HomeMy WebLinkAbout01/31/1989, 3 - MADONNA PROPOSAL FOR DEVELOPMENT OF THE FROOM RANCH, WEST OF LOS OSOS VALLEY ROAD NEAR CALLE JOAQUI r r
�BIII�I��j���ll city o� San LUIS OBISpo MEETING DATE
1-31-89
COUNCIL AGENDA REPORT ITEM N
FROM Michael Multan, Community Development Director; BY: Glen Matteson, Assoc. Planner
SUBJECT: Madonna proposal for development of the Froom Ranch, west of Los Osos Valley
Road near Calle Joaquin.
CAO RECOMMENDATION: No action is necessary at this time.
BACKGROUND
Situation
The applicant has asked the county to change its general plan designation for an 80-acre
section of the 274-acre Froom Ranch, from agriculture to commercial, with parts to
accommodate auto sales, motels and restaurants, and offices and manufacturing. Also, the
urban reserve line would be extended to include the 80 acres. A draft environmental
impact report (DEIR) is being circulated for public review. Comments on the draft
received by the county environmental coordinator by February 1 will be included in the
final EIR.
This meeting is an opportunity for the council to become familiar with the latest
proposal. No formal action by the council is requested at this time. The city will have
additional opportunities to comment on the proposal before the Board of Supervisors acts
on it. A date for a board hearing has not been set.
Excerpts from the draft EIR, including the summary and project description, are
attached. A copy of the whole report is available in the office for councilmembers' use.
Issues/Response
The applicant previously approached the city concerning annexation and development of a
smaller area. The council chose to exclude the area from the urban reserve during
hearings on the hillside planning program. In response to the applicant's proposal to
the county, in February 1986 the City Council sent a letter to the county Board of
Supervisors saying:
A. The proposal conflicts with the city's general plan Land Use Element, which shows the
area as conservation/open space, outside the urban reserve line.
B. City water supply and sewage treatment are not adequate to serve the development
along with existing and potential development within the existing city limits.
C. The city is concerned with using on-site water supply and sewage disposal.
D. Much of the site is within the 100-year flood plain.
E. There is adequate space within the city for new offices and tourist businesses.
F. Development in this area with high scenic value should not block views or otherwise
detract from scenic values.
G. If the area is to accommodate urban uses, it should be annexed such uses should not
develop outside the city.
City of SJU g tins OBISPO
1=Igo COUNCIL AGENDA REPORT
Madonna proposal
Page 2 -
Staff Concerns:
Staff suggests the following for council's thinking:
I. The concerns raised on 1986 are still relevant and must be satisfactorily addressed
before any change for this area occurs.
2. The project as proposed should not be approved.
3. Further consideration of development in this area should --and will-- be part of the
city's Land Use Element revision and the county's revision of its plan for the San
Luis Obispo area.
4. There is more than enough office and service-commercial development potential in the
city and within the airport area, and more here would further imbalance jobs and
housing in the community. However, there may be justification for reserving some
area along Los Osos Valley Road for auto sales, especially considering city policies
to relocate such uses from downtown. Rather than more of other kinds of commercial
uses, any additional developed area should be used for housing, coordinated with the
Irish Hills expansion area to the north.
5. Hills above the 150-foot elevation should not be developed, consistent with the
alignment of the urban reserve line in the vicinity. Froom Creek should be
maintained as a natural area with unlined natural banks, adjoining riparian habitat,
and opportunities for public access. It should not be lined with concrete or
otherwise channelized.
6. Any proposal should address flooding and circulation problems in this area.
Staff has prepared comments on the draft EIR (attached). Our main concerns are:
A. Inadequate evaluation of alternatives, particularly omission of reduced-scale
alternatives.
B. Determining that the proposed project with minor variations is environmentally
superior, because offsite wetlands protection outweighs expected visual, air-quality,
and other wildlife impacts.
C. Inaccurate assessment of the overall imbalance between potential jobs growth and
potential housing growth.
NEXT STEPS
This meeting is for information and discussion. Sometime soon, however, the applicant
may want the council to indicate whether or not this proposal or some alternative might
be acceptable and if annexation would be reconsidered. Consideration of the general plan
update this spring appears to be the best forum for this discussion.
gm7: mad-cc Ju
i
DRAFT
ENVIRONMENTAL IMPACT REPORT
MADONNA
GENERAL PLAN AMENDMENT
(G851030:2; ED86-67
SCH # 8606 1811)
Prepared for
COUNTY OF SAN LUIS OBISPO
�! OFFICE OF ENVIRONMENTAL COORDINATOR
GOVERNMENT_CENTER, ROOM 320
SAN LUIS OBISPO, CA 93408
Prepared by
Hc=0 alram1p, IIfficeo
P.O. Box 6297
Los Osos, California 93412
NOVEMBER, 1988
I. INTRODUCTION 1
A. BACKGROUND 1
The applicant,Mr. Alex Madonna, is requesting to change an 80-acre portion of the 374-
acre Froom Ranch from the Agriculture designation of the Land Use Element of the County
General Plan to Commercial Service. The applicant is also requesting that the parcel be
included within the City of San Luis Obispo Urban Reserve Line, and an adjustment of the
Sensitive Resource Arra boundary to exclude a hillside terrace below the 225 foot contour.
To facilitate the conceptual development plan review and amendment process, the applicant
waived his right to an environmental determination and requested that an Environmental
Impact Report (EIR) be prepared on the General Plan Amendment and Conceptual
Development Plan. The County of San Luis Obispo Environmental Coordinator
subsequently retained The Morro Group, Inc. to prepare the EIR:
B. EIR CONTENTS
This EIR has been prepared in conformance with the California Environmental Quality Act
(CEQA)and its Guidelines for Implementation of the California Environmental Quality Act,
revised June, 1986, and with the County of San Luis Obispo Environmental Guidelines.
Contents of the EIR were determined from the results of an Initial Study prepared by the
County and responses from Notices of Preparation of an EIR sent to responsible agencies.
The Initial Study and the responses to the Notices of Preparation are contained in Appendix
A. Appendix B contains the County Planning Department Staff Report for the acceptance
of the General Plan Amendment for review. The EIR focuses on the following concerns of
which the scope of work for each concern is available for review at the Office of
Environmental Coordinator, Room 370, County of San Luis Obispo Government Center,
San Luis Obispo, CA 93408; (805) 549-5011:
• Geology,Soils and Seismic Hazards
• Drainage and Flooding
• Water Supply and Waste Water Disposal
• Biological Resources
• Air Q„ality
• Archaeological Resources
• Traffic and Circulation
• Visual Quality
• Agricultural Conversion
• Land Use Issues, including Land Use Assessment
Economic Analysis and Public Services
As directed by the County, background environmental reports submitted by the applicant
have been used as applicable in the preparation of the EIR. Copies of these reports are
available for public review with the County Office of Environmental Coordinator. These
reports are listed with an asterisk N in the References section of this report
C. USE OF THE EIR
1. County General Plan and Local Coastal Plan Amendment Process
The EIR will be used by the County of San Luis Obispo during the consideration of the
applicant's request for an amendment of the Land Use Element of she General Plan. This
procedure is described in the Land Use Element Framework for Planning and is
summarized as follows:
The EIR will be reviewed by the Planning Commission in conjunction with review
of the request for General Plan Amendment. A public hearing will be held on the
adequacy of the EIR as well as on the proposed amendment. The Planning
Commission will recommend to the Board of Supervisors what action should be
taken on the proposed amendments and EIR. The report from the Planning
Commission includes the reasons for its recommendation and its evaluation of the
relationship of the proposal to the General Plan and any affected amendment.
After a favorable Planning Commission recommendation or an appeal, the Board of
Supervisors holds a public hearing on the proposed amendment and may approve,
modify or disapprove the recommendation of the Planning Commission.
The County will hold the amendment request until one of three regularly scheduled
amendment hearings. All approved amendments will be adopted by board
resolution.
