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HomeMy WebLinkAbout1-11-2017 PC Correspondence - Item 1 (Lopes)Meeting: I'& I - I I. 14 - Item: I From: James Lopes [ Sent: Monday, January 09, 2017 4:20 PM To: Advisory Bodies <advisorybodies@slocity.org>; E-mail Council Website <ea ma i lco u ncl_@ slocity.o rg> Subject: PC communication on Avila Ranch Draft EIR TO: Planning Commission SUBJECT: Draft EIR for Avila Ranch RECEIVED CITY OF SAN LUIS OBISPO JAN 0 9 2017 COMMUNITY DEVELOPMENT Please read my attached comments on only the Avila Ranch Specific Plan DEIR. City staff have not provided enough time to fit in an adequate review of this and the San Luis Ranch DEIR before your January 11, 2017 hearing. I only have preliminary comments on Avila Ranch, but you will find them interesting as well as related to San Luis Ranch. Thank you in advance for giving me your thoughtful consideration. Sincerely, James Lopes James Lopes 1336 Sweet Bay Lane San Luis Obispo, CA 93401 1336 Sweetbay Lane San Luis Obispo, California 93401 January 8, 2017 Planning Commission City of San Luis Obispo RE: Avila Ranch Specific Plan and Draft EIR; Honorable Chair and Commissioners: Right off I want to mention that progress in planning our community has been derailed by putting forth both the Avila Ranch and San Luis Ranch Draft Environmental Impact Reports in the middle of the holiday season and the start of 2017. Your commission and the public is being railroaded, after the applicants have spent extravagant time going through their preliminary general plan changes and development planning. I encourage you to give these conceptual projects at least a nine-month trajectory from now to earn community approval of their Specific Plan requirements. • The DEIR mistakenly refers to the entitlement as a Development Plan, although the Land Use Element requires a Specific Plan. The topic before you is a mid-level planning document, called a Specific Plan, which is very different than a Development Plan, which the DEIR incorrectly states is the current application. The Specific Plan has to be approved before any subdivision, use permit and architectural reviews can be approved. • The DEIR does not propose mitigation measures or project alternatives which are greater than the immediate scope of the project, although they would provide greater community benefits and lower impacts beyond this scope. It unfairly limits the decision horizon and conversation against the interests of the City of San Luis Obispo. The Specific Plan has an elevated status like a general plan amendment; it is a "legislative" decision; meaning that the planning staff, consultants and you, the decision makers, have wide latitude in determining the most appropriate requirements in response to the potential impacts on the community. Your obligation is negative; not to be arbitrary or capricious in these requirements; and they are positive; to be reasonably related to the scope, timing and extent of the whole project and its impact on the community and its benefits. This setting is Avila Ranch Specific Plan 2 James Lopes Comments broader than if you are reviewing a subdivision map or a project; in those cases, your requirements must be reasonably related to the immediate impacts of the project within and by their type and extent (i.e. the famous Nollan and Dolan Supreme Court decisions). For instance, if the Avila Ranch project will cause unsatisfactory danger and delays on Buckley Road and its intersections, then your commission may impose road improvement requirements that are greater than just the traffic increase impacts of the proposal, in the interests of traffic safety and high-quality community development. Or, if the prime farmland/open space loss on-site is extensive, you may impose a land dedication requirement that is off-site; or one on-site which dictates a reduction in the size of the project and increases its density. I ask that you commission ask the staff and consultants to re -think the scope of their review and analysis, and propose the full extent of mitigation measures which would reasonably protect the interests of the residents and visitors of the community in meeting the General Plan goals and objectives for a high-quality community. • The staff report and the DEIR limit their discussion narrowly to the immediate proposal, rather than give the background of previous proposals, particularly as to why the proposal has expanded exponentially, and its consistency with other plans. 1. It seems that your Commission and the public would benefit from a background report concerning the decision to designate the property for residential use in the Land Use and Circulation Element update, whis was and is inconsistent with the Airport Land Use. 2. A similar report might be made for your and the public's benefit concerning why the applicant revised the first development proposal upward from approximately 250 units to 720. What hearing can be referenced and summarized by staff to understand the motive and implications surrounding such an expansion? What consideration was given to the Airport Land Use Plan, which was already being "over-ridden" in the first proposal? 3. What is the project? The Land Use Element on page 23 includes the Land Use Diagram which designates the property as "SP -4: Avila Ranch." General Plan text requires that a Specific Plan be prepared, but no mention in staff's review is made of the relation of this proposal to a specific plan, which is subject to state law requirements. 