The URL can be used to link to this page

Home My WebLink About07-18-2016 Correspondence - Public Comment (McLean)Evidentiary Errors/Omissions Pertaining to Oliveira Environmental Consulting, LLC Initial Study/Mitigated Negative Declaration For the 71 Palomar Avenue Multi-Family Residential Project Evaluation Of Environmental Impacts: 1) “The project has potential to impact ﬁsh and wildlife resources and shall be subject to the payment of Fish and Wildlife fees pursuant to Section 711.4 of the California Fish and Wildlife Code. This initial study has been circulated to the California Department of Fish and Wildlife for review and comment.” Comment: Where are the comments from the CA Dept. of Fish and Wildlife? Aesthetics 2) “The proposed project is in an urbanized section of the City on a site that has generally ﬂat topography, sloping gradually toward the north and east. Although the project site exhibits a fairly open lot conﬁguration dominated by the Sandford House and associated outbuildings, the project site is surrounded by similar higher density residential development (with the exception of the single-family neighborhood to the south) and does not contain unique visual features that would distinguish the site from surrounding areas, nor is it located within a designated scenic vista.” Correction: This topographically prominent site is not “generally ﬂat”. This site does contain “unique visual features”. The mature tree canopy is a large part of the property's aesthetics. 3) “…there would be no change to existing conditions regarding scenic vistas or scenic resources.” Correction: The scenic vistas from the homes along Luneta and Palomar would deﬁnitely change. Biological Resources 4) “These areas typically provide low potential to support native plant or animal species occurrences. Within the City limits, occurrences within urban/developed areas would consist primarily of urban‐ adapted avian species such as house sparrow (Passer domesticus) and Eurasian collared dove (Streptopelia decaocto) utilizing the abundant tree canopy and concentrated food sources, common animal species adapted to human presence such as raccoon (Procyon lotor), opossum (Did” virginiana), and striped skunk (Mephitis mephitis), and aquatic, semi aquatic, and terrestrial species resident in or utilizing riparian areas. The mature landscaping present at the project site provides the tree and shrub habitats that have the potential to support wildlife habitat limited primarily to urban-adapted avian species discussed above.” Correction: The mature stand of trees support at least 19 species of birds as well as pollinating pastures for bees and butterﬂies. 5) “No heritage trees or signiﬁcant native vegetation exist on the portion of the site to be developed.” Correction: Why is there no mention of “signiﬁcant non-native vegetation”? There are 48 old- growth, specimen trees slated for clear cutting and these are clearly located on that "portion of the site to be developed”. 6) “This includes mulberry trees/shrubs, pine trees, olive trees, decorative palms, larch or spruce trees, eucalyptus and redwood trees.” Correction: Where is the precision and/or accuracy in identifying these trees? Cultural Resources 7) “…Master List of Historic Resources on the basis of architectural signiﬁcance as an excellent example of the Colonial Revival style of American architecture.” Correction: This is a modiﬁed Italian Renaissance Revival style of American architecture. Greenhouse Gas Emissions 8) Correction: This section is limited to carbon emission reduction strategies. No mention is made here of the removal of mature trees that are far more effective in sequestering carbon than the sapling trees and bushes that will replace them. No mention is given to how these mature trees use far less water than do sapling trees and bushes. Water is a resource that is becoming scarce due to climate change. No mention is given to design strategies to maximize daylighting of interior rooms thereby reducing electricity use. Land Use and Planning 9) “The project is also consistent with neighborhood circulation plans in the General Plan and is discussed below in Section 16. Impacts are considered less than signiﬁcant.” Correction: Opening up Luneta will create havoc with pedestrian, bicycle and vehicular circulation on Palomar, Serrano, Broad, Luneta and Ramona. Noise 10) “Residential uses would not result in substantial changes to the existing noise environment. Other noise sensitive uses in the vicinity include other neighboring residential developments. These uses will be shielded from noise generated by residential uses by distance and by the structures themselves.” Correction: High-density student-oriented residential projects such as these do in fact result in substantial changes to the existing noise environment. Moreover, the additional number of vehicles and the four story parking garage will contribute greatly to increased noise on the aforementioned streets. Population and Housing 11) “The proposed project includes construction of a multi-family residential development…” Correction: A better term to use here is “high-density residential development”. The term of “multi-family” is misleading as the design of these apartments will not accommodate families. There