2. Development Plan Review
The conceptual development plan is reviewed in this EIR only to indicate the effects of
development under the General Plan Amendment if this amendment were approved. Once
the General Plan Amendment occurs, the applicant may submit a Development Plan or
plans based upon the new General Plan requirements for the subject area a for County
review and determination based on planning area standards.
3. Public Use of the EIR.
An Environmental Impact Report is an informational document which, when fully
prepared with CEQA and its Guidelines would inform the decision makers and the general
public of the environmental effects of a project that is proposed to a public agency for
approval. The CEQA Guidelines describe the basic purpose of CEQA which includes
public involvement in the decision making process.
Under CEQA, an agency must solicit and respond to comments from the public and other
agencies concerned with the project( CEQA Guidelines Sections 15073, 15086, 15087,
and 15088). For this ETR the County would provide public notice of the availability of
the draft EIR by publishing the notice in local newspapers and will send the EIR to
responsible public agencies for their review and comment. The EIR will be available in
local public libraries and the public is invited to review it within a 45-day review period
and submit their comments in writing to the Office of Environmental Coordinator, Room
370, Government Center, San Luis Obispo, California, 93408. Public hearings will be
held on the EIR at the Planning Commission meeting during which time public testimony
will be taken regarding the adequacy of the EIR..
H. SUMMARY
A. PROJECT DESCRIPTION
The applicant is requesting to change an 80-acre portion of the 374-acre Froom Ranch from
the Agriculture designation of the Land Use Element of the County General Plan to
Commercial Service. The applicant is also requesting that the parcel be included within the
City of San Luis Obispo Urban Reserve Line,and an adjustment of the Sensitive Resource
Area boundary to exclude a hillside terrace below the 225 foot contour.
B. ENVIRONMENTAL IMPACTS
Environmental impacts and mitigation measures are summarized in Table 1. Impacts are
divided into: 1) those that are unavoidable adverse impacts and which cannot feasibly be
mitigated, 2) those that are significant but which can be mitigated; and 3) those impacts that
are adverse but which are not significant. Those significant effects that cannot be mitigated
will require a Statement of Overriding Considerations by the lead agency.
C. ALTERNATIVES
Alteratives considered were the"no project", implementation of a mitigated development
plan including California Department of Fish and Game (CFG) Wetlands Policy
mitigations, alternative General Plan designations, and annexation to the City. The "no
project" alternative is not the recommended action, because it would leave the property
agricultural use which could, with increased agricultural production, result in removal of
the wetlands C.N.P.S. listed plant species without mitigation. The mitigated development
plan including the Wetlands Policy mitigations is the recommended alternative.
The mitigated development plan alternatives assumes that the General Plan Amendment
would occur as proposed but that the California Fish and Game Wetlands Policy mitigation
measure, mitigation measures to protect C.N.P.S. listed plant species and other mitigation
measures to reduce identified significant impacts would be implemented. The
implementation of these mitigation measures would 1)allow for"in-kind off-site wetlands
mitigation to offset the unavoidable destruction of approximately 40 acres of"man-made
wetland;" 2) would reduced development on the terrace to protect significant areas of
C.N.P.S. listed plant species; and 3)would require the applicant to protect area of special
plants located adjacent to the development area. Further information regarding this
alternative is contained in Section VI, and in the Biological Resources evaluation, Section V-
D, of this EIR.
D. RECOMMENDED CONDITIONS OF APPROVAL
The mitigation measures are summarized as follows to provide the decisionmakers with a
listing of those which are recommended to be attached as Planning Areas Standards to the
General Plan Amendment, and those mitigation measures which are recommended to be
considered during development plan review. -�
• _i 1
1. General Plan Amendment Planning Area Standards
The designation of a possible new land use trend for industrially oriented commercial
service uses west of Highway 101 away from the Airport Specific Plan Area could be
mitigated by restricting uses to certain retail commercial service uses and office space, and
by discouraging manufacturing and industrial related uses in the area. It is recommended
that the County consider amending the General Plan for the auto park area as commercial.
service, a portion of the business park as large professional offices (such as insurance
companies, corporate offices, and complementing commercial service uses such as
newspaper companies, printers, etc.), and the remainder as Tourist Commercial. This
would serve as a better control for the type of developments that could locate in this area.
Please refer to Table 2 which designates possible land use designations as given in Table O
of the Land Use Element
If the mitigated development plan is selected, the GPA should include designations for
Commercial Service with limitations on use to auto park on the lots fronting Los Osos
Valley Road, business park for the remaining developable lots and open space designations
for areas so designated on Figure 21 in order to protect sensitive biological habitats. If the
CFG Wetlands mitigation alternative is selected, then the uses should be changed as
described in the paragraph above.
The City of San Luis Obispo Land Use Element-allows large professional office buildings
which can include multiple tenants but with no single tenant space less than 2,500 square
feet within commercial service, designations subject to the approval of a Planned
Development A similar provision could be established in the proposed project area which
would discourage small professional offices and would be in keeping with the City's desire
to locate the smaller professional offices near the downtown core and in close proximity to
medical facilities.
It is recommended that the City and County review standard conditions and ordinances to
ensure that-all new projects are required to "pay their fair share"by providing development
fees (or improvements)to meet the cost of necessary public services.
2. Conceptual Development Plan
The following recommended mitigation measures apply to the proposed action. Similar
mitigation measures would be required if either of the alternative development plans were
selected as the environmentally superior alternative.
Gradiniz Plan
At the Development Plan stage of project review, the applicant shall submit a Grading Plan
as defined in Section 22.05.024 of the LUO with the following additions or clarifications:
Design of Phases l and 2:
1. Remedial measures proposed to mitigate adverse foundation conditions and
shallow groundwater problems as now known and which are to be further
clarified by additional soils engineering investigations.
2. The grading and remedial measures proposed by the applicant from among
potential alternatives to mitigate soils problems identified above.
II-2
3. Since fill is to be excavated from sources on site, the Grading Plan shall
identify the areas from which the fill is to be obtained, the results of grading as
required by LUO Section 22.05.024(b), and the estimated volume of material
to be obtained from each location.
4. If special materials will be required to implement remedial measures, then the
volumes of such materials, their source, necessary hauling on public roads,
numbers of truck loads,etc., shall be identified.
Design of Phase 3
5. In addition to the normal requirements for a grading plan for Phase 3, the
design of this phase shall include special detail as to the measures to be
implemented on Lots 21 and 22 to mitigate surfacing groundwater problems
consistent with measures as may otherwise be required to mitigate impacts to
sensitive biological resources.
The information provided above will be reviewed by the Office of the Environmental
Coordinator, and an environmental determination will be issued as required under
Section 22.05.030 of the LUO.
Drainaste
Measures to control drainage from springs in the Phase 3 area may result adverse impacts
on the biological resources dependent on the water from these springs,and the mechanisms
of control should be reviewed by the Office of the Environmental Coordinator at the time a
Development Plan for this phase has been prepared.
Dependable Groundwater Sunviv
The water resource beneath the site is probably capable of supporting low-water demand
uses such as those identified for Phase 1. However, prior to approval of high-demand
uses such as motels or restaurants, further clarification of the capability of the resource to
sustain long-term demand should be provided. This clarification may be provided by the
study now in progress by the City of San Luis Obispo. If additional information or studies
are required, this would be determined at the stage of Development Plan processing that
proposes the higher-demand uses.
Sewage Disposal
On-site sewage disposal may be feasible using engineered systems for those uses having
low rates of wastewater generation. If such systems are to be used, the proposed design
shall be submitted as a part of the Development Plan for those uses requiring such systems.
If on-site treatment with off-site disposal of wastewater is proposed, a preliminary
configuration of such a system shall be submitted with the Development Plan application
for uses requiring such a system. The preliminary configuration shall include at least:
• The location of and type of treatment system proposed. }
• The areas of spray and/or flood irrigation proposed, with percolation testing of /
the proposed site adequate to establish its capacity to infiltrate and/or evaporate
11-3 jny
l
the volumes of effluent to be disposed of.
