HomeMy WebLinkAboutAvila Ranch DEIR Public Comment received 1-18-17 (Bike SLO County)From: Lea Brooks [
Sent: Wednesday, January 18, 2017 4:08 PM
To: Corey, Tyler <tcorey@slocity.ora>
Subject: Bike SLID County Avila Ranch DEIR Comments
Mr. Corey:
RECEIVED
CITY OF SAN LUIS OBISPO
JAN 18 2017
COMMUNITY DEVELOPMENT
Attached are Bike SLID County's comments on the Avila Ranch Draft Environmental Impact Report. Thank
you.
Lea
Lea Brooks, Advocate
Bike SLO County
City of San Luis Obispo
Community Development Department
Attn: Tyler Corey, Principal Planner
919 Palm Street
San Luis Obispo CA 93401-3218
tcoreyCa7slocity. arg
Dear Mr. Corey:
Re: Avila Ranch Draft Environmental Impact Report
Jan. 18, 2017
Bike SLO County appreciates the opportunity to comment on the Avila Ranch Draft
Environmental Impact Report (DEIR). We are supported by more than 4,800 individuals
throughout the region who believe safer complete roads for biking, walking and driving
are essential to communitywide well-being.
Our comments focus on the Mitigated Project Alternative because City staff announced
at the Jan. 11, 2017, San Luis Obispo City Planning Commission meeting that the
applicant is proposing this option.
Bike SLO County supports more and denser housing for people who want to live closer
to their jobs in the City so they don't have to commute. However, the significant and
unavoidable environmental impacts identified in the DEIR, including long-term impacts
to air quality and long-term transportation and traffic impacts, are not acceptable. We
are also concerned with the DEIR's finding that "the Mitigated Project Alternative would
increase demand for bicycle facilities in an underserved area and potentially conflict
with the City's Bicycle Transportation Plan regulations and General Plan thresholds."
Again, not acceptable.
A major shift in emphasis from motor -vehicle dependency to multi -modal choice is
required to reduce the environmental impacts to below a level of significance. Additional
mitigations to reduce vehicle trips are needed to achieve the 20 percent trips -by -bike
goals in the Land Use and Circulation Elements (LUCE) and Climate Action Plan and
the 20 percent mode share objective in the Bicycle Transportation Plan to preserve our
health and high quality of life. According to HEAL SLO, San Luis Obispo County's
obesity prevention coalition, Avila Ranch is projected to produce one-third more driving
miles per household (72 per day) than the City average (54), especially drive -alone
automobile traffic, because it is at the edge of City limits and far from most services and
all schools.
Although there are excellent bicycle facilities proposed onsite and crucial connections
proposed to the bicycle transportation network, there are no guarantees that the
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org
connections the applicant isn't funding fully or in part as mitigations will be constructed
in the near future, especially in the unincorporated area. Unless these connections are
made at the same time the project is occupied, we are concerned that trips by bike will
be largely limited to the project site and immediate adjacent destinations.
The significant increase in project -generated vehicle traffic on South Higuera Street, Los
Osos Valley Road, Tank Farm Road, Buckley Road, Broad Street and other roadways
without adding buffers and other safety enhancements, and the DEIR's proposed
mitigations to address traffic congestion by adding multiple turn lanes in intersections to
increase capacity for motor vehicles will likely reduce the number of people currently
riding bicycles and prevent others from trying out of fear of being hit by motorists.
The City Bicycle Transportation Plan notes that "intersections can be significant barriers
for bicyclists, depending on the bicyclist skill level and the complexity and volume of the
intersection traffic."
A San Luis Obispo Council of Governments' (SLOCOG) 2013 bicycle use survey found
that the majority of County bicycle riders fall into three major categories:
-Strong and Fearless (14.6%): Defined as someone comfortable riding on almost any
road or intersection in the county regardless of road conditions, traffic speed and
volume.
-Enthused and Confident (31.3%): Defined as someone comfortable riding on certain
roads with wide shoulders, bicycle lanes and easy -to -navigate intersections.
-Interested but Concerned (27.9%): Defined as someone only comfortable riding away
from motor vehicles or on roads with bicycle lanes, neighborhood streets with low traffic
speed and volume, and on bicycle paths.