is virtually no storage, closet space, no children play areas, easy access to parking, easy access to trash bins or privacy provided in these apartments. Nor are the cramped, galley kitchens designed for families. Transportation/Trafﬁc 12) “While existing streets have sufﬁcient capacity to accommodate the added vehicular trafﬁc without reducing existing levels of service..” Correction: Palomar, Serrano, and Ramona are not designed to accommodate the added vehicular trafﬁc, particularly if Luneta is opened. Evidentiary Errors/Omissions Pertaining to “Archaeological Resource Inventory, Signiﬁcance Evaluation, and Design Review” Submitted By Applied EarthWorks, Inc. October 2015 1) “The repositioning of the historic residence will, as proposed, allow construction of a new 41- unit apartment building on the west and north portions of the parcel.” Correction: The apartment building complex can be built without relocating the historic residence. 2) “Historical research identiﬁed 13 owners of the subject property, although it does not appear that the ﬁrst three owners made any improvements to the property.” Correction: It does not appear that the ﬁrst TWO owners made any improvements to the property. 3) “While no speciﬁc information was located conﬁrming Wills-Sandford as the builder of the residence, the timeframe of Wills-Sandford’s ownership as well as his afﬂuence make it likely that the residence was constructed circa 1895 during his era of ownership.” Correction: This is pure speculation. Wills-Sandford’s wife was the oldest daughter of Chauncey Hatch Phillips. There is no evidence that Reginald Wills-Sandford was “afﬂuent” or if his afﬂuence might have resulted from his wife’s inheritance. However, it’s much more likely that Reginald’s father-in-law selected the architect and ﬁnanced the construction of the house on behalf of his eldest daughter. 4) “Jacobson was also a central ﬁgure in bringing the ﬁrst television station to the region, founding KVEC-TV in 1953.” Correction: Important omission: In 1953, Jacobson became the ﬁrst female to own a TV station in America. 5) “By 1966, the property was owned by Alexander P. and Carolyn J. Quaglino.” Correction: Important omission: The Quaglino’s were roofers. The property needed a new roof and the Quaglino’s took title to the property in exchange for replacing the roof (presumably the roof conﬁguration was changed at this time from the original hip style to the Colonial gable style). 6) “The modern stucco siding is not original, and it is not known when that modiﬁcation was made.” Correction: This statement needs further substantiation. The stucco siding could be original to the house. 7) “ The original windows were likely wood multi-light double-hung windows or wood French doors, which are both features of the Colonial Revival style.” Correction: The arches over these windows are NOT features of the so-called “Colonial Revival style”. These are features of the Italian Renaissance style of architecture (see illustration below). 8) “While documentation of the speciﬁc date of construction was never located, research indicates that circa 1895 appears to be the approximate date of construction. This date is consistent with the general time period associated with the Colonial Revival style and is associated with the ownership of Reginald Wills-Sandford, likely the ﬁrst occupant of the residence, and for whom the building is named.” Correction: The general time period associated with the Colonial Revival style here in San Luis Obispo is NOT circa 1895 but much later. 9) “The Sandford House is an example of the Colonial Revival style of American architecture. According to the City Guidelines: The Colonial Revival style refers to a revival style popular in the early twentieth century that was inspired by the early houses of the Atlantic seaboard.” Correction: Applied Earthworks initially states that the Colonial Revival style of architecture was popular around 1895. Later, the consultant states that this style was popular in the “early twentieth century”. Which is it? 10) “The City Guidelines brieﬂy list characteristics of the style, which include: A hipped or gambrel roof…” Correction: In this case the City Guidelines are in error and this should be corrected. Colonial Revival style residences are predominately gable roofed, not hipped, have ship-lapped siding and are not stuccoed. On the other hand, Mediterranean or Italian Renaissance style architecture lacks dormers, lacks shutters and is predominately stuccoed, all characteristics of the Sandford residence. 