• The location and capacity of wet-weather storage to be provided and the
rationale for the rapacity proposed.
• Identification of the public entity that has agreed to operate the system.
• Any additional information requested by the public entity that has agreed to
operate the system.
• If disposal is proposed on slopes steeper than 10%. a soils engineering and
engineering geological investigation shall also be submitted that establishes that
the slopes in the area of disposal will be stable with application of the proposed
volume of effluent, and that the effluent will be contained within the proposed
disposal area.
Biological Resources
Wetlands Habitat Preservation. If the project is approved as proposed, it is recommended
that the California Department of Fish and Game Wetlands Policy be enforced in the
following manner.
1) Applicant agrees in concept to set aside wetlands habitat that is to be destroyed
on a one-to-one basis on other properties owned by the applicant adjacent to
existing wetlands prior to Development Plan approval.
2) A biological project team consisting of a qualified biologist with knowlege of
wetlands and the project site,a representative of the California Department of
Fish and Game,a representative from the Office of Environmental Coordinator
and the applicant or his representative,shall determine the best location for off-
site, in kind mitigation and the amount of acreage to be set aside in perpetuity
for wetlands habitat, and necessary improvements to ensure that the property
has similar characteristics to the wetlands on the Froom Ranch. Adequate
buffer of the wetlands should be included in the acreage and improvements.
3) The project team determines the best mechanisms for protecting the chosen off-
site wetlands area, either by open space easement, dedication to a land bank or
other state or private concern, or other means acceptible to the applicant, County
and California Department of Fish and Game. The mechanism determined
should then be executed and necessary improvements made to the satisfaction of
the project team.
4) If possible, the applicant should complete the above program under items (2)
and (3) above prior to issuance of building permits for the project site, or a
schedule of improvements should be set up and a completion date determined.
If the wetlands area is not set aside prior to issuance of building permits, then
other incentives should be established to ensure that the above is completed.
Vegetation Protection. The majority of the C.N.P.S. listed plant species are located in the
area of Lots 23 through 31 and west of Lot 25. As an incentive for protection, it is
recommended that.the biological team consider this area as an On-site, Out-of-Kind
II-4 �r
I 1
mitigation, and provide acreage credits against the in-kind, off-site wetlands habitat to the
applicant if this area can be set aside as open space. A reorganization of Lots 21 and 22
could provide a building area on the knoll for commercial or office uses, provided the
outcrops and sensitive vegetation could be buffered from development impacts.
Burro Ana Owl Habitat. According to conversations with the consultant biologist, the
burrowing owl may or may not mate and nest in the same areas for its entire life cycle
might relocate to nearby areas. There are other area within the vicinity that can be used for
burrowing owl nesting areas, including areas downstream on Froom Creek. However,
realignment of Froom Creek should be done so as to provide habitat of similar value
downstream for use by burrowing owls assuming that flooding problems can be resolved
in the process.
Construction should not occur during burrowing owl mating and nesting season. To
ensure protection of the burrowing owls, a qualified biologist should conduct surveys
prior to construction to determine if burrowing owls are present. If no owls are present,
then construction could proceed.
Archaeological Resources
The two archaeological sites identified on the subject parcel are in excellent condition and
are considered significant cultural resources as defined in CEQA. As currently designed,
the project lots 24, 25, and 26 may directly and indirectly adversely effect the two
archaeological sites;and require mitigation measures as follows:
1. The subsurface boundaries of both sites need to be defined as well as the nature
and internal organization of each site. This can be done using a hand auger(10
cm. dia.), and small V2 meter or 1 meter square excavation units. All soil
should be screened with a V16" mesh and cultural materials saved for
laboratoryanalysis. It is estimated that 10 to 20 auger borings should be made,
and 4 to 8 test units should be excavated. three shell samples should be
collected from Site 2 and submitted for C-14 dating to determine the dates of
occupation. this should take about 1 week with a crew of 2 or 3 people.
2. All cultural materials should be processed and described in a report of results
complete with reaps showing subsurface boundaries. The report should also
contain final mitigation measures. This is expected to take 1 archaeologist about
10 days for laboratory analysis and report preparation.
3. Once the accurate boundaries of the two sites are determined and mapped, the
project should be redesigned so as to avoid directly impacting either site. they
should be left in open space if possible or capped with clean imported soil. The
sites should be protected from future relic collectors. It is suggested that a
performance bond be obtained to prevent accidental damage during the
construction phase of the project. The consulting archaeologist should work
closely with project designers to achieve these ends.
4. If during subsequent construction activities associated with this project, any
isolated or buried archaeological materials are unearthed, it is recommended that --
a qualified archaeologist be contacted to evaluate what was unearthed and to
make appropriate recommendations regarding its treatment as outlined by CEQA
and the San Luis Obispo County Land Use Ordinance.
n-S -/D
-- Traffic and Circulation
In conjunction with Phase 1 construction, Los Osos Valley Road.should be widened along
the project frontage to provide four continuous through lanes. Street "A" should be
extended to Los Osos Valley road opposite Calle.Joaquin (north leg). Calle Joaquin(south
leg) should be connected to Street "A" approximately as shown on the development plan
(Figure 3). The on-tamp connection to Los Osos Valley Road should be reconstructed to a
design satisfactory to the county Engineer and Caltrans.
The applicant should enter into an agreement with the county and Caltrans to participate in
the cost of installing traffic signals at the two intersections adjacent to the project
The final development phase of the project should be conditional upon widening the two-
lane sections east and west of the project
In the design of Phase 3, unless there is assurance that Street"A" will be extended to Calle
Joaquin, it should be terminated in a cul-de-sac.
Project design should include treatments to facilitate and encourage the use of non-auto
modes of transportation. Possible treatments include recessed bus bays and bus stops on
Los Osos Valley Road, and bicycle storage areas at commercial, office and industrial
developments. Some employees could be required to provide areas for bicycle users to
change clothes and shower.
Az6culture
Any cow-calf production occurring on the subject property should be transferred to nearby
property owned by Mr. Madonna which is already in rangeland, thus preserving the
marginally economic benefits of the project site.
Land Use
The County should consider reduction of undeveloped commercial and industrial
designated areas in other less suitable locations as a mitigation measure for over-supply of
such land. Additionally, the County could consider special growth management programs
to regulate various types of commercial development to balance employment with housing
and/or to reduce possible overbuilding based on short-term economic factors.
II-b �s//
U
_ .eC3r C
c0 Cj V
y C oG0 00
Liz
GL° CA G,V3 (A
y >
c
o e
is �, 'vi.�E
., V1 .Q �
Z
OCO
�
ee�i Cmu
- ' m° vw Mo
go
0 .0
ooE cc
d C R
ccy
Otio_ _
oho E - °a�
ani = as ° _ CZ
act.- Z 0120
—
�= > o � er�oU � Hw mEc, E
V
F �� QE.i4cH`a zcs Z2`o °2'
a Qv
("0 W
z �y
> Z o w
W - a a � °' '
en ev = `
�.CC�
ZT � o°' E ,o� E IC o
y
— O C C13Ue � � a�C7 € C6.
.9: v
0
co
3'vru- Ooc°� Ja
Lu
> U
Z N
R .
'E E
u o
V C
y
Q �
Y
m
O y >
m
Como .Q C o f w O c `o "a.s
,>, a � a ° o 'er cc3
- u y
e F O ` o mE Vic, o000
we>i u > � Ewa.
Q- QS a:G o:aE Q43 m .. C3
z az r) a -�
Fcin
> gs �e sV a •v
W rn� o mE _.ca _ E � � m
Vo. -c E � 43 u °c
w
o a $ 4.) E o a=
oj
mo qa
Q, R R V . >fC/�
EA 42
rn
f.
200 � z
w C O E m 0 = m Jr.
Oui 4j
eo `° = c .. yEa. w R a "= Ccc LW H
zm
Q7 m
� o
� � 3 = 4
z c o c y y s E:
U _
C C C C cCc�� cCc��
t. L t4 L L L L
V! d0 oc0 u � oc0 � oC0
� 'N y O y in •N •N
^� y ■.Ci ►C. CS.r rC. ^ r.Ci
�1
V!
