials for liquefaction and settlement. The letter from Earth Systems Consultants (refered to in 3.a. above) does not satisfy this requirement. Work Scope Issue: The potential for seismic ground failure, including liquefaction, should be investigated as part of an independent geologic engineering report. 9 Issues and Supporting Information Sources sources Potentially _ Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated d) Seiche, tsunami, or volcanic hazard? X e) Landslides or mudflows? 1,3,4 X 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 are located in the hills that can accelerate creep and should be mapped 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. Policy 5.2 in the Seismic Safety Element states that no development should be permitted in areas of moderate, high, or very high landslide risk without requiring a slope stability investigation in the vicinity of the site. The letter from Earth Systems Consultants (refered to in 3.a. above) does not satisfy this requirement. Work Scope Issue: A 2-page letter from Earth Systems Consultants dated October 10, 1995, which discusses a staff geologist's visual survey -%f the site, should be reviewed as part of an independent engineering geology report. However, its cursory evaluation of ie site's geology is not an adequate substitute for a slope stability investigation. 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 (southwestern building on current plans). These areas should be mapped as part of the geologic engineering 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 grading and drainage plan (Exhibit F7.61) proposes to locate three sediment basins at the rear of the two westernmost buildings to catch rock and other debris moving down slope during a storm. Work Scope Issue: An independent geologic engineering 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? 1 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 4.i. regarding subsidence as a result of well water use. Work Scope Issue: A soils engineering report should be prepared for this project. It should address the potential for subsidence and identify ,icessary earthwork and foundation design criteria for the site development proposed. 10 t3-�z� Issues and Supporting Information Sources sources Potentially Potentially Less Than No Significant Significant Significant Impar Issues unless Impact Mitigation Incorporated h) Expansive soils? 3,4 X The Soil Conservation Service maps indicate that three of the four soil types underlying the project site have a high shrink- swell potential. A sols 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. Work Scope Issue: A soils engineering report should be prepared for this project. It should address the potential for shrink-swell based on analysis of soil borings and identify necessary earthwork and foundation design criteria for the site development proposed. 1) Unique geologic or physical features? ( The project will change the character of the Irish Hills in this area. The impact is primarily aesthetic and is therefore discussed below in Section 13. 4. WATER. Would the proposal result in: a) Changes in absorption rates, drainage patterns, or the 1 X rate and amount of surface runoff? A conceptual drainage study was submitted by Central Coast Engineering in February, 1996. Public Works Department staff reviewed that study and concluded that it is possible to develop a drainage plan for this project whereby storm water runoff after construction would not exceed current runoff levels. In that case the project would not worsen the seasonal flooding situation that occurs down stream as a result of inadequate capacities in existing storm water facilities (primarily the Prefumo Creek culvert under Highway 101 and a 48" culvert running through 1605 Calle Joaquin that directs Froom Creek water under the highway). The conceptual drainage study proposes to achieve this objective of no net gain in runoff through a system of sedimentation basins, detention ponding, installation of a levee at the bend in the Froom Creek channel, and installation of culverts and/or enlargement of the open swale along Los osos Valley Road. Final drainage improvements must be designed to meet standard City design criteria. If designed properly, detention ponds in the area on the Froom Ranch near the Highway 101 interchange could enhace the habitat value of existing wetlands and perhaps alleviate some of the flooding that occurs at the interchange as a result of Froom Creek flows breaching the creek bank during heavy rains. However, without some additional detail regarding the size, capacity, location, and grading requirements for components of the drainage proposal, it is not possible to evaluate their environmental impacts. - 11 oCJ Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Drainage cont'd: Mitigation: A drainage master plan must be formulated to the approval of the City, County, Cal Trans, the Army Corps of Engineers, and the Department of Fish and Game prior to construction of site improvements. The plan should show all proposed on- and off-site drainage facTities, including changes to Froom Creek and any modification of the area between the proposed development and Highway 101. The drainage plan should be designed to convey all drainage to an appropriate point of disposal to the satisfaction of the City Engineer. Monitoring: Architectural review and building permit issuance. Work Scope Issue: For purposes of environmental review the drainage master plan must include sufficient detail to enable analysis of potential adverse archaeological, biological, botanical, and aesthetic impacts and identification of appropriate mitigation. b) Exposure of people or property to water related hazards X such as flooding? The subject property is located above the 100-year flood plain. For a discussion of potential off-site flooding hazards as a result of this project, please refer to discussion under 4.a. c) Discharge into surface waters or other alteration of X surface water quality (e.g. temperature, dissolved oxygen or turbidity? See discussion under 4.d. below. d) Changes in the amount of surface water in any water X body? The applicant's drainage study is recommending that drainage improvements be installed with the project that will not result in any increase in runoff from the property above the level that already exists. The Public Works Department has accepted this design alternative and has stated that drainage facilities will need to be designed to City standards. e) Changes in currents, or the course or direction of water' X movements? 12 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated The conceptual drainage study proposes to install a levee at the bend in Froom Creek to prevent creek waters from breaching the bank. This aspect of the project will require approval from the Department of Fish and Game and the Army Corps of Engineers. Mitigation: As recommended under 4.a. above. 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? The project estimates a water usage of roughly 20 acre feet per year for 360,000 square feet of warehouse style commercial development. The project could be served by City water subject to compliance with water retrofit requirements. Use of well water for potable purposes is subject to Council approval. See discussion under 12.g. Mitigation and Work Scope Issue: As recommended under 12.g. g) Altered direction or rate of flow of groundwater? X Before use of well water can be approved, the applicant must submit a hydrological study which evaluates potential impacts on groundwater to the satisfaction of the Utilities Director. See discussion under item 12.g. h) Impacts to groundwater quality? X Impacts to groundwater quality are not anticipated as a result of this project. 1) Substantial reduction in the amount of groundwater 1,5 X otherwise available for public water supplies? See discussion under item 12.g. 5. AIR QUALITY. Would the proposal: a) Violate any air quality standard or contribute to an exiting or projected air quality violation? 13 - x-97 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated San Luis Obispo County is a non-attainment area for the State ozone and PM,o (fine particulate matter 10 microns or less in diameter) air quality standards. State law requires that emissions of non-attainment 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,o. 