HomeMy WebLinkAbout04-05-2016 Item 8, HavlikCOUNCIL MEETING:
ITEM NO.: ,
March 22, 2016
Honorable Mayor and City Council
City of San Luis Obispo
990 Palm Street
San Luis Obispo, CA. 93401
RE: Proposed El Villaggio development on Los Osos Valley Road and Calle Joaquin
Dear Mayor Marx and Councilmembers:
I am writing on behalf of the San Luis Obispo County Chapter of the California Native Plant
Society.
We have some concerns about the so-called El Villaggio project on the John Madonna Ranch
and would ask you to consider those concerns before deciding to go forward with the project.
First of all, we recognize that a campus -like retirement facility at that site could be a community
benefit, providing security, attractiveness, and amenities to its residents, and incorporating
natural features of the site for the benefit of the entire City. We believe, however, that the
project as proposed is too large for the site, and violates several principles and guidelines of the
City's General Plan. We also believe that the inclusion of several clearly unrelated features take
away from the basic purpose of the project and only serve to take up more room. Therefore we
urge you to consider certain alternatives to the project. These are enumerated below.
1. Development above the 150 foot level. The City's General Plan requires that new
development in the Irish Hills stay below the 150 foot elevation line. The current proposal
ignores that restriction and extends well above that line in two areas of the property. In one of
them, there is a relatively small area now being used for equipment storage; in the other, there is
no existing development. The latter is a large plateau or flat which is undisturbed, and which is
known to contain at least two plant species of concern in the City's General Plan (Chorro Creek
bog thistle and clay mariposa lily) and likely others, based upon a survey from some years ago.
We believe that the City's General Plan should not be changed to accommodate the proposed
development on the plateau. Development there would be visible from much of the City and
would be radically different from what currently exists in the city limits in the Irish Hills. The
nearby Vineyard Church was developed in the County (which had and has no elevation limit for
development). You may recall that the Church made a conscious decision to develop in the
County rather than annex into the City; therefore the Church's existence in that location should
not be used as a justification for the City abandoning its policies in this regard.
In the northern area, a public amenity may be justified in the area above the 150 foot elevation;
this is explained below.
2. Protection of listed species. The Federally listed Chorro .Creek bog thistle occurs in several
areas on the property, and has been reported in other areas in the past. The project proposes to
stay 50 feet away from the populations of this rare plant; however, nothing is said about the
conditions that support these populations. This species occurs in wet areas such as springs or
seeps in serpentine soils. It is possible, even likely, that development around or near them could
change or interrupt the flow of groundwater and result in the destruction of the stands, especially
the larger northern one. The maps showing the proposed development are unclear, but they
appear to show development covering the small tributary stream near the southern boundary of
the property. This would be a violation of the City's Creek Setback ordinance, and would
destroy additional bog thistle habitat. (The writer observed numerous bog thistle plants on this
stream in 2010; plants which have presumably died due to four years of drought, and which
could return with sufficient rainfall.) It should be noted that both of these populations are above
the 150 foot elevation on the aforementioned plateau.
3. Realignment of Froom Creek and Destruction of Wetlands. The project proposes to "restore"
Froom Creek to something more nearly approximating an earlier alignment, which evidently was
changed at some time in the past. The proposal, however, seems to have more to do with
creating space for new development than any particular desire to "restore" the creek. The
proposed alignment would bring the creek very close to Los Osos Valley Road, picking up the
drainage alongside the road, and turning back to the point where the creek currently leaves the
property. This alignment would effectively destroy a rich and valuable wetland alongside Calle
Joaquin by grading, levee construction, and groundwater flow interruption. There is a seven acre
agricultural conservation easement that would be effectively destroyed by this realignment as
well; this easement was required by LAFCO as mitigation for impacts associated with
development of the Target shopping center some years ago. It is possible that LAFCO could
require retention of this easement or its effective replacement.
We believe that the Froom Creek realignment proposal sets dangerous precedents for the City,
and will face significant opposition from regulatory agencies and the public. Why destroy a fine
existing wetland by replacing it with a flood control channel? Please note that the realigned
channel will be an engineered waterway, and will have to be able to contain the 100 year storm
event: this practically guarantees that the "creek" will be bordered by a levee on one or both
sides which by its very nature will be upland, and will result in the need for significant mitigation
for otherwise unnecessary wetland losses.
4. Preserving Site History. The project proposes to preserve the historic buildings on the site in
some fashion. We support this idea, and suggest that the proper place to do this is the current
storage area on the property. This area could serve as an attractive location for a historic farm as
well as a small park (also proposed) and a trailhead into the Irish Hills Natural Reserve. Such a
public amenity might be justification to override the City's 150 foot elevation policy in this one
area; however, building an isolated group of single family homes would in no way provide such
justification.
5. Staying on message. This project has been primarily proposed as a campus -like retirement
complex for the community. Why then have the project sponsors thrown in single family homes
and apartments having nothing to do with the retirement facility? We suggest that the concept
of the retirement facility—and the retirement facility alone—be considered by the City. Such a
project would have a smaller footprint, could be fully accommodated below the 150 foot
elevation, would not require the realignment of Froom Creek (at least, not the wholesale
relocation being proposed), and could certainly fulfill this perceived need. It could still provide
the historic park, still undertake habitat enhancements to Froom Creek, and have a small retail
area oriented to serving the retirement community.
The City of San Luis Obispo is currently considering, or has already approved, hundreds of
single family homes and apartments within the city limits. Are two more isolated clusters of this
type really needed? We urge the Council to limit the potential for this development to a project
clearly more needed in the community, with a number of public amenities and benefits, and
without such disregard of the City's General Plan policies.
Thank you for the opportunity to comment upon this proposal. Please be sure to include CNPS
in any notifications regarding the project or its environmental impact studies and reports. We
will be prepared to comment in greater detail on these issues as the matter moves into more
detailed environmental analysis.
Sincerely,
Neil Havlik, PhD
CNPS SLO Chapter Ad Hoc Madonna Ranch Project Committee
672 Serrano Drive #11
San Luis Obispo, CA. 93405
805-781-9624
neilhavlik@aol.com
cc: D. Davidson
R. Hill
C. Kofton
S. Henry
W. Waycott