N
W r
O � E
u u a w ea
V oc > a
a e 3
cw °
0
a' Z C C L °' C Q 00
''91 a a R Z, C
ao 'O = y
� O •� �v a a>i �c 3 � c � u m ° n. r1
a 00 96 go 0
ba bo
C e4 C C N
Ad c H a }
� e
0
a
o -
a c a c ° v
3 e
° ae
O �
y U v E u O E E o
OC . = m ct m > e
O U c �
v� Q ° w •o � o c c
ticc �a
W U y N
ra
C C
p o a�
° W N.-7 D aold, 0.
c a
.2 U -
W a S c4 c =
U W o
H
0
III. PROJECT DESCRIPTION
A. LOCATION AND EXISTING USE OF THE SITE AND
SURROUNDING AREA
The proposed project site is located within the County of San Luis Obispo on the southwest
boundary of the city limits of the City of San Luis Obispo, as shown on Figure 1. The site
generally is bordered on the northeast by Los Osos Valley Road and the San Luis Obispo
city limits, on the north, west and south by the Irish Hills and grazing land, and on the
southeast by Calle Joaquin Road and U.S. Highway 101.
The project site is an 80-acre portion of a 374-acre parcel, as shown on Figure 2. The
project site comprises assessor's parcel number 67-241-19. The property is owned by the
applicant,Alex Madonna.
The site is currently known as the Froom Ranch and is used for cattle grazing. The ranch
house and barns are located off the site. Froom Creek traverses the property.
B. HISTORY OF PROJECT AND PROJECT OBJECTIVES
1. Project.Objectives/Specific Request
The applicant is requesting to change an 80-acre portion of the 374-acre Froom Ranch from
the Agriculture designation of the Land Use Element of the County General Plan to
Commercial Service. The applicant is also requesting that the parcel be included within the
City of San Luis Obispo Urban Reserve Line,and an adjustment of the Sensitive Resource.
Area boundary to exclude a hillside terrace below the 225 foot contour.
2. Background
Prior to 1980 and adoption of the current Land Use Element of the General Plan, the site
was designated A-1-5 (light agriculture with a five acre minimum parcel size) within 250
feet of Los Osos Valley Road. The rest of the site was zoned A-1-3(Light Agriculture with
a three acre minimum parcel size).
The City's 1977 General Plan designated the valley floor as Interim Agricultural and within
the Urban Reserve line, but the terrace area was outside the URL and designated
Conservation/Open Space. The City subsequently revised its Urban Reserve Line to
exclude the valley floor portion of the site, as an incidental action initiated as part of the
"Hillside Planning Program."
This decision was reflected and.reinforced by LAFCO sphere of influence and service
studies,since the exclusion from the URL meant no anticipated urban services. Adoption
of the Land Use Element in 1986 designated the site in the Agriculture category and outside
the Urban Reserve Line for the City of San Luis Obispo.
The applicant submitted a similar proposal to the City of San Luis Obispo in March, 1985.
This application involved a 60-acre portion of the Froom Rancho from Los Osos Valley
Road to the 175 foot elevation (as opposed.to the 80-acre portion to the 225 foot elevation
III-1 j//'
SA% LUisiro 'NATIONA�'cur\R�t' '_ J Figure 1
. t,.•
hr // ' w`51 % .�'7 ate. LOCATION MAP
FtKgJ0NAt6 an
' �• C?10RfLCS..+ . � ;� Scale. 1"=1.6 mi.
en
Amon
C„• .` 0(),,'1L... ti ,,,�.a�. ' i4 Uunitrµty� p•' .} I '. '��r '�.
`rte ,-�- ,-�� I._` •� .a, -, >\/ /' _ �.'__'\• \ f�` :\C:^=��i(. ' '..
,N;Sat, Lzris
.
f'•-:( �:.�\� �C )1�� t..'...- �,nJ �,�1;�`•:��f,� `/Nf nii,BtelV•) ...,�; �/� ` 4f
✓- i - / ?�� 1„"_y `•` Ent' i
_ Z• HoITT
lm x,
ice`,_ 1 `l M\`•.'rte I_ ` � �"� 0✓ \
;:1 1.:. -.fes/ M ..,( •\``. .Q
�' \ J•f.O -, 1'.'� r NNLL"a iank5•(•AUTIV
Yl f
_� ..,• �S'Ie\^ �, •gig :• -, .; 'il:'''.._ _ '.. -; '_' �' _,`/._
rZ
L- 't.'d � h��,' JICC�• ,t'r�l/' t'�C-r `•V
�r-=,�/�. T -�`.. 1 t•�/? n to .�' _ `,:�'.;' . ''3L.}',"i /�' M �: ��? {�I ^I' -7
WG• U
XX
'�• .ice 1,111{ ftint
✓,.
' r+�
US COAST GUARD ✓'•pJCIL
wSi (�-•()�.
.RESERVATn
San Lua Shell Beach
,n
Figure 2
VICINITY MAP
y� \,•a' 1 � I
lag
Y — I
�\
Scale: l"=2,000'
\° �4 .
Base from USGS Pismo Beach Qlrad=gle, 1978 ♦•, I
tb
and San Luis Obispo Quadrangle, 1979
. ;Wier •t
,. .• - ''� ,� 'N.1 ,_ I arty
Athletic '40
!cs} ,� •YVat
•
Field
Ta+ �:-� 1', Ta In A4Jc.l
•.•. ti..•.; ;�. w
/ ••::•BMs I6�1 �y tw�•�'"����•�. N '° `;� / /� _ •
j• •�Y.p+,/ '•�,f• SellWith•'"...ti•,•�_•.`y..�♦ "y Q,�Pj • � F Illi
01,
y J•ti iY \Park
0 Golft13 p Ila.
,.� .,• ±le ' Once-,n �•1� IT
/ Couf� n nosier •i; iryl
EL
p. (BOAOwt' r.^•-•.+,•�+�,, �t� �ell;.,.�.6..•• tr'.'.•13 7+' - ~ Z.
pit
-Tanks `�., :r'•rI n J Y .• «t'E4+ x•;11+ [- _ _
• •t.,r•..y tl�r� hl.l`� `r C,I •J. TFad
-t, ,?tom •,�..' Y�r.y.�1 `�„ '2 •, Sewage rk
Well �/ / "N*Disposal
tit
Well
_ /r` 4,�•� .' -. //s �' Trader
Park
•�•-�• ♦ � 516 •'. • � _. - .. '1, + •
San uis Obispo
Dr
\ `� �'•.,. �•;,l\' 4iC'" • . .i I: °� Trader •
�\ `�� •l.-'��a_`OOfts _ _ .: 101 Cn�} ParY 'I
1 _� ,�1171• _ _ __:_ � , � =
L e r•
1 R �II a �� � ..-. ♦.1�� .. y °. 'L
.1•r* �' \♦� .I ''0 /�•/_� ..a 10 'e I
am
J !„
Dillg1 I a
1 � (r
A,1 1
1,
General Location currently before the County). The application was fora change to the
Urban Reserve Line to include the property within the City's urban reserve, and a land use
designation change from Conservation/Open Space to Interim Conservation/Open Space.
Eventual uses of the property were assumed to be similar. After an appeal of the negative
declaration was upheld, requiring a focused environmental impact report, the project was
withdrawn by the applicant.
C. PROJECT CHARACTERISTICS
This EIR will address the request for the General Plan Amendment to change the current
Agricultural designation to Commercial Service, the request for inclusion of the 80-acre
parcel within the San Luis Obispo City Urban Reserve Line, and an adjustment of the
Sensitive Resource Area(SRA) boundary to exclude a hillside terrace below the 225 foot
contour(see Figure 5 in Environmental Setting, Chapter IV, for location of Urban Reserve
Line).