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. The Clean Air Plan (CAP) for San Luis Obispo County was developed and adopted by the Air Pollution Control District (APCD)to meet that requirement. The CAP is a comprehensive planning document designed to reduce emmissions from traditional industrial and commercial sources, as well as from motor vehicle use. Land Use Element Policy 1.18.2 states that the City will help the APCD implement the Clean Air Plan. Site development will impact air quality as a result of construction activity and traffic generated by uses established. Standard mitigation is recommended to reduce impacts resulting from construction activity and future site development. However,these measures are not likely to sufficiently reduce potential impacts to a less than significant level. Air Pollution Control District (APCD) staff have reviewed the proposed project and have concluded that preparation of a focused EIR is warranted. Preliminary analysis by District staff indicate the project's air quality impacts will be well above significance thresholds. The District's concerns about the project and recommendations for the scope and content of air quality analysis to be included in a focused EIR are outlined in a letter dated July 29, 1996. litigation: Off-site 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 on and off-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 streets in the vicinity of the construction site. h. Use of non-potable water is required in all construction and dust control work. 14 fo Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Air Quality Mitigation cont'd: All PM1e 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 numbers) 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 car pool/ride share/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 car pool parking. g. On-site food facilities to encourage employees to stay on site during the lunch hour. Monitoring: Architectural review and building permit issuance. Work Scope Issue: An air-quality analysis should be prepared for this project which provides sufficient detail necessary to determine the type and scope of mitigations necessary to reduce impacts to an acceptable level, consistent with the Air Pollution Control District's Clean Air Plan. b) Expose sensitive receptors to pollutants X This should be addressed as part of the air quality analysis. c) Alter air movement, moisture, or temperature, or cause X any change in climate? d) Create objectionable odors? X Objectionable odors may be a secondary impact of air pollution resulting from additional traffic. Mitigation adopted to reduce traffic impacts will also help to reduce this impact. 15 �� 9 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 6. TRANSPORTATION/CIRCULA710N. Would the proposal result in: a) Increased vehicle trips or traffic congestion? 1,7 X Preliminary estimates indicate that this project could double the amount of traffic on Los Osos Valley Road between Highway 101 and Madonna Road. Necessary changes to the highway interchange,the roadway and affected intersections must be clearly identified. City staff are working with representatives of this project as well as representatives of a proposed residential project on the adjacent DeVaul property to develop a work scope for traffic studies. Work Scope Issue: An independent analysis of traffic and circulation impacts should be prepared which identifies project impacts, mitigation necessary to reduce those impacts to a less than significant level, and funding strategies to implement necessary mitigation. b) Hazards to safety from design features (e.g. sharp curves ? or dangerous intersections) or incompatible uses (e.g. farm equipment))? ee discussion under 6.a. above. c) Inadequate emergency access or access to nearby uses? ? See discussion under 6.a. above. d) Insufficient parking capacity on-site or off-site? ? See discussion under 6.a. above. e) Hazards or barriers for pedestrians or bicyclists? ? See discussion under 6.a. above. f) Conflicts with adopted policies supporting alternative ? transportation (e.g. bus turnouts, bicycle racks)? See discussion under 6.a. above. g) Rail, waterbome or air traffic impacts (e.g. compatibility 710T X with San Luis Obispo Co. Airport Land Use Plan)? T-1 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. 7. BIOLOGICAL RESOURCES. Would the proposal impact: a) Endangered, threatened or rare species or their habitats 1,3,6 X (including but not limited to plants, fish, insects, animals or birds)? 16 30 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Biological Resources: The Draft EIR prepared for the Madonna General Plan Amendment for property 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. Wetlands and grasslands, which provide valuable wildlife habitat, would be impacted by the project. The project proposes off-site changes to the Froom Creek drainage channel and adjacent wetland area and on-site development of a coastal valley grassland area. On-site wetlands may also be impacted depending on: 1) the design of proposed sedimentation basins in the foothills, and 2) the extent of the wetlands area as determined in accordance with the Army Corps of Engineers Delineation Manual. The City's Natural Resources Manager has identified the valley grasslands that exist in the development area to be "important habitat for wildlife, and a significant food source for species such as raptors." His comments on the project state that"the Froom Ranch development will remove 42 acres of this habitat which is a significant impact that needs to be addressed." Finally as noted in item 7.e., the project could have an impact on migrating wildlife. Work Scope Issue: A biological study should map the location and extent of affected wetland and grassland habitat relative to proposed development. Wetland delineation should be determined consistent with the Army Corps of Engineers Delineation Manual. The study should determine the type and significance of impacts that proposed on-and off-site improvements will have on habitat areas, with particular attention to potential impacts on burrowing owl habitat and on wildlife migration routes across the project site. The report should include recommended mitigation measures where impacts may be significant. See discussion under 7.c. also. More detailed information regarding the drainage plan will be necessary to complete this study. 17 2.3/ Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Botanical Resources: A revised botanical study prepared by V. L. Holland for the project site was submitted with the revised application. Essentially, the level area proposed to be prezoned Retail Commercial was surveyed. The hillside portion of the project proposed for open space dedication was not part of the study. The report states that although two plant species exist on the Froom Ranch property that are listed in the California Native Plant Society (CNPS) Inventory of Rare and Endanaered Vascular Plants of California (Skinner and Pavlik, 1994), they are outside of the area of disturbance. The report states that the project will result in the removal or destruction of the Coastal Valley Grassland plant cover on the site and a corresponding reduction in the amount of open grassland areas available to various wildlife species. There will be"Tittle loss of native plants"due to the disturbed nature of the site. Grading proposed near the quarry could disturb some small wetland areas. The report recommends some design modifications to address this potential impact. Mitigation-rare and endangered species: The project shall be designed so that site disturbance is limited to the valley floor and grading on the western boundary is confined to the flatter base of the hillside area, outside the quarry area and serpentine habitats that support rare and endangered species as described in the Botanical Survey prepared by V.L. Holland for the Froom Ranch 50 Acre Project Site, dated July 30, 1996. Ilonitoring: Site plans will be subject to staff and ARC review to ensure minimal disturbance of hillside areas. Work Scope Issue: The botanical study should be expanded to include a map exhibit showing the location of sensitive botanic areas and a discussion of potential off-site impacts in the open space easement area and in the fresh water marsh near Calle Joaquin as a result of the proposed drainage plan. b) Locally designated species (e.g. heritage trees)? X c) Locally designated natural communities (e.g. oak forest, 1 X coastal habitat, etc.)? The Open Space Element describes the significance of grassland communities and their value to the local area. Polices state that the City should preserve grassland communities as habitat buffers and open space through easements or dedications. Open Space Element polices also state that grassland communities should be protected from development impacts by requiring a habitat buffer, as determnied by a qualified biologist during the initial planning phase of development. Work Scope Issue: A biological study should identify an appropriate habitat buffer of sufficient width and size to protect the species most sensitive to development disturbances and to compensate for project impacts on the existing habitat, consistent with adopted Open Space Element policies. Wetland habitat (e.g. marsh, riparian and vernal poop? X 18 .�302 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated See also discussion under 7.a. 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 which 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 conveyed via culverts and open swales along Los Osos Valley Road. The conceptual drainage study does not provide sufficient detail to enable evaluation of potential habitat impacts. Work Scope Issue: As part of the drainage master plan 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 See discussion under 7.a. 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." A goal of the Energy Element is to encourage projects to make maximum use of passive means of reducing conventional energy demand rather than designing a particular image and relying on mechanical systems to maintain comfort. See recommended mitigation under 8.b. below. b) Use non-renewable resources in a wasteful and inefficient 1 X manner? 19 Issues and Supporting Information Sources sources Potentially Potentially Leas Than No Significant Significant Significant Impatt Issues Unless Impact Mitigation Incorporated To avoid using non-renewable resources in an inefficient manner, the following standard mitigation is recommended: Mitigation: Future site development shall incorporate: • Skylights to maximize natural day lighting. • Operable windows to maximize natural ventilation. ` Energy-efficient lighting systems for both interior and exterior use. In the event operable windows and skylights are not feasible alternatives for tenant operational reasons, buildings should be designed to exceed energy conservation standards in the California Energy Code by 10%. 