Loading...
HomeMy WebLinkAbout12-14-2016 PC Correspondence - Item 1 (Los Verdes Parks, Flickinger 2)Meeting: P ( I?- ._1 k-1 . ► U - Item: I From: Sarah Flickinger [ Sent: Wednesday, December 14, 2016 12:54 PM RECEIVED CITY OF SAN LUIS OBISPO DEC 14 2016 COMMUNITY DEVELOPMENT To: Advisory Bodiesadvisorybodes(cc7slocity.org> Subject: Correspondence re: Avila Ranch DEIR for Planning Commission Hearing December 14 Good afternoon, please include the attached second joint correspondence from the Los Verdes Park 1 HOA, Inc. and Los Verdes Park 2 HOA, Inc. in the public hearing and distributed materials for tonight's discussion of the Avila Ranch DEIR. The Los Verdes neighborhoods have so far jointly prepared two written comments with regard to the DEIR for Avila Ranch. A separate comment will be provided at the hearing. This is the second of two that will be sent electronically today. Individual owners may also be contributing comments on this document and are to be handled separately from the HOAs' comments. If you have any questions or if there are any issues with the attachment, please let me know and I will resend. Otherwise a confirmation email acknowledging all is well would be greatly appreciated. Sincerely, Sarah Flickinger on behalf of the Los Verdes Parks 1 & 2 Homeowners' Associations Los Verdes Park 1 Homeowners' Association, Inc. Los Verdes Park 2 Homeowners' Association, Inc. c/o Sarah Flickinger, Los Verdes Park 1 Homeowners' Association, Inc. 92 Los Verdes Drive San Luis Obispo, CA 93401 December 14, 2016 re: Planning Commission Hearing, Avila Ranch DEIR To the City of San Luis Obispo Planning Commissioners: This correspondence is made as a joint statement of the two Homeowners' Associations for the two Los Verdes Park developments located on either side of Los Osos Valley Road within the southern limits of the City of San Luis Obispo. Contrary to statements in the DEIR, our neighborhoods are planned urban developments (PUDs)—not unlike the proposed Avila Ranch Development—of single family homes on individual lots, with several commonly held parcels for communal facilities. Our homes are neither condominiums nor townhomes as characterized in the DEIR. Between the two existing residential neighborhoods, we represent more than 175 individual parcels as well as the common interest parcels, and are in direct proximity of the impacts of this development. Neither board has yet adopted a formal endorsement of the Avila Ranch project, though that is our goal. We recognize the additional residential needs outlined in the LUCE and General Plan updates as vital to the long-term sustainability of our community and its shift toward a multimodal future. Our primary concerns are real and immediate impacts to the safety, health and quality of life of our residents, whose homes became a part of this City as early as 1974. CECIA requires that impacts to existing neighborhoods affected by projects be addressed in the DEIR and EIR documents, which our neighborhoods feel has not been done adequately in this current iteration. The DEIR should include more specific analysis of impacts to ours and additional neighborhoods in the vicinity, followed by a new release of the DEIR through the CECIA clearinghouse for additional public comment on these new analyses. The following are specific concerns formally adopted by both HOA boards, with suggestions for amenable mitigations. We have been and continue to be willing to work directly with the developer and the City to work through our issues with the DEIR prior to a subsequent release of the document in an effort to avoid undue delays for the developer. 1). First and foremost, the proposed mitigation measure of a second lane on Los Osos Valley Road was the subject a settlement agreement between the two HOAs, the City of San Luis Obispo and CALTRANS, when it was proposed as part of the LOUR Interchange Project. Its impacts compromised noise levels, air quality and safety of residential living spaces and safety of vehicle, pedestrian and bicycle travel into, out of and in the vicinity of our neighborhoods beyond acceptable levels. It also caused degradation of access for public safety vehicles and put children loading and unloading at school bus stops at the intersection of Los Verdes Drive and Los Osos Valley Road at risk. The settlement was reached in good faith by all parties, and any proposed changes to the agreed upon striping and road alignments requires specific notification prior to consideration (including scoping and DEIR release) under the terms of the settlement agreement. This mitigation measure should be removed from proposal in the DEIR as its inclusion without prior notice violates the terms of the settlement agreement and therefore cannot be legally imposed. As two turn lanes from either NB or SB S. Higuera Street would be infeasible without changes to the striping on LOVR, those mitigation measures must also be removed from proposal in the DEIR. Furthermore, none of these proposed mitigation measures were discussed in the LUCE, making them incompatible with the City's General Plan. A suitable LUCE-evaluated alternative mitigation measure for this area must be considered in lieu. 2). As removal or further reduction of the medians between the Los Verdes parks on LOVR would be necessary in any restriping to multiple lanes on westbound LOVR, it is again infeasible under the terms of the settlement agreement, as it is expressly addressed therein. Any mitigation requiring adjustment to the medians other than their extension should be excluded from consideration as part of this project. 3). The intersection of Los Verdes Drive at Los Osos Valley Road is not evaluated nor discussed in the DEIR. While the document does include impacts at the intersection of LOVR and S. Higuera and the segment of LOVR from the intersection at S. Higuera to 450' past the intersection of Los Verdes Drive, it never specifically addresses or evaluates impacts to the intersection at LOVR and Los Verdes Drive, which serves as the sole vehicular and bicycle entrance and exit points to our residential neighborhoods. There are two school bus stops serving several additional neighborhoods in the greater area at this intersection, which also go unaddressed in the DEIR. This is also the single access point for public safety vehicles traveling to homes within the neighborhoods. That this intersection and impacts to access and public services caused by the addition of project traffic are not discussed at all in this document makes it insufficient as those impacts are real and immediate as early as Phase 1. The addition of project traffic, both near and long term is significant and will have impacts to the safety of Los Verdes Park residents at the intersection of Los Verdes Drive and Los Osos Valley Road for both vehicular and bicycle travel. The impacts further compromise the already failing LOS at the unmentioned and unmitigated intersection and the direct and indirect safety and wellbeing of residents, public servants, service providers (mail, utilities, contractors) and others who travel through this intersection. The addition of project traffic should warrant signalization at Los Verdes Drive prior to completion of Phase 1 to ensure the continued safety of Los Verdes residents and others who travel in and around our neighborhoods. 