1. General Plan Amendment
The applicant requests a General Plan Amendment change from Agricultural designation to
Commercial Service. The request also includes changes in Land Use Element text to place
this portion of the project site and lower hillsides within the urban reserve line but outside
the urban services line of the City of San Luis Obispo, thus allowing a phased development
plan which is not dependent on city services or annexation into the city limits.The applicant
also wishes to relocate the Sensitive Resource Area boundary from the 175 foot contour to
the 225 foot contour within the subject parcel. The current Airport Review and Flood Plain
Designations would remain the same.
The General Plan Amendment would include limitations on allowable uses. Table O of the
Land Use Element specifies the allowable uses within the Commercial Service category
(see Table 2 in Chapter IV for the listing of allowable uses). The applicant wishes to limit
the allowable uses and phase development within three sub-areas. The limits to allowable
uses would be by sub-area as follows:
Sub-area 1-Auto Park: This area fronts Los Osos Valley Road and includes
lots 1 through 4. Uses would include auto and vehicle dealers and supplies,
service stations, auto repair and service and temporary or seasonal retail sales
uses.
Sub-area 2-Tourist Commercial: This area is highly visible from U.S.
Highway 101 and includes lots 5 through 9. Uses would include hotels,
motels, transit stations and terminals, eating and drinking places, food and
beverage retail sales, service stations and temporary or seasonal retail sales
uses.
Sub-area 3-Busine33 Park: This would be the remaining property as shown
on Figure 4 and includes lots 11-31. Uses would be limited to business support
services, offices, electronic and scientific instruments, printing and publishing,
small scale manufacturing and storage(accessory) uses.
In-4 ����
2. Conceptual Development Plan
If the proposed amendments to the General Plan are approved, the applicant intends to
submit a development plan and tentative tract map for subdivision of the 80 acres into 20 to
31 parcels ranging from one to five acres. The EIR has been prepared considering the
maximum development of the applicant request of 31 parcels as conceptually subdivided in
Figure 3. It is also assumed that building coverage on each of the lots will average 24% of
the total lot area. Acreages for each of the proposed lots are given on Table 2. The phased
development of the property would begin along Los Osos Valley Road, progress onto the
valley floor interior of the proposed business park, and conclude with the lower, adjoining
hillside terrace.
Except for site preparation grading, development would be confined to portions of the
property with slopes less than 20 percent. The steeper slopes between the valley floor and
hillside terrace lots would remain in permanent open space and would be specified as such
in open space easements.
The hillside slopes above the 225 foot contour would be retained as agricultural and rural
lands, and would retain the SRA designation. This property would.be precluded from
further development,with the exception of accessory structures necessary for maintenance
of agricultural uses and the proposed water storage tank.
3. Site Alterations
Site alterations include grading for flood control and proper drainage, construction of on
site street improvements, water system, sewer and public utility improvements, and
realignment of Froom Creek.
To reduce flood problems on site, the applicant's representative indicates that the flat and
floodprone valley floor near Los Osos Valley Road would be required to be filled with
approximately one to three feet of material cut from the foot of the hillside slope and from
excavation from the realignment of the Froom Creek channel. Approximately 60 acres of
relatively flat valley floor lands would require balanced site preparation grading but no
importation or exportation of fill materials are expected.
The applicant is also proposing as further flood control measures, the construction of a
drainage retardation and debris basin at the mouth of the canyon above the project, and is
proposing to contribute funds to the county, Caltrans or Zone 9 Area in proportion to the
increased run-off created by the project, for eventual reconstruction of the inadequate
Froom Creek culverts under U.S. Highway 101. If necessary, temporary on-site drainage
retardation basins on individual lots would be integrated into the project to detain any
increased surface flows in order to prevent aggravation of existing on-site and downstream
flooding, until the freeway culverts are reconstructed.
Froom Creek channel within the subdivision is proposed for realignment in the area where
the creek exits from the narrow hillside canyon and turns south at the edge of the valley
floor(Figure 3).
4. Services
The applicant intends to develop a separate water system and private septic or sewage.
collection and treatment system. No City services are being proposed for the project site.
M-5 JW/
NUICK
LEGEND
AUTO PARK LOTS 1 -4 OMI[[AY
TOURIST O �A /
COMMERCIAL: LOTS S-9 �
O1
BUSINESS : LOTS 10-71 t
1 �O
CYEMREO 8"THE olArPHNf VRI. A/R( TOO
FORD rr
,\ YtIMYLi Aip ,fit
13 eo VI
((
HONDA
FR0011 RAO14
I
i 12
r aaAwn 3 To �
is
a
250
1 O
o ...
10 I' s [rrir'
17 9 %%
7
i \ is \
11 �
31 ` �1 •: /
I
30 19
) ) r 02228 23
2f, s •Ro""
27
24 g
� rf
26
1 _ I
I
I 25oof
Figure 3 _
CONCEPT DEVELOPMENT PLAN
c
Table 2
AREA CALCULATIONS BY LOT
MADONNA GENERAL PLAN AMENDMENT
LOT NUMBER AREA (ACRES) LOT NUMBER AREA (ACRES)
1 2.8 17 1.5
2 2.8 18 1.9
3 2.8 19 1.8
4 2.8 .20 1.9
Subtotal 11.2 21 2.4
5 2.8 22 3.1
6 23 2.1
7 1.8 24 2.4
8 1.9 25 1.8
9 2.3 26 1.7
Subtotal 8.8 27 1.7
10 2.2 28 1.8
11 2 29 1.8
12 2.2 30 2.7
13 2.9 31 3.3
14 3:3
15 1.6
16 1.5 Subtotal 47.6
TOTAL ACREAGE'• 67.6
• Less than I acre
••Excludes roads and other off lot improvements. -
III-7 ��� /
The water system would include new on-site wells and pumps which would be
interconnected for an adequate quantity and quality supply of groundwater, and would be
pressure pumped through an on-site transmission line connecting to a new hillside storage
tank. This system would provide gravity feed(or if needed would be pressurized) at levels
sufficient for fire flow, and would include a system of lines and hydrants to serve all lots
within the proposed subdivision.
The initial phases of development would utilize individual private engineered septic
systems. As an alternative and if necessary, a community sewer collection and treatment
system would be developed utilizing a packaged plant with disposal of effluent either by
hillside spraying or irrigating of an adjoining agricultural area. The developer has indicated
several alternative methods of effluent disposal, and will utilize the most feasible and cost
effective method.
S. Street Improvements
The development of the project would provide for the completion of Los Osos Valley Road
as a four lane arterial street west of the interchange ramps from Calle Joaquin intersection
through the intersection with Auto Park Way. As further traffic mitigation measures, the
applicant is willing to offer right-of-way on both sides of Los Osos Valley Road northeast
of the project to facilitate City and/or County construction of regional arterial street
improvements on those two-lane segments linking with Madonna Road, across
undeveloped portions of his ownership. The applicant will also participate or contribute
one quarter of the cost of signalization of the Calle Joaquin/Los Osos Valley Road
intersection or freeway on and off ramps, when the City, County and/or Caltrans determine
such improvements are warranted.
III-8 �• .
IV. ENVIRONMENTAL SETTING
A. PHYSICAL SETTING
The proposed project is located on the south side of Los Osos Valley Road and westerly of
its intersection with Highway 101. The northeasterly 40 acres of the site (Phases I and 2)
are on relatively flat terrain of the valley of Prefumo Creek, and are underlain by
recent alluvial sediments derived from the Irish Hills to the southwest. These sediments
are high in clay,and groundwater is at relatively shallow depth. The shallow groundwater
supports a"man made" freshwater marsh on the easterly third of this portion of the site and
along the northeasterly boundary, and intermittent flows in.Froom Creek support riparian
vegetation. The remainder of the valley portion of the site is covered by grassland and as
pasture.