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)? Fire Department comments note that the history of the site is unclear with regard to environmental/agricultural contamination. Soil borings should be analysed for toxic substances typically associated with agricutural and mining operations similar to those that have occured on this ranch. Work Scope Issue: Soil borings preformed as part of the soils and geology engineering reports should be analyzed for toxic substances typically associated with agricutural and mining operations similar to those that have occured on this ranch. b) Possible interference with an emergency response plan or X emergency evacuation plan? This will be addressed as part of the traffic study. Preliminary development plans do not indicate any interference with emergency response. c) The creation of any health hazard or potential health X hazard? 'I Exposure of people to existing sources of potential health X hazards? 20 3-3� Issues and Supporting Information Sources sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated This is unknown. See discussion under 9.a. _T e) Increased fire hazard in areas with flammable brush, grass X of trees? 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 letter from a consultant in environmental noise, dated March 1, 1996, was submitted for this project. It concludes that despite an increase in noise exposure - in excess of acceptable thresholds identified in the Noise Element-for residences along the frontage road between Madonna Road and Garcia Drive, no significant impact will result. The consultant also recommends, as mitigation, construction of a 10-12 foot tall sound wall along the property line this project shares with the Devaul property, where residential development is anticipated. The letter is premature in that the design of the Los Osos Valley Road widening will not be determined before completion of the required traffic study. It assumes a traffic distribution pattern along Los Osos Valley Road which is unlikely and won't be known with any certainty until a traffic study is complete. It was not accompanied by any supporting technical data, explanation of methodology, or cross sectional diagrams showing the physical relationship of noise sources to sensitive receptor sites. No actual field measurements of ambient noise levels were made. It incorrectly excludes front yards from "outdoor activity areas" as defined in the Noise Element. The letter does not address preferred mitigation approaches outlined in the 1996 Noise Element(page 6), which specifically discourage use of sound walls in the Irish Hills Special Design Area. The submitted letter does not meet criteria outlined for noise studies in the 1996 Noise Element (page 29, Noise Guidebook). For these reasons, the letter submitted is not an adequate substitution for an independent noise study. Work Scope Issue: An independently prepared noise study should analyze potential noise impacts of the project and identify appropriate noise attenuation measures consistent with the Noise Element and Noise Guidelines. It should be accompanied by supporting technical data, explanation of methodology, and cross sectional diagrams showing the physical relationship of noise sources to sensitive receptor sites. 21 3 35' Issues and Supporting'Information Sources sources Potentially Potentially Less Than No Significant Significant 'Significant Impact Issues Unless Impact Mitigation Incorporated b) Exposure of people to severe noise levels? X See discussion and recommended mitigation in 10.a. 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) Fire protection? X Comments from the Fire Department staff note that project plans lack the detail necessary to definitively assess all life safety and fire protection concerns. However, the project will be subject to compliance with all applicable Fire Code standards. b) Police protection? X c) Schools? X San Luis Coastal Unified School District was notified of this project and did not comment. ` Maintenance of public facilities, including roads? X eublic Works staff note that each new traffic signal proposed would cost the City roughly $5,000 per year to maintain. Upon annexation, maintenance of the annexed portion of Los Osos Valley Road would also become the responsibility of the City. Fiscal impacts of the project will be addressed as part of City Council's consideration of the annexation and prezoning proposal. 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 22 NZ Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Signfcant Significant Impact Issues Unless Impact Mitigation Incorporated The project was routed to PG&E for comment. They note that pole lines 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 off-site 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. c) Local or regional water treatment or distribution facilities? X This project has been reviewed by Utilities Department staff. Comments note that an existing 12-inch water main in Los Osos Valley Road is adequate for delivery of water to the project. The project will be subject to water impact fees at the time of building permit issuance. Water impact fees have been adopted by the City to ensure that new development pays its fair share of the cost of constructing water supply, treatment and distribution facilities necessary to service it. d) Sewer or septic tanks? X 23 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Utilities Department comments note that there are no adequate sewer facilities in the vicinity to serve the project site. The development plan indicates the project would include installation of a 10-inch sewer main extending to the existing gravity sewer that runs west to east under the Dalidio farm to the Laguna lift station. Comments note that sewer plans need to be developed further to determine engineering feasibility. Specific concerns include the crossing of Prefumo Creek and maintenance of minimum grades. The project will be subject to sewer lift station and impact fees at the time of building permit issuance. To ensure adequate sewer services, the following standard mitigation is recommended: Mitigation: Sanitary sewer 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 will qualify for reimbursement by the City, in accordance with City regulations. The sewer line extension crossing of Prefumo Creek shall be subject to review and approval by the Department of Fish and Game and the Army Corps of Engineers. "lonitoring: Building permit issuance. Work Scope Issue: Project comments received from the Utilities Department note that the developer should submit 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. e) Storm water drainage? X See discussion and recommended mitigation under 4.a. above. f) Solid waste disposal? 13 X 24 �-�I5 Issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Frequires nd research for the Integrated Waste Management Act of 1989 (AS939) shows that Californians dispose of ,500 pounds of waste per person per year. Over 90% of this waste goes to landfills, posing a threat to ter, air quality, and public health. Cold Canyon landfill is projected to reach its capacity by 2018. The Act ch city and county in California to reduce the flow of materials to landfills by 50% (from 1989 levels) by 2000.duce the waste stream generated by this project, consistent with the City's Source Reduction and Recycling, recycling facilities must be accommodated on the project site and a solid waste reduction plan for recycling discarded construction materials should be submitted with the building permit application. The project should include facilities for both interior and exterior recycling to reduce the unrecycled waste stream generated by the project consistent with the Source Reduction and Recycling Element. Mitigation: Site development shall include a solid waste recycling plan for recycling discarded building 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 facilities for interior and exterior on-site recycling. Monitoring: Architectural review and building permit issuance. g) Local or regional water supplies? 1 5 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 Water and Wastewater Management Element estimates that roughly 300 acre feet of water (available from retrofitting existing plumbing facilities throughout the City) can be applied to annexation areas outside the 1994 city limits but inside the urban reserve. 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 for nonpotable purposes, providing well water use is approved consistent with the Urban Water Management Plan and the Water and Wastewater Management Element. City water use factors estimate water usage for a warehouse store at .056 acre foot/1000 square feet. If the proposed 360,000 square feet of development on this site is composed of nothing but warehouses, the resulting water demand would be 20.16 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 16.13 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. 25 3_?q Issues and Supporting Information Sources sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated Water Supply cont'd: Mitigation: In the absence of available water allocations, site development will be subject to water retrofit offsets. In the absence of available water allocations and potential retrofit offsets, the location and use of wells for potable purposes shall be subject to approval 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 necessary well water treatment process shall be subject to approval by the City and may require a permit to discharge and on-site pretreatment. If well water is approved for the development, a determination will be made by the Utilities Department regarding the appropriate wastewater charge. Any cost associated with the determination of wastewater flows will be the responsibility of the developer. 