4. What general plan requirements apply? A word search for Avila Ranch reveals that on page 82 of the LUCE, text states that the required specific plan will be accompanied with text and map amendments in the LUCE, presumably at the same time. Specific Plan requirements for Avila Ranch state that the maximum number of units is 700, less than the proposed Avila Ranch Specific Plan 3 James Lopes Comments 720, and 50% of the site is to be in open space, which is more than proposed 47.5%. How is this application even accepted for processing? 5. DEIR Figure 1: Land Use Map: What does the dashed line represent? The flight path for the main runway? Where is the flight path for runway B? 6. Growth Inducing Impacts: The project introduces the first major development on the Buckley Road corridor for residential development, which is likely to cause similar planning and investment interest along the corridor; in other words, it will cause a significant growth inducing impact. 7. 4.3: Modifications to the AASP: Is the project consistent with the designation and policies in the Land Use Element? No discussion appears The very design of the specific plan will cause significant internal and, traffic regional commuting traffic, air and climate -change impacts, by placing different uses apart and away from each other and other destinations, and by emphasizing single-family detached housing rather than housing that is affordable for the great majority of commuters. Although the applicants improve on the miserable record of most planners and developers, they are not proposing most units as the greatest needed type of attached, multi-level housing that is necessary for the budgets of most commuters and job holders in San Luis Obispo. The general plan buildout will worsen the current jobs/housing imbalance by almost double, so the project is not designed to significantly reduce the cumulative prospect of a future gridlock on state highways 101 and 227, with that imbalance projected. The disjointed layout of the specific plan places multi -family development at its edges, far enough away from the neighborhood shopping center that bicycling and walking there will be discouraged, in favor of quicker vehicle trips. 1. The design does not address itself adequately to the over-riding, great majority of housing demand by low- and moderate -income employees, who are commuting now to Santa Maria and Orcutt, and to Paso Robles and Shandon. I will have more to convey about this segment in the future; now I can only state that probably over 80 percent of the units should be small-scale, attached and multi-level to sell at affordable prices for these incomes. Somehow the City has mistakenly made it a priority to build housing for "workforce" incomes, which are higher — 120 to 160 percent above the average or median. These incomes comprise probably on 20 to 25 percent of all incomes; they go to the managers and supervisors, the owners and developers; they do not go to most employees. The housing type for these incomes is the single-family detached units which dominate this project. 2. The design will generate unnecessary internal vehicle trips, discourage alternative transportation, and reduce the viability of the commercial Avila Ranch Specific Plan 4 James Lopes Comments center because other shopping areas will be equally or preferably accessible by vehicle in terms of time and convenience. After 30 years of New Urbanism and 20 years of Smart Growth concepts, subdivision planners still produce this type of sprawl, in separated pods, out of sync with pedestrian and bicycle efficiency. 1. The basic objective should be and is to place the commercial area at the core entrance to the project, so that it may serve outside uses which may locate nearby in the future and on a system transit line (along Buckley Road for instance). And, to locate the highest densities within and next to the commercial core and along a main street into the project and to a nearby neighborhood park and school. The Marigold Center and neighboring Islay/French Park neighborhoods were a tentative, under -built step in this direction. 2. Lower densities of triplex, duplex and single family detached densities are graduated away from this corridor. The lowest density should be next to agriculture (due to ag impacts) and impactful, even noxious uses (such as a cement and black manufacturer). The DEIR and staff should definitely engage an independent, new urbanist design firm to generate a very efficient, urban design which improves the chance of meeting or exceeding the City's transportation mode mix, to provide an urban character which improves upon the near -miss at the DeVaul Ranch project at Madonna and Los Osos Valley Roads. • The traffic analysis leaves me asking what the intersection impacts would be at Vachell Lane and South Higuera Street. I think a very detailed explanation of how the project might mitigate impacts near and at this intersection should be diagrammed as well as explained. • 1 also wonder if Buckley Road and an extension of it to South Higuera Street can be developed with only a proportional sharing of costs by this project. Realistically, this is the case where the negative impacts are so great that the developer should pay more than his proportion if he wishes to be able to go ahead with the project. I regret that the timing of your commission's hearing leaves me unprepared to provide other detailed comments. However, it is an informational hearing within the public comment periods. I hope to give more complete comments at the ends of those periods for your commission and staff to review. Sincerely, s/ James Lopes Avila Ranch Specific Plan 5 James Lopes Comments