-The fourth group, No Way No How, was comprised of respondents who had no
interest in cycling. It was notable that the share of this type of respondent increased with
age.
It's doubtful that the "Interested but Concerned" category of riders will bicycle on roads
with significant increases in traffic generated by the project and intersections with
multiple turn lanes. Facilities on and off the project site must be designed and built to
accommodate this category to achieve the City's 20 percent trips -by -bike goal. The full
survey is posted at: http:l/slocog.org/sitesfdefault/files/SLOCOG-Bike-Barriers-Survey-
Analysis- Report.pdf
Additional comments:
-The most glaring gap in the bicycle transportation network that will be exacerbated by
Avila Ranch is Buckley Road. While Avila Ranch proposes Class II bike lanes along its
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org
frontage, the abrupt end of the bikes lanes in the unincorporated area leaves an
approximate one -mile gap to the airport and growing number of job sites at the east end
of Orcutt Road. Increases in motor vehicle traffic when Buckley Road is extended to
Higuera Street, combined with project -generated vehicle traffic, will make riding a
bicycle on Buckley Road without continuous Class II bike lanes perilous. The DEIR
acknowledges the traffic impact on Buckley Road with its conclusion that "project -
generated traffic would cause exceedance of intersection capacities at the Buckley
Road/State Route 227 intersection in both the AM and PM peak hours, resulting in
significant and unavoidable impacts. The applicant would pay a fair share fee to offset
project contributions to this impact."
Unfortunately, the County has no provision for collecting fees from Avila Ranch toward
road improvements such as Class II bike lanes in the unincorporated area to complete
the Buckley Road gap. And the City and County have no agreement to complete such
gaps. Bike SLO County finds leaving a gap in the Class II bike lanes on Buckley Road
unacceptable because it would effectively block people from riding bikes out of fear for
their safety, including the "Strong and Fearless" category in the SLOCOG survey. The
City, County, SLOCOG and applicant must agree on a solution that results in
construction of consistent Class II bike lanes the full length of Buckley Road at the same
time. There must be no gap.
-The DEIR states that "construction of Class I and II bicycle networks would be a multi -
agency effort between the City, County and applicant. The applicant would develop all
segments within the project site. Depending on the jurisdiction of the proposed bicycle
lane segment, the City and/or County would develop Class I and II bicycle lanes along
the Buckley Road Extension, as well as future offsite connections along Santa Fe Road
and East Branch of San Luis Obispo Creek as part of capital improvements.
Implementation of these future offsite segments is also dependent upon right-of-way
acquisitions." Comment: If capital improvements do not occur and/or the acquisitions
don't happen and these bikeways are never built, what is the impact on the bicycle
transportation network?
- Regarding the proposed mitigation to add left turn lanes to the intersection of South
Higuera Street and Tank Farm Road: "Project development of Class I bike paths
through the project site and connections to the Bicycle Transportation Plan's regional
network would improve conditions to an acceptable level. This new bike path would
connect to a planned Class I path parallel to Tank Farm Road that would provide
cyclists with an alternative route that would allow them to bypass the South Higuera
Street/Tank Farm road intersection, reducing the usage of this intersection and
improving conditions to acceptable levels." Comment: There is no guarantee that this
Class I path will be built in the near future. And, people on bikes have the same
destinations as motorists. The Class I bike path may not go where all people on bikes
want to travel. Hoping people on bikes will avoid intersections to improve conditions to
an acceptable level is not an acceptable mitigation.
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org
-In response to the degradation of the City's bicycle level -of -service to the intersection
of Los Osos Valley Road and South Higuera Street due to project -generated vehicle
traffic, the proposed mitigation is to install a Class I bike path from South Higuera Street
and Buckley Road to Los Osos Valley Road. The applicant would pay a fair share fee
toward this bike path, but the DEIR identifies no time line or responsible party for
building it. Residents of the Los Verdes neighborhoods on Los Osos Valley Road
apparently would be expected to bike a circuitous route to the Trader Joe's shopping
center which is across the road by motor vehicle. Again, hoping people on bikes will
take Class I bike paths to avoid intersections is not an acceptable mitigation because
the bike path may not go where individuals want to go. Through bike commuters and
more serious recreational bicyclists on Higuera Street are another example. It's doubtful
they would divert to Class I bike paths because it would take them out of their way.