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 -f a meter on the well, installation of a meter on the wastewater discharge lateral, or some other means. 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 and the Froom Ranch complex. The applicant has provided the City with a visual study dated May 1996. In accordance with General Plan policies (policy 8.10.2),development plans shall be submitted in lieu of a specific plan that show "building heights, setbacks, and spacing to allow views of the Irish Hills from Los Osos Valley Road." The applicant's study does not match the development plan in that the buildings and site planning are not the same. In addition, the visual study used an exhibit from the LUE EIR that showed the visual impact of two story residential development. This study is insufficient since it fails to analyze the project in question. Work Scope 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 'Ree discussion under 13.a above. 26 -44a C) Create light or glare? X Architectural review of the project lighting will address this aspect of design to ensure against glare. 14. CULTURAL RESOURCES. Would the proposal: a) Disturb paleontological resources? X b) Disturb archaeological resources? 8,3,12 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. However the report does not address proposed off-site grading along Froom Creek and in the fresh water marsh to the south east of the project site. In a draft EIR prepared by the Morro Group for the Madonna general plan amendment request (pp 48-51),two prehistoric archaeological sites were identified during a surface survey. The subsurface boundaries of those sites were never determined. Work Scope Issue: The archaeological study should be revised to include an archaeological resources inventory for the off-site areas that would be disturbed as a result of the proposed drainage plan consistent with the City's Archaeological Resource Preservation Guidelines. c) Affect historical resources? 8, X 10,12 The phase one archaeological surface survey conducted by Robert Gibson in October, 1993 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 complex, which sits on a knoll overlooking the fields along Los Osos Valley Road is representative of early dairy farms in the area (circa 1870). Ranch buildings are located outside the proposed annexation and development boundary. Therefore, the project is not likely to have any significant adverse impact on them. 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 X or other recreational facilities? b) Affect existing recreational opportunities? X 16. MANDATORY FINDINGS OF SIGNIFICANCE. a) Does the project have the potential to degrade the quality X of 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? 27 issues and Supporting Information Sources Sources Potentially Potentially Less Than No Significant Significant Significant Impact Issues Unless Impact Mitigation Incorporated 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 impacting sensitive biological resources and/or the habitat important for their survival; and by erecting buildings that would block views of the Irish Hills. b) Does the project have the potential to achieve short-term, X to 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 consider- able" 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. Does the project have the potential to cause substantial X adverse effects on human beings, either directly or indirectly? Geologic conditions on-site may have a significant adverse impact on human beings due to faulting, landslide, and liquefaction potential. 28 18. SOURCE REFERENCES 1 San Luis Obispo City General Plan: Land Use, Circulation, Noise, Energy, Open Space, Seismic Safety, Water and Wastewater Management 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 USDA 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 10 Historical Evaluation of LongBonetti Ranch prepared by Judy Triem, February 27, 1990 11 Alquist-Priolo Earthquake Fault Zoning Act 12 Archaeological Resource Preservation Guidelines, October 1995 13 Source Reduction and Recycling Element 19. RECOMMENDED MITIGATION A drainage master plan must be formulated to the approval of the City, County, Cal Trans, the Army Corps of Engineers, and the Department of Fish and Game prior to construction of site improvements. The plan should show all proposed on- and off-site drainage facilities, including changes to Froom Creek and any modification of the area between the proposed development and Highway 101. The drainage plan should be designed to convey all drainage to an appropriate point of disposal to the satisfaction of the City Engineer. Air Ouality 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: 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; 29 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 streets 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/ideshare/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 car pool parking. g. On-site food facilities to encourage employees to stay on site during the lunch hour. Tra nsoortati on/Circulation To be determined based on completion of the project traffic report. Botanical Resources The project shall be designed so that site disturbance is limited to the valley floor and that grading on the western boundary is confined to the flatter base of the hillside area, outside the quarry area and serpentine habitats that support rare and endangered species as described in the Botanical Survey prepared by V.L. Holland for the Froom Ranch 50 Acre Project Site, dated July 30, 1996. Enemy Resources Future site development shall incorporate: Skylights to maximize natural daylighting. Operable windows to maximize natural ventilation. • Energy-efficient lighting systems for both interior and exterior use. In the event operable windows and skylights are not feasible alternatives for tenant operational reasons, buildings should.be designed to exceed energy conservation standards in the California Energy Code by 10%. 30 Utility and Service Systeme 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 off-site 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. 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 shall incorporate facilities for interior and exterior recycling. 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 water and sewer 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. In the absence of available water allocations, site development will be subject to water retrofit offsets. In the absence of available water allocations and potential retrofit offsets, the location and use of wells for potable purposes shall be subject to approval 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 necessary well water treatment process shall be subject to approval by the City and may require a permit to discharge and on-site pretreatment. If well water is approved for the development, a determination will be made by the Utilities Department regarding the appropriate wastewater charge. Any cost associated with the determination of wastewater flows will be the responsibility of the developer. 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. 20. EIR 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. 31 Drainage For purposes of environmental review the drainage master plan must include sufficient detail to enable analysis of potential adverse archaeological, biological, botanical, and aesthetic impacts and identification of appropriate mitigation. Geologic Problems 1. An independent geologic engineering report should identify the likelihood of a fault zone at the base of the Irish Hills and should identify all active faults in the area and the potential magnitude of a seismic event on each of the identified faults. 2. The geologic engineering report should also identify: a. The likelihood and magnitude of ground shaking on the site as a result of seismic events predicted for active faults in the region capable of impacting this site. b. The potential for seismic ground failure, including liquefaction. c. Location of mudslides, areas of fill, springs, and nearest landslides. d. Viability of the proposed sedimentation basins with recommendations for the construction, capacity, and maintenance of such basins. 3. An independent soils engineering report should identify 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 EIR 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, 1988 Air Quality An air-quality analysis should be prepared for this project which provides sufficient detail necessary to determine the type and scope of mitigations necessary to reduce impacts to an acceptable level, consistent with the Air Pollution Control District's Clean Air Plan. Transoortati on/Circulation Traffic Study meeting City approved work scope is currently in process. 