4. It appears that the traffic study and findings on several mitigation measures and their benefits may be inherently flawed. Referencing again the aforementioned settlement agreement, many of the yet uncompleted mitigation measures from the Los Osos Valley Road Interchange Project that were taken into account in that project's environmental documents and the subsequent settlement are being proposed as separate mitigations within the Avila Ranch project's DEIR. As the traffic study is based on the assumed outcomes of a completed LOVR Interchange Project—including said mitigation measures— to show them as having a new additional benefit on the additional traffic generated by the Avila Ranch project as Avila Ranch mitigation measures would effectively attribute their benefits at twice the level they will actually achieve. These include, but are not limited to, retiming at the signal of LOVR and S. Higuera, adjustments to US 101 signage, etc. The City is required to provide these mitigation measures as part of the LOVR Interchange Project, and should have done so according to the schedule outlined in the settlement agreement. Their benefits should not be leveraged as mitigation measures in the Avila Ranch Project as their completion are already part of the existing condition. The LOVR Interchange Project was completed November 2015, and the traffic study in the Avila Ranch DEIR appendix is annotated as February 2016. 5. The environmental impacts to our neighborhoods of additional project traffic on Los Osos Valley Road with regard to noise, light pollution and air quality are not adequately addressed nor mitigated in the DEIR document. The proposed additional project traffic between our neighborhoods is significant, as are the impacts to residents living in close proximity to it, and it should be quantified and mitigated in the DEIR. We would propose a mitigation of acoustic and light -blocking (read: solid, noise- absorbing, deflecting and/or dampening materials) sound wall along both Los Verdes parks' frontages facing LOVR prior to completion of Phase 1. Landscape features may be used in addition to the sound walls to further mitigate air quality, noise and light impacts as warranted by future phases. Future monitoring of sound and air quality in the existing neighborhoods should be incorporated in future EIR documents. 6. The added traffic, including construction traffic during the early phases of grading and construction, from the project onto Suburban Road is significant in nature and its impacts to adjacent residents should be evaluated and included in the DEIR. Suburban Road tees into the side of Los Verdes Park 1, with several residences with bedrooms and living spaces in close proximity to the intersection. Impacts to these residences should be quantified and mitigated in the DEIR. The existing wrought iron fencing and aging hedge at this location are likely insufficient in addressing the additional noise, light and air quality impacts from the addition of Avila Ranch project traffic, including during the construction phase. These impacts should be mitigated with acoustic and light -blocking sound walls and landscape features along the Los Verdes Park 1 frontage in direct and near proximity to the Suburban Road and S. Higuera intersection prior to the beginning of Phase 1. This would effectively include from the beginning of the Los Verdes Park 1 property north of the intersection to some point past the intersection to the south along S. Higuera. As there are noise, air quality and light pollution impacts on residences facing S. Higuera from the addition of project traffic throughout the S. Higuera corridor in growing significance as phases progress, this mitigation should likely be extended to include the entirety of the Los Verdes Park 1 frontage facing S. Higuera from the northern corner of the property up to and around the corner of the property at the intersection of LOVR and S. Higuera. Additional study on these impacts should be included in the DEIR. 7. We understand that exclusion of proposed infeasible mitigation measures within the DEIR will leave significant traffic impacts at the intersection of LOVR and S. Higuera in need of mitigation for the project to proceed. As discussed in the DEIR neither those measures nor the proposed extension of Buckley beyond S. Higuera to connect to LOVR, known in the LUCE and DEIR as the LOVR Bypass, are currently programmed for TIF, and either would require advancement under updates related to development to proceed. It is also unclear in the DEIR whether or not the cumulative assessments assume the LOVR Bypass as complete as part of the full buildout of the General Plan scenario, so the findings derived from the project's impacts with and without the LOVR Bypass and related mitigations may be inherently flawed as currently evaluated. As other mitigation measures for this intersection may be flawed and are infeasible under the terms of the settlement agreement, the alternative mitigation of the LOVR Bypass should be advanced as part of the mitigations for Avila Ranch traffic impacts, with a TIF program established for fair share contribution by the developer. The LUCE specifically allows the Bypass to be advanced to determine final feasibility with or without development of the parcels it crosses. Our neighborhoods remain open and available to support the City and developers in achieving the goals of the General Plan through collaborative efforts that serve existing and contemplated developments, as well as the greater communities of the City and County of San Luis Obispo. We regret that we were not able to review the DEIR in its entirety prior to release through the CEQA Clearinghouse or we would have provided this feedback and worked with the developer and City to address concerns in advance of publication in an effort to avoid substantive changes that necessitate a new release of the DEIR. Sincerely, Los Verdes Park 1 Homeowners' Association, Inc. Special Board Member Sarah Flickinger Los Verdes Park 1 Homeowners' Association, Inc President, Board of Directors Los Verdes Park 2 Homeowners' Association, Inc. Special Board Member Darrell Goo Los Verdes Park 2 Homeowners' Association, Inc. President, Board of Directors Bob Barker Cameron Boyne