-The DEIR does not address school access. How will students ride a bike to Los
Ranchos Elementary, Laguna Middle and San Luis High schools? The ability of children
to safely ride a bicycle or walk to school should be a top priority.
- Avila Ranch, with its significant increase in vehicle traffic and air pollution, does not
meet the goals of the Climate Action Plan, which says: "Vehicle miles traveled (VMT) is
the main indicator used to track greenhouse gas emissions produced from vehicle
combustion of fossil fuels ... With a land area of just over 10 square miles, many trips
within San Luis Obispo are short and may not require an automobile ... Replacing
vehicle trips with alternative modes of transportation, including bicycling and walking,
reduces VMT and related greenhouse gas emissions. Expanding the existing network of
bicycle and pedestrian routes, increasing the safety of alternative modes of travel and
conducting additional education and outreach efforts facilitate and promote car -free
alternatives."
-What is the impact on the bicycle transportation network, including connections to Avila
Ranch, of Chevron's decision not to move forward with its Tank Farm property project,
including the Class I bike path connection with the Avila Ranch Class I bike path?
-What is the impact on the bicycle transportation network of Chevron's decision not to
move forward with its Tank Farm property project on the Tank Farm Road shoulder
used by people who ride bikes?
-Because Suburban Road is not designated for Class II bicycle lanes in the Bicycle
Transportation Plan, there is no requirement that the applicant add Class II bike lanes
as mitigation. Suburban Road is an integral part of the Avila Ranch circulation system,
and the lack of Class II bicycle lanes will discourage people from riding bikes.
-The proposal to install signage at the South Higuera Street/Buckley Road intersection
to inform drivers of additional access to Highway 101 at Ontario Road to keep them
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org
from clogging the LOVR/Highway 101 on- and off -ramps is unacceptable without further
mitigations. The bridge on South Higuera just north of the northbound highway onramp
is substandard and needs to be brought up to current standards. Of special concern is
southbound motorists turning north on the substandard freeway on-ramp and cutting off
southbound bicyclists. In addition, the shoulders on Higuera Street from Ontario Road to
the northbound freeway onramp are substandard and must be upgraded to Class II bike
lanes, preferably buffered because of the additional traffic. Because this segment of
South Higuera Street is in the unincorporated area, the City has no leverage to require
these improvements without an agreement with the County.
The following are suggested mitigations to reduce motor vehicle trips and encourage
Avila Ranch residents to ride bikes, take transit and car share:
-Require participation in SLOCOG's Rideshare programs, including the new Residential
Transportation Demand Program.
-Free bikes or a -bikes for new residents (voucher to local store or certain bikes).
-Car sharing and a -bike share program on site. Initial free membership to encourage
these option.
-Bike hooks, racks, bike garages for safe, easy storage and quick grab use at all
housing unit entries.
-Reduce unit -specific and on -street parking.
-Include a number of no-car/no parking/no garage units for people without cars.
-First year free bus passes for residents.
-On-site bicycle maintenance kiosks at high-density unit complexes and neighborhood
parks.
-Bike/pedestrian connections in all cul-de-sacs.
In summary, the DEIR seems to assume City goals, such as multi -modal connectivity,
transit, active transportation and Safe Routes to School will magically happen after
construction of this project. In fact, virtually all required offsite transportation mitigations
will make it more challenging to meet these goals. Either more Class I conflicts need to
be called out or meaningful analysis must be done on options to avoid such impacts.
Bike SLO County recommends that a new green project alternative be analyzed that
employs recommended approaches, incentivizing switches to healthy transportation
habits, adds diversity to housing stock and helps San Luis Obispo live up to its Climate
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org
Action, LUCE, Bicycle Transportation and other community plans.
Sincerely,
Lea
Lea Brooks, Advocate
Bike SLO County
860 Pacific St, Suite 105, San Luis Obispo, CA 93401 1 bikeslocounty.org