32 BiolonicalBotanical Resources A biological study should map the location and extent of affected wetland and grassland habitat relative to proposed development. Wetland delineation should be determined consistent with the Army Corps of Engineers Delineation Manual. The study should determine the type and significance of impacts that proposed on- and off- site improvements will have on habitat areas, with particular attention to potential impacts on burrowing owl habitat and on wildlife migration routes across the project site. The report should include recommended mitigation measures where impacts may be significant. More detailed information regarding the drainage plan will be necessary to complete this study. The biological study should identify an appropriate habitat buffer of sufficient width and size to protect the species most sensitive to development disturbances and to compensate for project impacts on the existing habitat, consistent with adopted Open Space Element policies. As part of the recommened drainage master plan, 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. The botanical study should be expanded to include a map exhibit showing the location of sensitive botanic areas and a discussion of potential off-site impacts in the open space easement area and in the fresh water marsh near Calle Joaquin as a result of the proposed drainage plan. Expected Work Products Biological Study analyzing issues outlined above Amended Botanical Study Available Information Botanical Survey prepared by V. L. Holland for 50 acres of the project site, July 30, 1994 (revised May 1996) Draft EIR prepared for the County of San Luis Obispo by the Morro Group in 1988 for the Madonna General Plan Hazards Soil borings preformed as part of the soils and geology engineering reports should be analyzed for toxic substances typically associated with agricutural and mining operations similar to those that have occured on this ranch. Noise An independently prepared noise study should analyze potential noise impacts of the project and identify appropriate noise attenuation measures consistent with the 1996 Noise Element and Noise Guidelines. It should be accompanied by supporting technical data, explanation of methodology, and cross sectional diagrams showing the physical relationship of noise sources to sensitive receptor sites. Expected Work Product Noise Analysis of project construction and operation and recommended mitigation 33 Available Information Noise Element (May 1996) Noise Guidebook supplement to the Noise Element (May 1996) 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 and July 18, 1996. Exoected Work Product Wastewater generation estimates based on development of the entire annexation site in average gallons per minute and peak gallons per minute. Determination of whether the 15-inch sewer main in the Dalidio property and the Laguna lift station have the capacity to handle the additional flow. Recommended 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. Exoected 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) Examples of Visual Analysis prepared for other projects Cultural Resources The archaeological study submitted for a previous version of this project should be revised to include an archaeological resources inventory for the off-site areas that would be disturbed as a result of the proposed drainage plan consistent with the City's Archaeological Resource Preservation Guidelines. Exoected Work Product 1. Revised archaeological resource inventory that addresses potential off-site impacts in areas that will be affected by the proposed drainage plan and for the Froom Ranch complex. 34 -ye Available Information Archaeological Resource Preservation Guidelines; October 1995 Guide to Heritage Research in San Luis Obispo-County, January 1983 Historical Evaluation of Lorig/Bonetti Ranch prepared by Judy Triern, February 1990 Biographical sketch of Bill Froom, TelegrarnwTribune article, July 75, 1989 Attachments: Reductions of project plans y .35 Ii _ a i .9 R o IS � 3 r3c s sad g 1 d a10'.:28 z g E in a re q a ^ Eg = ° s It JIM \a Sot sroa � � o 20 � I u� o� I riNM�. 7a� I lof � I . I i • i ' I I I III , I ; � it I ;, � � ,, I ► I I I � . I ; . I. II III; .I!I , , I I 1 I =<; 1, I I ` I I►: I. _::.c;:-�.: •"t I ;I � I I, :I 'I!II. 111 i1 II I i I I o -=_x;f..:: 1 . II !1 1 II - :::c-::ii:��:ii=''= I i il•I� j III II' ''_ - -=—- _-_ - I � it ?IjI I�IIII I �Ij! 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O 3� Q 1 r o u °4621 32 ©zc3 From: Jerry Kenny To: CITY_HALLWMCILVAI Date: 8/8/9611:52am Subject Froom Ranch This is to state the Public Works and Utilities Department's comments as to the revised project's impacts: The revised project has been reviewed and PW and Utilities staffs find no significant change from its previous recommendations relative to drainage,traffic and utilities would be needed Refer to my Oct. 13,1995 memo to you on completeness of application and Dan Gilmore's memo of July 18, 1996,except a modification to the PW memo would be that the revised project/annexation area is not subject to 100-yr flooding per the FEMA Flood Hazard Boundary Map,although the impacts during a 100-yr event will still be required to be analyzed with the project,per City standards, and traffic issues as stated below. To summarize those: a. Traffic-the scope of work for an independent study has been developed and trar=3itted to the applicant and his representatives. As you know,the report will be utilized by the Citys EIR consultant.(See the letter from Terry Sanville, which also includes CalTrans'comments on the scope of work,sent by separate mail) b. Drainage-as noted earlier in a memo to M McCluskey dated 2-5-96,PW staff is satisfied with the last drainage study received on January 29, 1995 submitted by CCE and that standard City conditions,design criteria and detention basins will mitigate drainage impacts satisfactorily. The details will be worked out with final plans for the project Consideration of the specific detention basin(s)location(s)may be subject to further review. c. Utilities-Previous comments from Dan Gilmore dated 7-18-96 still prevail. CC: MMcClusk,ACablay,TSanvill,MBERTACC �/V AIR POLLUTION CONTROL DISTRICT COUNTY OF SAN LUIS OBISPO July 29, 1996 Ron Whisenand Community Development Department City of San Luis Obispo 990 Palm Street San Luis Obispo, CA 93403-8 100 SUBJECT: Froom Ranch Commercial Expansion Project Dear Mr. Whisenand: District staff appreciate the opportunity to partake in the review process of the above mentioned project. On February 6, 1996, the City Council considered an appeal by the applicant regarding preparation of a focused EIR for the annexation of 66.6 acres south west of Los Osos Valley Road(LOVR) and development of approximately 700,000 square feet of commercial retail including several warehouse stores. District staff indicated in a letter dated February 3, 1996, and in verbal comment at the February 6 Council meeting, that air quality concerns had yet to be satisfactorily addressed; we recommended preparation of a focused EIR with inclusion of an air quality section. The project applicant has since submitted a revised project description that outlines the annexation of approximately 42 acres and development of 360,000 square feet of retail warehouse space on the Froom Ranch south west of Los Osos Valley Road. While the current proposal is reduced in scope, we believe long-term air quality impacts will still be significant and difficult to mitigate. Thus, preparation of a focused EIR is still warranted. The following discussion details the need for an EIR and provides recommendations on the scope and content of the air quality analysis for the document. Adequacy Of Air Quality Assessment In Existing EIRS The applicant's current project proposal appears quite similar to the Froom Ranch Option#2 scenario investigated in the Supplemental Environmental Impact Report (SEIR)to the Land Use and Circulation Element updates. Froom Ranch Option#2 is a general and fairly rough sketch of the annexation of approximately 52 acres and development of 360,000 square feet of warehouse store space. Unfortunately, the SEIR presents only a qualitative assessment of potential air quality impacts from the project and does not provide the level of detail necessary to determine the type and scope of mitigations needed to reduce impacts to an acceptable level. Mr. Dennis Schmidt of Central Coast Engineering, the applicant's representative, acknowledged the general nature of that analysis in an October 29, 1993 letter to your department: "We recognize that the analysis of the Froom Ranch Commercial Expansion Area is based on assumptions concluded 2155 Sierra Way. Suite B• San Luis Obispo. CA 93401 805 781.5912 • FAX: 805 781 1035 (off from limited information and offer that if examination of the request included review of development details and design measures, the level of impacts and the subsequent recommendation to avoid'full development'to reduce these impacts to an acceptable level would be different." District staff are very interested in additional project details that might alter our current belief that potential air quality impacts will be well above significance levels. We believe a focused EIR is the best vehicle for evaluating such information and will allow identification of sources, quantitative assessment of impacts, and determination of the amount and type of mitigation required. Outdated Assumptions in the City's Circulation Element The Froom Ranch Option #2 scenario indicates that approximately 16,000 new daily vehicle trips would be generated above those expected under the existing open space and residential zoning. The SEIR states that"...this amount reflects trip generation rates corresponding with trip reduction programs in the draft Circulation Element, and a reduction for pass-by'trafc...". The goals of the circulation element include shifting modes of transportation from private motor vehicles to mass transit, car pools, bicycles, and walking, with the aim of achieving a 17 percent mode shift by the year 2017. The