The southwesterly 40 acres(Phase 3) is primarily hilly terrain developed along the lower
slopes of the Irish Hills. The most significant topographic feature on this part of the site is
a gently sloping terrace at about the 200-foot contour. Relatively flat areas at about this
same elevation are also present to the south (Figure 2), and this topographic feature is
probably an old terrace level of San Luis Obispo Creek. Vegetation on the terrace is
primarily grassland, but local springs support isolated areas of freshwater marsh and
narrow riparian corridors. The small canyon below the terrace supports a local coast live
oak and California bay woodland.
B. SURROUNDING LAND USE
Surrounding land uses are shown on Figure 4. On the northerly boundary of the proposed
project is the remainder of the Froom Ranch which consists of grazing land and the Froom
Ranch buildings. To the north of the Froom Ranch and north of Madonna Road are
residential areas. On the southerly boundary of the project site are existing tourist
commercial uses consisting of a gasoline station, the Columbia Restaurant, and a Howard
Johnsons and(recently developed) All Star Motels. An unoccupied restaurant which was
previously The Spirit Night Club is also located in this area. To the east and across Los
Osos Valley Road are the existing auto park,a commercial service complex,and additional
tourist commercial uses including two restaurants, a motel, two service stations and an
AAA office. West of the site is open space lands.
C. GENERAL PLAN CONSISTENCY
This section provides information as to the consistency of the proposed project with plans
and policies as stated in the following listed documents. It should be noted, however, that
it is the responsibility of the Board of Supervisors to determine consistency issues.
• County of San Luis Obispo General Plan Land Use Element, a Framework for
Planning and the San Luis Obispo Area Plan
• City of San Luis Obispo General Plan, Sphere of Influence Boundary and
LAFCo Sphere of Influence Study for City of San Luis Obispo
% County of San Luis Obispo Airport Area Specific Plan, preliminary reports
N-1
�.�3
Figure 4
SURROUNDING LAND USES
lea. l
Scale: 1"=2.000' 4
Base from USGS Pismo Beach Quadrangle. 1978 1 t
and San Luis Obispo Quadrangle. 1979
5
Maisano.-
!6B'
'\ /• i1t I Aller
�� I kms'
rk
\—r.-- ----�— Athletic a �d u^ 74=<% '■'1 — ' .Wet
.Feld i7fc•'e,'Iw•~:S. ., /: y ' •� w yi/ \ • \\T2 kk 434
f .BML t67N1 aay,.�,y !fft• ~�+. `' 4- `tea-_�• :� d� �`�': �
! �:'.•.t, .• .•:bar :A .e'. c 7 —
r.. 5 13 l ,
/;i4�' • C GGOoY11rS/l� -},,,� t)Y 'i�Ly'9:n•:• ".Wti :• ' _ ./•^� �1' I1 GG
nve-InTra,Ir
.I
lell �.1 Theater 'Par'
k' •„b ,gip:..;..'...:,:. '1 \ 11l".
fir:: '.`•--.''.: .
'.i BOrrOra•: • :+.... `"•., ..
12
Sankt •'� ?'I :' n ! � v' i :>..il� " ..
w,;:>• _
�7
t
ial
' •.r .+r ,\i:.: .•:;y?:. _ <w�nweil •� Sewage
� .,�• .Park
.i�-- :o e.�•. 1
1 ter
vau
ParkCre i
�vN
- Lam• ''4 lal �. }�'r' Tr;/k!r •
124jai) �,� ,J ;,'`\�,._,-�1' •�, 1� uKEY
W./N' Ir�l ( I a 1 All Star &Howard Johnsons Motels
Columbia RestaumnL Chevron Gas Sta
�
2 Tesaco and ARCO Gas Sts, AAA. Hobs
Big Boy, Denys,Motel 6 &Border Ptrl
3 Vacant C•T Lot
z
.�� i 1�;'l�l����.ei1\•y ^_' ' ' J,• a Recently constructed retail center
,^ / I 1 (i� `• 1 11�,r/ t ! \,F 5 Auto Park
6 School
7 Residential. Single Family
: o I, 8 Agricultrual property-Froom Rauch
� r 9 Agriculuual property-De Vaul
10 Residential. Multi-family
/ 11 Madonna property—ptn DAB&
(% 12 Zapata Farms—pm Dalidio
13 Madonna Plaza-Central Coast Plaza
! °s 14 Fire station
i
f \�J 15 Post Office
16 Retail Commeraal
:._. `\'- 0.I 1 — See Also Figure 3 for adjacent uses
ewcx
LEGEND
AUTO PARK LOTS 1 -4 moon
oat»
�� ♦
COMMERCIAL: LOTS S•0 c � � /�
BUSINESS: LOTS 10-)I , JPO
•RE»•aCO N T»■tANNNG tat .•1RL �
• rom"D
•�:' •. .:: AMC
RENAULT P
AINCIA
-X.
I■OYN WON t:•`• .. ...•.. !'
.•:,+•,•.est�,. 8
:
of :• ••.,••
t
e
0
1
► 1
i
i
220
AMC
W.
am
I r ,
CZ Wiliam VEGETATION COMMUNITIES
Valley Grassland Transitional Area D
Coastal Scrub :::::::::::'::Meadow Grassland 422M Treas
arlaa
Live Oak Ri Figure 14
�'• ' °'`
�__.- Freshwater Marsh Bay Woodland F
(silverweed), Rumex conQlomeratus (knotted dock), Solidasro guiradonis (marsh
goldenrod),Tvoha angustifolia(narrow-leafed cattail),Twha latifolia(broad-leafed cattail)
and Zannichellia a u is (homed pondweed). Locally, Bacc a is dou asii (marsh
baccharis), a subshrubby species, occurs among other marsh plants.
2) Rivarian Community
Riparian communities are common along waterways such as drainage channels, streams,
lakes and marshes. These waterways, drainage channels and areas of high water tables
often have a striking influence on natural vegetation of the area. Many of the plant species
found in riparian habitats are restricted to the flood plain, banks of streams, drainage
channels and other areas where they have access to a shallow water table. The riparian
plant community is the characteristic vegetation along Froom Creek and smaller drainages
that pass through the project site. This community overlaps with the freshwater marshes in
several places on the study site. Within the boundaries of the proper project, the riparian
vegetation is variable, ranging from woodland to rocky stream channel. It is found along
the drainage that parallels Los Osos Valley Road,along Froom Creek and along the smaller
creeks that drain the southeastern portion of the subject site and the adjacent portion of the
Irish Hills to the west(Figure 14).
The drainage that occurs immediately along Los Osos Valley Road is lined by herbaceous
species typical of the freshwater marsh areas listed above along with willows Salix
lasioleois and 5AM lasiandra . In some places the willows are scattered along the channel
while in other places they form a dense cover. This riparian zone extends along the eastern
property line(Los Osos Valley Road)and along the southern property line(boundary of the
city limits) from Los Osos Valley Road to an area near Froom Creek.
Froom Creek is the major drainage channel and flows in a north to south direction through
the subject property. It is lined by riparian vegetation that varies in structure and
composition depending on waterflow, terrain and past disturbances. The creek channel and
floodplain is composed of large rocks(mostly of serpentine origin) which is indicative of
the large amount of water that flows from the Irish Hills during the rainy season. The
channel has relatively distinct boundaries in the canyon west of the study site but the
boundaries become less distinct where it empties into the valley floor in the northern
portion of the study site. Here it becomes diffuse and forks forming a large floodplain area
with large rocks in lots 12, 13, 14 and 15 of the proposed development. The C.N.P.S.
listed chorro bog-thistle occurs in this floodplain area in lots 14-15 (Appendix Figure E-5).
As the creek flows southward through the subject property, the channel again becomes
more defined, partly due to the construction of berms. The riparian vegetation along the
portion of Froom Creek that traverses the study site is variable. In some sections there are
scattered willows [EAM lasioleois (arroyo willows)and 5AM sitchensis (velvet willow)]
while in other areas there are mixtures of scattered shrubs and herbs without willows.