11) “The subject property does not appear signiﬁcant for any association with the lives of persons important to local, California, or national history…While Jacobson began the KVEC television station in 1953, during her era of residence at the Sandford House, she also divested her interest in all local media holdings just 3 years later…Based on this analysis, the Sandford House does not appear to be historically signiﬁcant under this component of the Historic Criteria.” Correction: This is an implausible statement! There are two important omissions here. First Christina Jacobson was the ﬁfth female to own a radio station in the United States. Secondly, Christina Jacobson was the FIRST female to own a TV station in the United States. Over the 14 year period that she resided in this house, she was proprietor of both. 12) “Original side-gabled roof orientation is also intact.” Correction: The 1907 photograph included in this report clearly shows a hipped roof. 13) “While there is no known formal garden or landscaping plan associated with the property, expansive lawns remain around the residence to the east, west, and south.” Correction: The 1907 photograph included in this report clearly shows two formal hedges running some length down the hill and planted on axis to the entry porch of the house. There remains today formal planting of two Norfolk Island Pines and two Eugenias again planted on axis to the entry porch of the house. 14) “The size of the property itself has also been altered from 15.80 acres to today’s 1.17 acres. The integrity of setting is signiﬁcantly diminished.” Correction: Based on the 1907 photograph included in this report, it is clear that the rear of the Sandford Residence has always been framed by a mature forest of trees. This remains in the form of extensive plantings of mature eucalyptus. Any urbanization that occurred behind this grove of trees did little to diminish the integrity of its setting. 15) “While the building currently features stucco siding, a departure from original wood siding, this alteration may have occurred within the period of signiﬁcance.” Correction: This statement is again pure speculation. The stucco siding could be original to the house. Earthworks later admits the following: “The two rear additions must be removed with the minimum amount of impact to original construction and it is unknown if removal of the ﬁrst addition will reveal a stucco or wood-clad exterior wall.” This proves that Earthworks is clearly guessing that the original siding was wood. 16) “The only change to the house will be the elimination of the twin chimneys at the rear (west) elevation, which are already largely invisible from the street.” Correction: An important omission here is that the existing concrete day-lit basement will also be eliminated and replaced with a slab on-grade foundation. 17) “The Sandford House will be re-roofed with suitable composition shingle material.” Correction: The roof should be restored to its original hip roof conﬁguration. And consistent with Italian Renaissance architecture, the rooﬁng shingles would more suitably be clay rather than composition. 18) “Based on historical research, the Sandford House at 71 Palomar Avenue is signiﬁcant as a good example of the Colonial Revival architectural style and is appropriately listed on the City Master List of Historic Resources.” Correction: Based on this report the Sandford House in its current state is NOT a “good example of the Colonial Revival architectural style”. The house is lacking dormers, shutters, a hip roof and ship-lap siding. However, the Sandford House IS a “good example” of the Italian Renaissance architectural style. 19) “The proposed project appears to be consistent with the City Ordinance relocation criteria, City Guidelines, and the Secretary’s Standards for Rehabilitation.” Correction: According to Applied Earthworks, the proposed project may APPEAR to be consistent with the City Ordinance but it is not. Per the SLO Historic Preservation Ordinance - 14.01.070 “Evaluation Criteria for Historic Resource Listing”, this property will no longer meet eligibility criteria if the property no longer “occupies its original site and the original foundation has been changed.” 20) “Modern replacements for the ﬁrst-ﬂoor solarium windows should minimally consist of window sash that is of the appropriate proportion to ﬁt into the original openings; multi-light versions which replicate the original multi-light windows located throughout other areas of the residence could be employed, however no evidence has been found thus far that documents the original window design for the solarium.” Correction: Besides the solarium windows, there is no mention of all the other windows. Are we to construe that, excepting the solarium, no other windows will be replaced or rehabilitated? Colonial Revival Architecture Evidentiary Errors/Omissions Pertaining to A & T Arborists Tree Survey For the 71 Palomar Avenue Multi-Family Residential Project 1) Tree report: “Tree #2 w/ 36” diameter (NI Pine) located next to the CI palm is very suppressed on one side and has the most significant dieback so it will be removed (condition 3).” Correction: Norfolk Island pines are particularly tolerant of sandy soils and windy conditions. They were an early introduction into California by William Walker in 1859. These two at 71 Palomar are among the largest specimens in San Luis Obispo County having been planted only 25 years after this species was first introduced into California. If branch tips and the main growing tip is yellow instead of dark green then apply a micronutrient solution and water less. If there is branch loss, then water less. According to a web site titled “Monumental Trees” a comparably aged Norfolk Island pine in the garden of Pazo e Lourizán, Spain is considered a “monumental tree”. “The owner of a 100-year-old Norfolk Island Pine at Banora Point, New South Wales, Australia, said he's going to do everything in his power to