EIR indicates that "the primary mechanism for this shift is the Trip Reduction Ordinance (TRO) under development by the San Luis Obispo County APCD." The TRO being developed at the time was aimed at reducing trips generated by employees traveling to work in single occupant vehicles. Unfortunately, state legislation was recently enacted which prohibits APCDs and other jurisdictions from imposing mandatory TRO programs. As a result, our Commute Alternatives Rule was repealed at our July 24, 1996 board hearing. The District is in the process of developing a voluntary employee trip reduction program to replace the rule. However, the ability of that program to achieve the mode shift goals identified in the City's Land Use and Circulation Element is questionable. Thus, the capacity to reduce trips from the applicant's proposed project is likely less than that assumed in the SEIR. The project EIR should include an examination of how the loss of Rule 901 will affect the substantial number of project specific and cumulative trips. Cumulative Impacts The significance of cumulative air quality impacts is evaluated in the Land Use and Circulation Elements EMs, but only in relation to population projections. This may be an appropriate analysis for a program-level EIR. However, in evaluating the potential impacts from a specific development project, it is important to also consider its cumulative impact in relation to other planned or proposed projects in the surrounding area. District staff are aware of a number of commercial, recreation, and residential projects in the vicinity of the Froom Ranch proposal that could generate considerable cumulative air quality impacts. Failure to evaluate and adequately mitigate these impacts could jeopardize District attainment efforts. The existing EIRs addressing the annexation and development of the lands to the south west of LOVR indicate the need to substantially widen a number of roads and install additional signalization at some intersections. These congestion mitigations, while improving traffic flow, may hinder the implementation of other transportation modes, especially bicycling and walking. Pedestrian safety and convenience is typically compromised with increasing street widths and intersection complexities. Thus, the analysis of cumulative impacts should include an evaluation of impacted intersections as well as potential impediments to implementation of alternative transportation modes. The analysis should also consider the potential trip generation from future development of the 10 acre parcel resulting from the difference between the applicant's current 42 acre annexation proposal and the 52 acres identified in Froom Ranch Option#2 (components A and B). Consistency with the Clean Air Plan The trip reduction measures in the District's Clean Air Plan are designed to reduce the current rate of increase in vehicle trips and miles traveled (VMT) to the rate of population growth. Unfortunately, the applicant's current design proposal (three large warehouse stores with an expansive parking lot) caters almost exclusively to patrons traveling by automobile, which will exacerbate the countywide trend to drive further and more often. Design alternatives to help mitigate this impact include adding neighborhood scale commercial/retail components to serve existing and future residential areas; orienting the buildings toward the street, with parking in the rear; and reducing the building mass to alleviate some of the need to buffer the property from current or future adjoining land uses. We recommend that a focused EIR thoroughly explore alternative project designs that could reduce the number of trips and associated emissions from the project as currently proposed. Another consistency issue that warrants examination relates to the CAP goal to maintain, and improve where possible, the existing balance between jobs and housing needs. The City of San Luis Obispo is currently"job-rich" in this regard, with significantly more land allocated to commercial and industrial uses than for housing all those who work there. The proposed project would develop three warehouse stores above 100,000 square feet while concurrently reducing residential capacity by about 360 dwellings. This trend is clearly not consistent with the District's Clean Air Plan goals and should be evaluated in the EIR. Proposed Mitigations The District would like to acknowledge the efforts of the applicant in proposing alternative transportation facilities at the site to help mitigate expected traffic and air quality impacts from the project. Unfortunately, the measures proposed to date are unlikely to be effective at reducing private vehicle trips. For instance, the proposed establishment of a park and ride lot at the project site is unlikely to capture a significant number of commute trips since the City of San Luis Obispo, as a regional employment center, receives many more inbound trips during the morning commute hours than it generates. Likewise, the development of a transit center on site is a commendable concept. However, the primary design features of the project are an expansive parking lot and large building mass; both are considered significant impediments to the use of alternative modes j-61 of transportation. As pointed out in the SEIR for the Land Use and Circulation Elements: "... warehouse stores are less amenable to trip reduction efforts than most other kinds of development." Large parking expanses can actually generate a significant number of internal trips (trips generated within, and not leaving the project boundaries) since customers and patrons of tenant business are faced with long and possibly unsafe walking conditions. We recommend evaluation of project alternatives which incorporate smaller and/or more varied building mass with integrated parking and pedestrian access routes. Again, the proper vehicle for such an analysis is a focused EIR. Thank you for taking the time to consider our views and concerns regarding this proposed development project. If you have any questions or need additional information, please feel free to contact me or Barry Lajoie at 781-5912. Sincerely, Larry R Allen Air Quality Planning Manager LRA\BPL\tra H.IPLAMBARAY\WP51%1996AREFERAAf.\96M I BBPL MEMORANDUM Date: July 26, 1996 To: Ron Whisenand, Current Planning Manager From: NO Havrik, Natural Resources Manager Subject: Froom Ranch Commercial Expansion Project I have reviewed the submittal and argument from Central Coast Engineering regarding the above-captioned project, and offer the following observations: Items 1-2. These two items are related in my judgement Timing of the dedication is not particularly important as long as the commibnent is made. The now-lapsed'Social Security building"project on Higuera Street had a dedication requirement that presumably died with the lapsing of the project However,since this is an annexation,it might be reasonable to require the open space dedication at the time of the annexation,on the basis that it is firming up the urban limit line. I can also understand the concern over"double-dipping"of open space and ag land dedication. This project has perhaps a unique opportunity to dedicate open space that is also prime ag land. I am referring to the land south of the current Froom Ranch access,between Froom Creek and LOUR. I would offer the suggestion that such a dedication would be preferable from the City's standpoint and would obviate the question posed by Cental Coast Engineering. Item 7. The valley grasslands whether grazed or not are an important habitat for wildlife, and a significant food source for species such as raptors. Th Froem Ranch and Devaul property developments will collectively remove a significant area of such habitat,and this is a significant impact that needs to be addressed. I would expect that,if the City does not require analysis of this impact,citizens or State agencies will. This impact is far greater than just displacing some burrowing owls. Recommendation. I recommend that City staff suggest that an appropriate conservation easement on the valley floor at the time of annexation would obviate issues 1 and 2. 1 further recommend that the issue of loss of wildlife habitat is an issue that requires further it-depth study and should be included in a focused EIR. 100 SAN LUIS OBISPO COUNTY DEPARTMENT OF PLANNING AND BUILDING ALEX HINDS DIRECTOR BRYCE TINGLE ASSISTANT DIRECTOR ELLEN CARROLL ENVIRONMENTAL COORDINATOR BARNEY MCCAY CHIEF BUILDING OFFICIAL ENVIRONMENTAL DIVISION NORMA SALISBURY ADMINISTRATIVE SERVICES OFFICER July 18, 1996 Ron Whisenand City of San Luis Obispo 990 Palm St. San Luis Obispo, CA 93401-3249 RE: Froom Ranch development Dear Mr. Whisenand: This is in response to the letter requesting comments on the scope of the environmental review for the Froom Ranch development The subject property is currently outside the city limits of the City of San Luis Obispo, and if annexed it will be surrounded on three sides by property in the jurisdiction of the County of San Luis Obispo. Given its location the project would appear to have the potential to result in impacts to resources or areas located within the County's jurisdiction. In addition,there is the potential for impacts to resources located on the subject property. An EIR was prepared in 1989 for a general plan amendment (Madonna General Plan Amendment: G851030:2)proposed for property located directly south and east of the subject property. The proposed amendment involved a change of land use category from Agriculture to Commercial Service for an 80-acre portion of the Froom Ranch. Numerous issue areas were examined including: drainage and flooding, biological resources, air quality, archaeological resources, traffic, and land use. This document may provide valuable background information for scoping the City's environmental review. Issues areas the County feels should be addressed in the City's review of the proposed project include: 1. Traffic- Given the information indicated by the applicant in his letter,it is likely that the retail center envisioned will be regional in nature and will draw customers (and traffic) from surrounding communities. The impacts on surrounding County roadway facilities should be closely examined. Needed improvements should be identified, and the specific impacts of those improvements should be considered. 