Common species are Baccharis dou asi' (marsh baccharis), Artemisia dousrlasiana
(mugwort),Toxicodendron diversilobum (poison oak),Xanthium stmmarium (cocklebur),
Nasturtium offrcinale(watercress), Mimulus sruttatus (common monkeyflower), Rumex
spp. (docks), Poivoogon interruvtus (ditch polypogon) and PolvDoaon monsveliensis
(rabbitfoot grass). In some of the wetter places along the creek, sedges, rushes and other
species common to the freshwater marshes occur along the creek.
The drainages in the southwestern portion of the Froom Ranch flow seasonally but were
mostly dry during the bri-site survey. These were perhaps drier than normal because of the
timing of the survey(during the autumn following a dry year and dry summer and before
the first fall rains). However, even so there were places along the drainages that still had )
standing water with aquatic plants and animals. For the most part, these drainages are
V-32
(Q
irllj IIII'�I IIjI�II III'Ili�i�r I Iji nl�lij'I��i ri iI
IIIJ�►j! ,, city of San WIS OBISPO
990 Palm Street/Post Office Box 8100 • San Luis Obispo, CA 93403.8100
January 18, 1989
County Environmental Coordinator's Office
Room 370
County Government Center
San Luis Obispo, CA 93408
Attention: John Nall, Environmental Specialist
SUBJECT: Comments on draft EIR for Madonna plan amendment (ED86-67)
Thankyou for the opportunity to review this EIR. These are our comments:
Items affecting hniq conclusions 2L ther r
Item Page Subject Comment
1, II-3 Water The city's groundwater study to date will not help clarify
adequacy of groundwater on the project site. The first phase
was an overview of potential yields in the San Luis Obispo
subbasins. The second phase was drilling and pumping test
wells, which appears to be the only way to accurately assess
availability in the highly variable subbasins. Assessment of
reliable yields is preliminary, and will require years of
pumping experience to verify. In the meantime, the city is
being cautious in counting potential well yields toward "safe
yield" which can be allocated to additional development.
2. IV-9 Consistency Raising the urban reserve line from the 150-foot to the
225-foot elevation contour is not consistent with the
"community characteristics" of urban reserve line location to
the north and the break in slope between nearly flat and
hillside areas, as reflected in the city's hillside planning
standards. The fact that some city water-pressure zones can
provide service to higher elevations is not relevant here.
3. IV-9 Consistency In the first paragraph under item 2, the word "improvements"
should be deleted from the sentence describing uses for areas
marked for conservation/open space.
4. IV-10 Consistency The project is not consistent with the city's policies for
minor annexations, because it (1) includes more than 25 acres
for urban development, (2) does not meet hillside planning
criteria, and (3) at full development it would increase demand
for city water supplies.
f
Madonna EIR comments
Page 2
Item Page Subject Comment
5. V-5 Grading The import of "special materials" would seem to require use of
public roads or quarrying on this or neighboring parcels, which
is not considered in the EIR.
6. V-7 Grading Concerning item 3.b, realigning the creek and cutting away the
hillside to fill the lower parts of the site does not minimize
grading.
7. V-14 Creeks City policies discourage lined channels in place of natural
creekbanks unless there is no feasible alternative. The
Department of Fish and Game will probably concur in this.
Since the site is not constrained by existing development, the
alternative of a sufficiently wide channel with natural banks
is available. Throughout this discussion, the term "channel
changes" would be more appropriate than "channel improvements,"
unless the changes will actually improve habitat, scenic
values, and downstream flooding conditions, in addition to
on-site water-carrying capacity.
8. V-21 Water There is another estimate of groundwater basin yield: the
city's Groundwater Study (John Wallace and Associates, March —
1988), which says, "the South Central San Luis Obispo area
could support [groundwater withdrawals of] approximately 1000
acre-feet per year." The referenced area includes and is
substantially larger than the Madonna property. So far, the
city has drilled wells within the "south central area," but
outside the Madonna property, which have been estimated to be
capable of yielding as much as 795 AFY (though the actual yield
will be less due to water quality problems and well operating
practices). Assuming the 1,000 AFY estimate of subbasin yield
is valid, subtracting the 795 AFY estimated maximum yield of
the recently drilled city wells from the 1000 AFY leaves 205
AFY which could be withdrawn from other wells. These estimates
of groundwater potential do not reflect additional withdrawals
by others within the subbasin.
9. V-22• Water The EIR contains an estimate of groundwater storage, but not
reliable yield. We expect competition for groundwater to
become more intense as urban development increasingly relies on
it. Eventually, this may lead to limits on pumping to protect
this shared resource.
10. V-24 Water Maximum pumping rates cannot be equated to reliable yield. In
the case of the city's six test wells, including four in this
general area, maximum pumping rates would yield 1,035 AFY.
However, the amount available to the city water system, after
considering water quality, stream habitat protection, and
feasible pumping rates, was determined to be about 450 AFY.
Madonna EIR comments
Page 3
Item Page Subject Comment
11. V-27 Sewage Use of on-site sewage disposal appears impractical; on-site
treatment with off-site disposal would require operation by a
public entity (R.W.Q.C.B. criteria). The city will not operate
such a system, and city and L.A.F.C. policies oppose creation
of such entities at the edge of the city.
12. V-27 Water Again, any clarification of the groundwater situation by city
studies would indicate less availability than assumed in the
EIR.
13. V-39 Wildlife Grading building sites and draining the springs which provide
shaded pools in the vicinity of lots.21 - 24 would destroy this
habitat, a factor which appears to have been given little
weight in concluding that the proposed development plan, with
minor changes, is the environmentally preferred alternative.
(See also items 15 and 29.)
14. V-40 Wildlife While DFG cannot veto land development projects, it can
advocate land-use choices and reduced-scale projects, in
addition to advocating conditions of project approval.
15. Wildlife habitat/Other .impacts/Alternatives
V-45 In our view, the EIR is flawed in concluding that commercial development is
the preferred alternative since more intense agricultural use under the
existing designation could also destroy on-site, "man-made" wetlands. It
appears to rationalize the project, without evaluating impacts
consistently. Consider:
VI-2 A. The EIR does not include a reduced-scale alternative, and
it offers no evidence that such an alternative would not be
"viable." What is the acreage that must be developed for a
viable project?
VI-5 B. The habitat values could be protected by adding a sensitive
resource designation and additional standards to the basic
agriculture designation. This possibility is not mentioned.
V-59 C. The land was used for a dairy --a fairly intensive
livestock operation-- followed by land rental for "a variety of
summer crops," apparently with no significant, lasting harm to
the special plants or wetland habitats.
V-62 D. When discussing alternative production practices under a
continuing agricultural designation, the report concludes "it
would be highly unlikely that a major change in crop
enterprises would take place."
Madonna EIR comments
Page 4 /
Item Page Subject Comment
15. (continued)
VI-1 Previously, the report said loss of habitat could occur under
an agricultural designation, but that more intensive use is
"highly unlikely." Here, the report says "The adverse
biological impacts of development ... would occur whether or
not the property were left in agricultural use." These varying
points of view are not consistent, but are central to the
report's conclusions.
16. V-47 Habitat How can realignment of Froom Creek, especially if it lined,
provide habitat of similar value on-site or downstream?
17. V-56 Views Developing above the 150-foot elevation would conflict with the
city's hillside planning policies.
18. V-57 Views The EIR suggests landscape screening so large vehicle-display
lots along Los Osos Valley Road will not be so unsightly.
Based on city experience, car dealers can be expected to resist
any measures to reduce their visibility from Highway 101 and
Los Osos Valley Road.
19. V-57 Views The proposed development of this site would be regarded as
expansion --not infill— under the planning concepts the city
has used since the 1970's.
Residential development of the Irish Hills area to the north,
consistent with thew city's adopted plan, probably would not
appear similar to the proposed commercial development. Compare
the Edna-Islay residential expansion area's Tank Farm Road
frontage to the Auto Park Way.
20. V-63 Ag land First paragraph, last sentence does not make sense. How can
the County's deciding there is enough farm land lead to
concluding that pressures to urbanize farmland are lessened?
