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HomeMy WebLinkAbout1-11-2017 PC Correspondence - Item 2 (Cooper)Meeting:PL 1. t, I -- Item: ?i To: City of SLO Planning Commission From: Allan Cooper, San Luis Obispo Re: Review of San Luis Ranch Draft EIR Date: January 10, 2017 RECEIVED CITY OF SAN LUIS OBISPO JAN 1 1 2017 - COMMUNITY DEVELOPMENT I You will be evaluating on January 11, 2017 the adequacy of the San Luis Ranch Development Draft EIR. I concur with the findings in this draft EIR which states that air quality', cultural resources (historic resources and cumulative historic resources), land use/policy consistency (General Plan policy consistency), noise (construction noise), and transportation (existing and near-term intersection operations, existing and near-term lane capacities, existing and near-term segment operations, cumulative intersection operations, cumulative lane capacities, and cumulative segment operations) created by this project will be significant and unavoidable. This project at the time of buildout will also place unavoidable adverse impacts on the City's current sewer, water, school, law enforcement and fire protection capacities. However, the proposed tree replacements, particularly along the riparian corridor, will result in not only significant but unavoidable adverse impacts - not mitigable impacts as the draft EIR states. The mitigations involving replacement in-kind minimum ratios, particularly with regards to the proposed removal of the mature eucalyptus trees, will hardly mitigate the permanent loss of the monarch overwintering grove and active great blue heron nest habitat. Monarchs need tall trees (of at least 60 feet) because they roost in the intermediate level of the canopy where wind protection is greatest. Tall Eucalyptus trees are hugely important as habitat trees as they provide cover and nest sites for Great Blue Herons as well as for Double - Crested Cormorants, hawks and Great Horned Owls. The report notes that 1 Often during the Spring, an area of high pressure will build at the surface over the western United States and produce Santa Lucia (northeasterly) winds, also referred to as "offshore winds" because they flow from the land out to sea especially during the night and morning hours. Severe temperature differences in the vertical plane occur resulting in an inversion. A temperature inversion occurs when a warmer, less dense air mass covers cooler, denser air at the surface. The temperature changes are because of cool moisture -laden northwesterly (onshore) winds from the Pacific Ocean blowing through Los Osos Valley while hot and dry Santa Lucia northeasterly (offshore) winds move from the Santa Lucia Mountains through Avila Valley. one mitigation - creating new offsite nesting habitat for great blue herons - is experimental and that the relocation techniques described in Crouch et al. (2002) were used to relocate black -crowned night heron (Nycticorax nycticorax), not great blue herons. Finally, the California Government Code - Gov Title 7. Planning And Land Use [65000 - 66499.58] ) "...recognizes that premature and unnecessary development of agricultural lands for urban uses continues to have adverse effects on the availability of those lands for food and fiber production and on the economy of the state. Furthermore, it is the policy of the state that development should be guided away from prime agricultural lands..." This project involves conversion of 68 acres of prime soils to urban development. Therefore, your certification of this draft EIR should note that, per the City of San Luis Obispo's Housing Element2, this project is "inconsistent with State Planning Law". Thank you for your time and consideration. 2 City of San Luis Obispo Housing Element 1.30 Consistency with State Planning Law California cities and counties must prepare housing elements as required by State law set forth in Sections 65580 to 65589.8 of the California Government Code. The law mandates that housing elements include "identification and analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives and scheduled programs for the preservation, improvement and development of housing." This Element fulfills that requirement and provides a detailed strategy for implementing the City's housing goals through 2019. State housing goals rely on the effective implementation of housing policies at the local level. To ensure local housing policies are consistent with State law, the State Department of Housing and Community Development (HCD) reviews local housing elements and reports its written findings to the local government. Housing elements must also be consistent with the jurisdiction's other general plan elements and must address several specific requirements regarding the element's scope and content."