2. Drainage&Flooding-The project area is one that has experienced drainage and flooding problems in the past The project proposes a si_gnificant increase in paring and impervious surfaces. The site is part of the San Luis Creek watershed and any drainage or associated runoff may affect downstream properties, users and resources. Drainage impacts on and ,�70 COUNTY GOVERNMENT CENTER • SAN Luis OBISFO - CALIFORNIA 93408 (805) 781-5600 - FAX (805) 781-1242 OR 5624 paving and impervious surfaces. The site is part of the San Luis Creek watershed and any drainage or associated runoff may affect downstream properties, users and resources. Drainage impacts on and off-site should be carefully analyzed. 3. Biological Resources - Site specific analysis should be comprehensive. The analysis should address potential effects off-site. For example, sensitive wildlife species may use the area for feeding or foraging, even if the site is not used for nesting or burrowing. Specifically, wetlands exist on adjacent property or on properties in close proximity. Drainage and runoff from the proposed development may change the hydrology of these nearby wetlands, and may contribute contaminants from runoff to these areas. Care should also be taken in making sure that impacts resulting from other mitigation measures are also considered. For example if traffic impacts require the widening of Los Osos Valley Road, the impacts from this widening on the wetlands located adjacent to the road must be addressed at this time. 4. Air Quality - The project has the potential to affect area wide air quality. Both construction and operational emissions should be assessed. 5. Land Use - It appears that the proposed project is intended to be the first phase of a larger plan. This raises the question of whether the applicant is splitting, what is in reality; a larger project. This is not appropriate under CEQA as it may result in identification of some impacts as insignificant, when in fact they would be significant when considered in the overall scheme of a development. If this is considered as an isolated development, the precedent setting nature as well as the increase of conversion pressure on surrounding properties should be examined. It appears that a staged EIR would be perhaps the most appropriate document This would allow a more accurate analysis of the overall development scheme discussed by the applicant, and the area wide impacts associated with the project, but it could focus on the specific impacts of the first phase. In summary, it appears that the project as proposed has the potential to result in significant impacts to site specific resources as well as surrounding resources located in the county of San Luis Obispo jurisdiction. The above-mentioned issues should be examined in the appropriate environmental document. Feel free to contact me if you have any questions. Sincerely, STEVEN McMASTERS Environmental Specialist C- Mike Draze stevehvp/docAet/cslo-frm.let S9 LUIS OBISPO COURTY DEPARTMENT COUNTY GOVERNMENT CENTER • ROOM 207 • SAN LUIS OBISPO, CALIFORNIA 93408 j TIMOTHY P NANSON PHONE(805) 781-5252 • FAX (805) 781-1229 F COYiRY DKNKF@ ••• GLEN L PRIDDY D04M COUNTY DOURER SNOINESRm SERVICFS NOEL KING DEPUTY COUNTY SNORYER ROADS AD&RMS12AYIOM SOLID WASTE FRANCHISE ADMINISTRATION WATER RESOURCES July 18, 1996 COUNTY SURVEYOR SPECIAL DISTRICTS Attn: Whitney Mcllvaine City of San Luis Obispo Community Development Department INTER-OFFICE MAIL Subject: Froom Ranch - Revised Development Proposal Dear Ms. Mcllvaine: Thank you for the opportunity to provide input on the scope of the environmental review for the revised development proposal for the Froom Ranch property, on Los Osos Valley Road near Highway 101. You previously received (January, 1996) correspondence from myself, and from Louis Gibson of this department, regarding the previous development proposal, and many of the general comments in those letters still apply. I offer the following comments and suggestions for the current review process: Traffic The traffic impact study should evaluate the following scenarios: (1) existing conditions; (2) existing + project; (3) cumulative or"buildout" conditions; and (4) cumulative + project. It is very important to include all these steps, in order to identify which mitigation measures are the responsibility of the subject project, and which are attributable only to cumulative development and therefore should be shared with other projects. With regard to County facilities, we are the "minor player" in this discussion, as our only facility of concern is Los Osos Valley Road between Madonna Road and Highway 101. We are concerned that any improvements along this stretch of road include the entire segment, and not create any "bottleneck" points. Drainage Our main concern is with the historic problem of flooding in the San Luis Obispo Creek watershed, of which there have been several notable examples in recent years. However, I believe that our previous correspondence from Mr. Gibson adequately outlines those concerns, so I will not reiterate them here. 3-7� I look forward to continuing to work with you in the evaluation of the development proposals for this site. Please call me at 781-5280 if you need further information. Sincerely, ,CHARD MARSHALL Development Services Engineer File: PD - Froom Ranch t:\develop\rem\froom.ftr.Ina _ 3- 73 MEMORANDUM TO: Whitney McIlvaine, Department of Community Development FROM: Spencer Meyer, Fire Department SUBJECT: Revised Froom Ranch Proposal DATE: June 21, 1996 ACCESS: All proposed access ways (within and around this proposal) shall conform to all current San Luis Obispo Fire Department Development Guidelines. Required access ways (fire lanes) shall have minimum unobstructed width of 20 feet and vertical clearance of not less 13.5 feet. Dead-end access ways/roads in excess of 150 feet in length shall be provided with an approved turn-arounds. All primary access ways shall be designed as fire lanes. Required fire access ways (with minimum width) shall be posted with the appropriate signage to prohibit parldng. Required access compliance with reference to emergency response apparatus and required turn-arounds (travel distance in excess of 150 feet) is unclear based on the present submittal (scale) but appears adequate. FIRE-FLOW: Public distribution mains (within the City) appear just adequate to supply the proposed land-use. New private (on-site) distribution mains will be required and shall be capable of supplying the required fire-flows. Private fire mains shall be looped per NFPA 24. HYDRANT LOCATIONS: Public and private fire hydrants will be required (densities are inadequate with reference to the proposed land uses). Fire hydrants shall be spaced per SLOFD Development Guidelines (maximum of 225 foot intervals) and shall be capable of supplying the required fire-flows. It should be noted that LOVR is considered a "Major Roadway" (with reference to emergency response). Fire hydrants on opposing sides of the streets/roads shall not be used when determining required densities. General Notes: (1) All structures shall be protected with approved automatic fire sprinkler systems per NFPA 13. (2) When traffic control signals are installed, emergency preemption devices (e.g. Opticom systems) will be required to expedite emergency access. (3) History of the site is unclear with reference to the potential for environmental/agricultural contamination. (4) Approved graphic annunciator panel(s) shall be required in conjunction with required automatic fire sprinklers /alarm systems. (5) With reference to the developments wildland interface, consideration shall be given to developing and maintaining some form of a "green belt" between the structures and critical wildland areas (areas need to be well defined). (6) Plans lack the detail to definitively assess the proposed project for all Fire Department concerns with reference to life-safety and fire protection. (7) It has been noted that on sheet (Exhibit) F8.65, a median strip was shown running South on LOVR from Madonna Road. Although (aparently) not part of this proposal and realizing it is only a schematic sketch, this median design would not be acceptable without a service (return) entrance to fire station #4. c: Jerry Kenny Engineering Department Dan Gilmore, Public Utilities Department Ron Hanson, Fire Department February 5, 1996 "r MEMORANDUM TO: //��,, Mike McCluskey, Public Works Director FROM VJerry Kenny, Supervising Civil Engineer VIA: I! Wayne Peterson, City Engineer SUBJECT: FROOM RANCH ANNEXATION DRAINAGE STUDY THe "latest" version of the Froom Ranch drainage study, prepared by Central Coast Engineering, was received January 29th. Staff reviewed it and found the study to be satisfactory. It now shows that a substantial increase to existing (undeveloped) Q's would occur as a result of- the development, as proposed. This was the basic opposition staff had with the earlier versions of the report. The report summaries with the following noteworthy mitigations: 1. Detention basins (as well as improved channels and culverts) . are listed among the mitigation measures to limit the outflows to no more than existing undeveloped Q's. The final Q's may be subject to refinement in conjunction with design of the basins and other improvements. The County and Central Coast Engineering's calculations differ somewhat from that of City staff; Central Coast Engineering's developed Q's are higher (more conservative) than both the City and County. (County Q's lower than City Q's) The result of the report is larger detention basins. 