21. V-74 Induced growth Designating more land for commercial/industrial use invites
its development and encourages owners to seek land users,
thereby stimulating more relocation of industry to this area
than would have happened otherwise.
22. V-74 Impact type Commercial development and resulting revenues would not be a
beneficial impact on the natural environment, though they may
be seen as an overriding consideration justifying the project
despite significant, adverse impacts on the natural
environment.
23. V-75 Housing The report incorrectly concludes that there will be no.impacts
due to lack of housing in the area. The number of college
students enrolled and the number of jobs in the community
already exceed housing opportunities. In studies for the
city's current general plan update, we found that full J410 .
Madonna EIR comments
' Page 5
Item Page Subject Comment
23. (continued)
V-75 Housing development of all areas in and next to the city would result
in housing demand growth exceeding housing supply growth by
about 4,000 dwellings (even with development of all the
residential expansion areas shown in the city's current plan).
If this project would result in demand for 1,000 more
dwellings, the shortfall would increase to 5,000 dwellings.
The last sentence of the "Housing" paragraph embodies a fallacy
which causes housing impacts to be understated. The issue is
overall balance of jobs and housing, and capacities for
employment-accommodating vs. household-accommodating
development. It makes no difference whether the households
drawn to the area by additional commercial development live in
existing housing or housing which they occupy first. The
current residents of the "existing housing" must be accounted
for when new residents move in.
24. V-76 Growth Another accounting problem: When those employed in the area
move to a job position in a new development, their previous job
position is filled, unless employment in the industry or firm
is declining. The net increase is therefore not lessened by
such moves within the community.
Is there any evidence that a greater number of employees will
be drawn from families already residing in the area than
assumed? The origin of the City's employees, the evaluation of
relocation potential in the fourth paragraph of page V-74, and
the proportion of the county's population growth due to
in-migration (recently, about 90%) all seem to suggest the
opposite.
25. V-77 Cumulative We disagree that a ten percent addition to an already
unbalanced situation is not significant. Also, like statewide
loss of wetlands, no one project makes a dramatic difference.
However, these additions to commercially designated land add up
to substantial cumulative impacts. Further, the city and
county recently received applications for a major business-park
project ("Obispo del Sur," east of the airport) which should be
included in this assessment of cumulative impacts.
26. V-79 Housing The report rather glibly observes that housing impacts will be
reduced since 56% of the demand will be met outside the San
Luis Obispo area. Such displaced demand only shifts the
impacts to other communities, including some (Los Osos, Morro
Bay) with more stringent development limits than San Luis
�., Obispo. The housing in such places will not remain "moderately
priced" if demand increases faster than supply, due to
excessive commercial and industrial development in the county.
Madonna EIR comments
Page 6 J
Item Page Subject Comment
27. V-80 Phasing To the extent that the identified phases would contain
different kinds of uses (auto sales vs. offices), there would
be no advantage in requiring 50% occupancy of phase.one before
allowing development of phase two to begin .
28. V-92 Streets The report discusses "temporary dead-end street A" in relation
to maximum cul-de-sac length, but not dead-end street C. Why
is C street stubbed rather than terminated in a cul-de-sac? Is
there an intention to accommodate development on the adjoining
property? If so, the growth-inducing and cumulative impacts
should be evaluated.
29. V-103 Air quality The city, in adopting its general plan Water Management
V-104 Alternatives Element, endorsed a countywide policy of "no significant
VI-1 deterioration" in air quality. Our recent public opinion
VI-5 survey found that residents want to keep our current,
relatively good air quality, and that they are willing to
forego additional commercial development to do so. This
report, we believe correctly, concludes that development of the
proposed project along with other, already designated
commercial land will have a significant,adverse impact. Also,
there are no measures which will significantly reduce this
impact. Given these conclusions, and the concerns about
jobs/housing balance, on what basis did the authors decide that
offsite wetlands protection compensates for all other types of
impacts, making the proposed project with minor changes the
environmental superior alternative?
A project with lower intensity and reduced commercial area
appears to be superior.
30. VIA Alternatives We suggest evaluation of a reduced-scale alternative, which
would not encroach into the hills and which would include a
residential component, consistent with the city's plan for the
area to the north (schematic map attached).
31. VII-I Growth Again, the housing impacts are incorrectly stated. Also, the
report does not take into account "multiplier effects:"
secondary demand for services and development which will follow
from the direct increases due to this project. Such
secondarily induced growth will probably cancel out some of the
assumed impact reductions from project jobs being filled by
unemployed people already living in the area.
32. VII-2 Growth The report again understates housing impacts by losing sight of
the big picture: jobs and housing are now out of balance; city
and county plans already allow a larger capacity for
development which causes housing demand than for development
which meets housing demand, even though housing capacity is
substantial; this project would worsen the imbalance.
Madonna EIR comments
Page 7
Item Page Subject Comment
33. V-17 Flooding Will the fill displace flood waters onto lands which do not now
flood? Will additional downstream channel changes be needed to
prevent more flooding than with pre-project conditions?
34. III.5 Open space The project description says the part of the ranch' not proposed
now for development (most of the hills) "would be precluded
from further development," but implies that this protection
would come from retaining the current land use element
designations (which can be changed) rather than a by dedication
of a permanent open space easement. This should be clarified.
Technical j= not affecting basic conclusions of Litt r r
35. I-2 Process Local coastal plan does not apply.
36. II-6 Traffic Some employers, not employ2M could be required to provide
bicycle amenities.
37. II-6 Land use The report notes that there is an oversupply of
commercial/industrial land and recommends reductions in such
designations, but does not suggest locations.
38. III-1 Background Adoption of the County Land Use Element in 1980 designated the
site in the Agriculture category.„
39. II1-3 Figure 2 The applicant's entire contiguous ownership should be shown, to
better portray the whole site under consideration.
40. throughout In the text, Figure references do not correspond with numbers
on the Figures themselves.
41. throughout Several grammatical and typographical errors we can point out,
if you wish (marked in copy on file in our office).
42. V-49 Archaeology San Luis Bay, not Estero Bay, is about five miles south.
Estero Bay is about eight miles north.
43. V-60 Ag uses "However, as stated earlier, specific conditions exist that
have made the production of intense row crops [not]
economically feasible." There was a discussion of comparative
advantage, but the specific conditions were not made clear.
44. V-63 Crop acreage If Table 8 shows acreage changes per year, as stated in the
text, rather than over the period 1973 - 1986, it should be so
labelled.
C -
Madonna EIR comments
Page 8
Item Page Subject Comment
45. V-69 Land use The city has not received an application or a county referral
for the De Vaul/Irish Hills area, so we are surprised at the
precision of the potential development description.
46. V-70 Industry Fifth paragraph, first sentence does not make sense.
47. V-73 Land use So far as we know, the KSBY proposal for a lot on Auto Park Way
is no longer active.
48. V-74 Economics This phrase is confusing: "...if the airport area specific plan
can capture one-half or 14 percent of the market share with 600
acres..." Perhaps "or" should be "of."
49. V-84 Bicycles The consultant may not have observed bicyclists on this segment
of the road because the existing two-lane road is dangerous for
cyclists.
The EIR should be revised to address our comments concerning water, plan consistency,
grading, growth inducement, housing impacts, and assessment of alternatives. Other city
departments may have additional comments. -\
We will have additional comments on the project itself. /1
Please contact Glen Matteson in this office (549-7165) if you have any questions.
Sincerely,
/L•tiG�y�'�it�t.-
Michael Multari, Director
Community Development
copies: Planning Commission
City Council via CAO
gm7: mad-eir
• � ALTER . .
. Nq vie
PRO
jEC
T
� r
z'c
ith �,,I\
\� Sch
;•
Li
"O .•: " ..:...r Tv CO
•-:•�••• `.•: cam.--+•-•: '�:'•-- •- -
COP
20
.•'. ' _ .;}':t:•:,:; -•�•�•: `�-.- -• :•lF.-•. �..:�.o. ,' .ter ;• , � , /i .
- •fir-, ��.;::;': :1.� fi'. •::•:;':