save the historic tree…” http://www.tweeddailynews.com.au/news/fears-100-year-old-tweed-icon-norfolk-pine-dying/ 3006651/ 2) Tree report: “All the eucalyptus are planned for removal. These trees have all been topped in the last 20 years and have now re-grown suckers that are a significant hazard. Indiscriminate topping is not a proper arboricultural pruning action as the sucker growth is not properly attached to the trunk. Over time, they will split off. All of the eucalyptus trees (mainly the large blue gums) are infested with eucalyptus tortoise beetles (Trachymela sloanei). While these beetles don’t necessarily kill the trees, they eat the leaves making the trees a bit unsightly close up. There is no viable control.” Correction: In temperate Southern Australia eucalyptus live 400-500 years. San Luis Obispo is close to Southern Australia in climate. Eucalypt flowers are mainly pollinated by insects, but birds and small mammals may also act as pollinating agents. http://wiki.bugwood.org/Eucalyptus_globulus#POLLINATION In fact, eucalyptus is particularly valuable as bee pasture, because it blooms year-round. The hollows in older eucalyptus trees also provide homes to animals and birds. Birders have identified over 40 species of birds in Sutro Forest. This is not unique to Sutro Cloud Forest. From a Nature Conservancy assessment: “The wildlife in a Eucalyptus forest varies depending upon the geographic location of the grove. At Jepson Prairie Preserve, CA, Swainson’s hawk and yellow warblers, both of which are “Blue Listed” species of concern, nest in the trees. At Pescadero Creek County Park, south of San Francisco along the coast of California, great blue herons and egrets use the trees to build their rookeries.” Eucalyptus is actually fire-resistant. In fact, it may actually fight fires by acting as a windbreak and blocking flying embers. It will burn in forest fires, but so do all trees. Many people think of the devastating Oakland Hills fires; but a inquiry there noted that trees were not the primary hazard – not even eucalyptus trees. (Click here for a post on that subject.) Grass fires are actually more dangerous (click here for more on the subject). There’s also an excellent post on the Death of a MillionTrees website on the subject. 3) Tree report: Tree #43 w/ 29 inch diameter: “…one stone pine, (severely stressed; condition 2) one Monterey pine along with several ash trees will be removed. None of these trees would qualify as a “specimen tree” so replacement is a viable option.” …” Correction: This (Italian Stone Pine) handsome evergreen is drought-tolerant, rarely bothered by deer and is not highly susceptible to many diseases. Stone pines thrive on the West Coast, especially in California where temperatures do not fluctuate severely. Tolerant of saltwater spray, the pine isn't picky about where it lays down its roots and will grow in acidic and alkaline soils. This tree neither has pitch canker (causing the branch tips to droop) nor does it have root rot (causing the needles to turn yellow, orange or red and drop). http://motherhood.modernmom.com/droopy-italian-stone-pine-plant-care-13251.html Britain’s Kew Gardens has records of one of these Mediterranean beauties that attained an age of 300 years. Contrary to the tree man’s opinion, this tree would qualify as a “specimen tree”. 4) Tree report: “A couple of the olive trees are of decent quality, however, they are all fruit producers. Many HOAs and parks are removing them due to the fruit load. People track the olives onto carpets which caused permanent stains and also people slip and fall on sidewalks from the fruit. Replanting with fruitless varieties is highly recommended.” Correction: “In the case of olives—a tree that can live well over 500 years and still bear fruit —farmers are losing history as well. “Olives have been around since the start of civilization,” DePaoli says. “It literally hurts to pull them out.” Fruit and seed eating birds, including finches, will take the berries off most shrubbery, steal fruit from trees and even olives that aren’t yet ripe. 5) Tree report: “There is one small, multiple trunk coast live oak along the berm. The top has been broken out of this tree by a passing vehicle most likely. This tree will never amount to a quality tree due to the severe damage.” Correction: The acorns (of the Coast Live Oak) feed everything from squirrels and deer to wild turkeys and black bears. More than 500 butterflies and moths are attracted to this host plant. Trees That Form A Part Of The Cultural Landscape Like historic buildings and districts, cultural landscapes reveal aspects of our country's origins and development through their form and features and the ways they were used. Cultural landscapes also reveal much about our evolving relationship with the natural world. For example, the Italian Renaissance garden emerged in the late 15th century at villas in Rome and Florence, inspired by classical ideals of order and beauty, and intended for the pleasure of the view of the garden and the landscape beyond. In the late Renaissance, the gardens became more symmetrical. The symmetrical placement of the two Eugenias and the two Norfolk Pines relative to the entrance of the Sandford Residence should be preserved as they complement