HomeMy WebLinkAboutAvila Ranch DEIR Public Comment received 1-18-17 (San Luis Obispo Council of Governments)
January 18, 2017
City of San Luis Obispo
Community Development Department
Attn: Tyler Corey, Principal Planner
919 Palm Street
San Luis Obispo, CA 93401-3218
Subject: Avila Ranch Development Project – Draft Environmental Impact Report (DEIR)
Project # SPEC/ER 1318-2015
State Clearinghouse #2015081034
Dear Mr. Corey:
The San Luis Obispo Council of Governments (SLOCOG) submits the following comments on the
Draft Environmental Impact Report (DEIR) of the Avila Ranch Development Project (hereby
referenced as “Project”).
Air Quality and Greenhouse Gas Emissions
Consistency with Sustainable Communities Strategy (SCS)
As the Metropolitan Planning Organization (MPO) for the San Luis Obispo region, SLOCOG is
required to prepare a Regional Transportation Plan (RTP), which is updated every four years,
and includes a Sustainable Communities Strategy (SCS). The SCS (pursuant to SB 375, 2008)
must identify a forecasted development pattern and transportation network that will meet
greenhouse gas emission reduction targets specified by the California Air Resources Board [ARB]
through their RTP planning process (2010 RTP Guidelines, California Transportation
Commission).
As such, several policies of SLOCOG’s 2014 RTP/SCS reference coordination in land use and
transportation planning in the region, and reducing greenhouse gas (GHG) emissions from
passenger vehicle travel in order to meet regional GHG targets specified by ARB.
Policy OTS 8 (Land Use and Transportation Coordination) states “Facilitate the development
and economic vitality of communities in ways that reduce trips and travel distances. Maintain
and improve the regional transportation system in a manner which assists development and
implementation of local jurisdictions’ general plans that support livable community concepts
and efforts.”
Policy OTS 13 (Climate Change) states “Develop and implement programs and advocate land
uses that will reduce overall vehicle miles traveled, delay, and support alternative vehicle and
other programs to attain state-designated greenhouse gas reduction targets for the region.”
Policy SCS 4 states “Reduce vehicle miles of travel related emissions by encouraging the use of
public transit and other alternative forms of transportation and by supporting and encouraging
the adoption of general plans and zoning that promote more compact communities.”
In order to implement SB 375, SLOCOG – like other MPOs in California – use scenario planning
tools to test policy options for different development patterns to determine which future land
use scenarios will allow the region to meet the regional GHG reduction targets set by ARB.
SLOCOG developed four future year scenarios (one for future year 2020 and three for future
year 2035, with a focus on two variables: (a) share of new housing that is multi-family, and (b)
share of new employment located in urbanized areas. Table 1 shows how the four future year
scenarios varied.
Table 1. Policy differences of 2020 scenario and three 2035 scenarios in 2014 RTP/SCS
Scenario Scenario Name
Share of new
housing that is
multi-family (MF)
Share of new
employment located
in urbanized areas
Projected GHG
emissions per capita
2020 Scenario 1 Near Future
Scenario 22% 82% -8.40%
2035 Scenario 1 Business As Usual
Scenario 25% 85% -7.90%
2035 Scenario 2 Preferred Growth
Scenario 35% 90% -9.43%
2035 Scenario 3 Aggressive
Scenario 45% 95% -10.91%
In order to develop future year land use scenarios, proposed land use projects with pending
entitlements were considered. At the time, the City of San Luis Obispo’s Land Use and
Circulation Element (LUCE) considered Special Focus Area 4, with a range of 500 to 700 new
housing units. SLOCOG’s 2035 Preferred Growth Scenario assumes 450 housing units (at Avila
Ranch); this can be interpreted as an assumption that 450 units (of the total units proposed) are
built, acknowledging a potentially slower pace of development, and hence may not represent
build-out of the project. Table 2 shows how the three scenarios varied in the level of new
growth assigned to Avila Ranch area.
Table 2. New Housing Allocated to Avila Ranch (Special Focus Area 4)
Scenario Scenario Name New housing units New jobs
2035 Scenario 1 Business As Usual Scenario 210 du 0 jobs
2035 Scenario 2 Preferred Growth Scenario 450 du 30 jobs
2035 Scenario 3 Aggressive Scenario 410 du 27 jobs
Housing mix
The Project provides a mix of housing product with a residential density range of 6.0 units per
acre to 26.5 units per acre, representing small- and medium-lot single-family detached housing,
single-family attached/condo housing, and multi-family housing. This represents a range of
housing proposed for this project, and is consistent with SLOCOG’s policy language regarding
mix of housing.
Policy SCS 7 of the SLOCOG 2014 RTP/SCS states “Support equitable, affordable housing.
Expand location- and energy-efficient housing choices for people of all ages, incomes, races and
ethnicities to increase mobility and lower the combined cost of housing and transportation.”