2 . Sedimentation ponds would be constructed behind the proposed development to eliminate plugging of a proposed improved swale to pick up runoff from the hill above. 3 . A levee would be constructed along Froom Creek (between the project and US 101) where breakout has occurred in the past, resulting in additional flows onto LOVR. An agreement would be recorded that ties the responsibilities (and authority) to maintain any offsite facilities to the owner of the commercial development, regardless of the ownership of the properties. Staff also just received letters (attached) from George Gibson of the County Engineer's Office and .Lance Gorman, the CalTrans Dist.S Hydraulics Engineer stating that they have no objection to the project relative to drainage, subject to no added runoff generated from the improved project, as described above. Attachments: 1) Letter from George Gibson to W McIlvaine (2-2-96) 2) Letter from Lance Gorman to W McIlvaine (2-5-96) c: W McIlvaine, MB/HB/file- G: \. . . \froom\drainRep 3-76 FEB-05-196 MON 11:53 Ir TEL N0: #128 P01 ENGINEERING U S OBISPO COUnTY ' DEPARTMENT COU GOVERNMENT CENTER - ROOM 201 - SAN LUIS 011M,CALIFORNIA 93408 T1MOrnY K NANION PHONE (805) 781-5252 - FAX(805) 781-1229 ewlm twraamr *LOW L PAIMN _ SFAG 3 96 V. eavn aOYM}y DNuan 7wmrnrs wmou JWL ENO Post-It-brand fax transmittal memo 7671 IF of pages ca NOUD WArm POUreWA ADMINIrTIIAT)" February 2, 1996 prPG Phare %WIN wuavreu rrr r COUNTY turnmr • r •nein D)enen' y. MEMORANDUM TO: Whitney Mcllvalne, City of San Luis Obispo Planning FROM: George Gibson, Hydraulic Planning Engine SUBJECT: Froom Ranch Drainage Work After talking with Ben Maddalena of Central Coast Engineering (after he reviewed our letter to your department concerning the Froom Ranch drainage) 1 would like to clarify the County's position on our comments. If the development includes either full retention or detention facilities, therefore causing no increase to existing flows within the San Luis Obispo Creek watershed, our concerns and conditions for development would be met. We would view this as a no impact scenario on the creek watershed requiring no further Investigation or development of watershed management plans. If the development proposes a different scenario or alternative drainage solution which causes an Increase in flow to areas downstream of the project, potential impacts caused by this increased should be evaluated in a watershed management plan. If you have any questions or comments, please contact me at x4469. Fife: FC Zone 9 - General m:Veanne11ggVroom.mmo :TATE OF CALIFORNIA—BUSINESS, TRANSPO. .ION AND HOUSING AGENCY PETE WILSON, Govemor DEPARTMENT OF TRANSPORTATION 4IGUERA STREET !WIS OBISPO. CA 934015415 TELEPHONE: (8057 549.3111 TDD (805) 5495259 -. INTERNET httpl/www.dotca.gov/dLnOSt February 5, :1996 SLO-101-25 . 91 Development Drainage in Froom Creek Watershed from Froom Ranch Madonna Development San Luis Obispo Community Development Department Attn: Whitney Mc Elvaine 990 Palm Avenue San Luis Obispo, CA 93401 Dear Ms Mc Elvaine I was contacted, this morning, by Mr Kenny from the City Engineering Dept. regarding the proposed Madonna development along Los Osos Valley Road and adjacent to the Froom Creek Watershed. He informed me that- Central Coast Engineering (the designers for this project) had proposed developing a detention basin design to retain an adequate amount of runoff from the upland watershed to yield no change in flow rate downstream of the development. Mr Kenny also told me that the City of SLO had contacted George Gibson of the County Flood Control District for an opinion on detention storage standards. Mr Gibson' s response essentially reflects the State' s which is that no additional flows be generated as a result of development . The facilities conveying the Froom Creek and Prefumo Creek - drainage beneath SLO-101 are already stressed under high flows and no additional flow can be accepted. I am writing you to say that the detention basin approach is conceptually acceptable to the District 5 Hydraulics Department . . 1 would like to have the opportunity to review the specific design when it is completed for review. Please contact this office if you have any questions or comments regarding this project . Sincerely, Lance Gorman District 5 Hydraulics Engineer January 22, 1996 TO: Whitney McIlvaine, Associate Planner VIA: Jerry Kenny, Supervising Civil Engineer FROM: John Rawles, Traffic Engineer Terry Sanville, Principal Transportation Planner&7� SUBJECT: Critique of the Traffic Impact Study for The Froom Ranch (December, 1995) 1. (Existing Conditions; paae 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 clearer understanding of traffic at this location. 2. (Future Planned Improvements; pave iii, last paragraph; page vi, paragraph, &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, par-aaraph 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; pace iv, pwagraph 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 City-79 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 Traffic; 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; pace v) What is the first paragraph saying? 7. (Paridna Shorties; page 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 LOUR. 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. Acr 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 project 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 LOVR is operating at LOS C, what is the resultant LOS after the project is completed 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 turn traffic. What effects will closure have on the residential areas and the schools north of LOVR? 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 warrant improvements, the timing of the improvements, the responsibilities for providing them, and the 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 Corridor 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 35NTH south of Calle Joaquin 12. (Table 1; page 3) This table should be expanded to also identify changes in link LOS for each link and include the existing + proiect 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 Wanhnts, page 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? 17. (Project Traffic Distribution; page 23) The 885 inbound peak hour trips was reduced to 665 trips 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. (LOVR-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 ratings for existing conditions that may be drastically different than the actual existing conditions. The 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). , ��3 ❑ Traffic impacts of the project on LOUR 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.\wp51\froom2 _ �8y i4u;MU7 544-3276 #232 P01 Poat-It"bray._ .ax transmittal meoo 7871F0wP.s... CENTRAL COAST "�, v n. ENGINEERING ` 396 Buckley Road,suite 1 Sm LWs obupo 2 25 November November 1996 C&Ufbmla 93401 l 289 (805)3443278 PAX(800)541.3137 City of San Luis Obispo MEETING AGENDA Community Development Dept, DATE ' 'f'6 ITEM # _ 990 Palm Street San Luis Obispo, CA 93401.3249 Attn: Arnold Jonas Subject: Froom Ranch Commercial Project Appeal Arnold... On behalf of the Madonna Construction Company we are requesting a time extension of the scheduled 03 December 1996 appeal hearing to the fisrt meeting of the new year (07 January 1997?). Also, this past weekend's public notice in the Telegram Tribune stated the applicant was appealing the Pl&mM Cornminsion's recommendation for requiring a EIR Please let us know by phone if the hearing date is recommended for extension, and if the notice is problematic. Thankx for your consideration... Dennis c e: Ales Madonna Many Tamgeman 4KCAO ❑ FIN DP ✓ACAO ❑ FIRE CHIEF V ATTORNEY ❑ PW DIR 2/0LERWORIG ❑ POLICE CHF ; '--J MGMTTEAM ❑ REC DIR CRE,AD FV-E ❑ UTIL DIR � .1 MEETING AGENDA �i RECEIVE® DATE ITEM # ,NCV L � mn CITY COUNCIL leAN Vicon. CA November 26, 1996 San Luis Obispo City Council 990 Palm Street San Luis Obispo, CA 93401 Dear Members of the City Council: I believe that an EIR must be prepared for the proposed Froom Ranch annexation and development plan. As I understand, the proposal includes 360,000 square feet of retail space which could generate significant increase in traffic and air pollution in the surrounding area. These potential impacts must be assessed and mitigated. In addition, I believe that the growth inducing implications of this proposed annexation and development plan must also be addressed. I cannot attend the December 3rd City Council public hearing, but I would hope that you will require an EIR and deny the appeal. Please see that this letter becomes part of the public record concerning this proposal. Thank you. Sincerely, Beryl Reichenberg 308 Longview San Luis Obispo, CA 93405 CAO ❑ Fihi_;Z :CAO ❑ FIRE CH1E.- i/171 OR1JEY12 P41 D.R 1 :- . i_.... �. ❑ POL.CE WHr OR L l fAGLiT?PJa 1 ❑ REC DIF NO Q UTuL ON-11 CITY CLERK. ..:'0.CA