the Italian Renaissance revival architecture. Olives are natural choices for Italian-style gardens, or planted in formal lines ﬂanking a driveway or walkway. Similarly, the lone Stone Pine and Frond Palm, which were frequently planted within the context of Italian Renaissance gardens, should also be preserved. Trees That Are Either Endangered Or Historically Important Seven trees on the 71 Palomar property should be preserved both for their historical importance and for their rarity. Of the seven trees, two are Norfolk Island Pine, two Eugenia, one Frond Palm, one Italian Stone Pine and one European Olive. The trees are believed to have been planted by the owner, an orchardist, around 1895 when the historic Sandford residence was built. These trees are large and healthy specimens. They add beauty to the north part of San Luis Obispo and are accessible for viewing and enjoyment by the public. The City Arborist remarked recently “I have admired the trees at 71 Palomar for some time now and appreciate you and your group taking the time and effort to take pictures and ﬁll out part of the Heritage Tree Form. Thank you!…Bob and I feel very strongly about preserving canopy and habitat…”. Nevertheless, these trees are scheduled to be cut down for an apartment complex. Timely action by residents and the CHC/ARC may preserve them. Araucaria hetrophylla or Norfolk Island Pine are naturally long-lived and reach a height of 100’, making our local trees at over 65' very large specimens. In modern home landscapes, where frost-free climates or protected locations allow, Norfolks are known to live 150 years or more (see: The California Polytechnic State University SelecTree. "Araucaria Heterophylla Tree Record," 1995-2015). They are particularly tolerant of sandy soils and windy conditions. These pines are cylindrical at maturity. Due to its size, they are seldom seen in home landscapes and their use is limited to parks and botanical gardens. Norfolk Island Pines make spectacular specimen plants when situated on large expanses of lawn. Norfolk Island Pines are endemic to Norfolk Island located between New Zealand and New Caledonia. They were an early introduction into California by William Walker in 1859. These are the largest specimens in San Luis Obispo County having been planted only 25 years after this species was ﬁrst introduced into California. Eugenia brasiliensis, with common names Brazil Cherry and grumichama, is medium sized tree (maximum 65’ height) endemic to Brazil which bears small fruits that are purple to black in color, and have a sweet cherry-like ﬂavor. Its slow growth and low rate of dispersal make it rare, and it's generally considered an endangered species. Although Phoenix canariensis or Frond Palm grows just six inches a year and requires many years to attain full height. But because the tree grows so slowly, needing decades to reach its full height of 60 feet, very few nurseries even try to grow it. Exceptionally tall specimens can be up to 120 feet. The rare full-grown trees can fetch $20,000. While best in full sun and the usual well-drained loamy soil, P. canariensis can tolerate a wide range of exposures, including deep shade, and a wide range of soil types, including sand and heavy clay. It has a unique ability to tolerate both severe drought and ﬂooding very well, which makes them ideal to plant in housing tracts in which the soil was heavily compacted. Frond Palms dating back to the 1880's are middle aged and some live to be over 400 years old. The pinus pinea or Italian Stone Pine is a coniferous evergreen tree that can exceed 82’ in height, but 40’–65’ is more typical. In youth, it is a bushy globe, in mid-age an umbrella canopy on a thick trunk, and, in maturity, a broad and ﬂat crown over 26’ in width. In Italy, the stone pine has been an aesthetic landscape element since the Italian Renaissance garden period and is frequently planted within the context of Italian Renaissance architecture, such as is the case with the Sandford Residence. Britain’s Kew Gardens has records of one of these Mediterranean beauties that attained an age of 300 years. Olea europaea, commonly called Common Olive, is an evergreen tree that is native to the Mediterranean region. It typically grows at a slow rate to 20’-30’ tall with a rounded crown. Common olive trees are drought tolerant once established. The lifespan of the European Olive tree ranges from 300 years to 600 years. The Italian Stone Pine was frequently planted within the context of Italian Renaissance gardens The Italian Renaissance garden emerged in the late 15th century at villas in Rome and Florence, inspired by classical ideals of order and beauty, and intended for the pleasure of the view of the garden and the landscape beyond. In the late Renaissance, the gardens became more symmetrical. “The upper class, however, wanted European reﬁnement, not rustic gardens. They favored aspects of Italian Renaissance gardens, with axial designs, fountains, and parterres, and the warm climate allowed them to incorporate into this frame a potpourri of exotic ornamental plants that would not grow outdoors in Europe or back east. They enjoyed living and entertaining outdoors here, appreciating the view of well- tended gardens with rose bushes an palm trees…”