Over the past nine years, SLOCOG staff has collected building permit data from the eight local
jurisdictions in the region, for the time period of 2000 to 2014. The three building permit
surveys were conducted in 2007, then in 2011, and most recently in 2015. A key finding was
that during the time period, San Luis Obispo has permitted a greater mix of housing other
communities and the region as a whole.
Figure 1 shows the share of new housing units permitted by type of unit from 2000 to 2014,
including single-family detached (small-, medium-, and large-lot), single-family attached/condo,
and multi-family (duplex and apartment units), among other housing units. San Luis Obispo
permitted a greater share of MF Apartment units, SF Attached/Condo, and 2nd Units than the
region as a whole, and a similar share of SF Detached (Small-Lot) units as the region.
The Project proposes a strong mix of housing product, when compared to what has been
permitted from 2000 to 2014, as well as compared to the region as a whole. Table 3 shows the
distribution of housing types across the four proposed residential land uses (R-1, R-2, R-3, and
R-4), and how that compares to housing product types as considered in the San Luis Obispo
Regional Building Permit Survey Data Summary Report (2000-2014) (SLOCOG [2016], currently
unpublished).
Figure 1. Share of New Housing Units by Type, Incorporated Cities (2000 to 2014)
Table 3. Distribution of Proposed Housing Types compared to SLOCOG Building Permit Survey
*Note: MF Apartment housing product proposed for development in R-4 is represented as unit size rather than lot size.
As shown in Table 3, the project will provide a greater share of SF Detached (Small-Lot) than
what was permitted between 2000 and 2014 (42.4% versus 12%). The project also proposes a
greater share of SF Attached/Condo than what was permitted between 2000 and 2014 (25.7%
versus 20%).
Proposed
Residential
Land Uses
Number of
units
Share of
units Range of lot sizes*
Housing Product Type
(as compared to SLOCOG
Building Permit Survey)
R-1 105 14.6%4,000 to 8,000 sq. ft.SF Detached (Medium-Lot)
R-2 305 42.4%1,350 to 2,000 sq. ft.SF Detached (Small-Lot)
R-3 185 25.7%1,100 to 1,700 sq. ft.SF Attached/Condo
R-4 125 17.4%650 to 1,150 sq. ft.MF Apartment
720 100.0%
Location of town center
In a review of the Land Use Plan (Figure 2-2 in the Project Description), the proposed town
center is not located in the center of the development. Although the neighborhood commercial
center may provide some basic goods and services to residents in the project area, its current
location in the eastern portion of the project may lead to longer travel distances for a majority
of the new residents.
Policy SCS 2 of the SLOCOG 2014 RTP/SCS states “Facilitate the development and economic
viability of communities in ways that reduce trips and travel distances.”
SLOCOG suggests a modification to the land use plan that would result in locating the town
center at the intersection of Venture Drive and Earthwood Lane, as well as moving the
development of the town center to an earlier phase of the development. This intersection
represents a more centralized location within the development, and could facilitate reduced
travel distances and more walking and biking trips to this location.
SLOCOG recognizes that the suggested location spans three phases (1, 2, and 3), so if the town
center were relocated to the Venture Drive/Earthwood Lane intersection, it would require an
adjustment to the development phasing.
Connections to existing adjacent uses
In a review of the Land Use Plan (Figure 2-2 in the Project Description), SLOCOG suggests that a
bike and pedestrian connection be considered at the northern edge of the development to
connect to the Sports Warehouse existing employment center.
Policy SCS 1 of the SLOCOG 2014 RTP/SCS states “Improve mobility through a combination of
strategies and investments to accommodate anticipated growth in transportation demand and
reduce current and projected levels of congestion.”
An existing example of this type of connection can be found between the Marigold Center
development and the residential development immediately east of Marigold Center. This type
of connection shortens travel distances to adjacent and existing destinations and would provide
a bike and pedestrian connection to a warehouse facility with many employees and four
existing retail storefronts.
Effect of school trips
Section 3.11.1.3 lists the closest schools to the development. Table 3.11-2 lists the San Luis
Coastal Unified School District’s (SLCUSD) capacity, enrollment, and % utilization. P. 3.11-7
states: “SLCUSD currently provides intra-district open enrollment, which allows parents a
request to enroll their children at any district school; the district approves requests on a space-
available basis. Pp. 3.11-19 and -20 evaluate the impact on public school enrollment, present
student generation projections, and discuss impact fees.
Although DEIR Appendix P includes trip generation, distribution, and assignment, which should
reflect home-based school trips, the DEIR should at least include a qualitative discussion of the
influence of the distance of the closest schools on mode choice and traffic. This discussion
should reflect input from the school district and other applicable stakeholders.
SLOCOG acknowledges that it is difficult to know the precise influence in the absence of
knowing where students living at Avila Ranch would attend elementary school. (In the case of
middle and high school, the estimated number of students – 36 and 69, respectively – would
have more of a known impact, with Laguna Middle School and San Luis High School being the
closest at those respective levels.) However, SLOCOG seeks to promote mode options for
school trips, as described in the following RTP/SCS goal.
Ch. 6, Goal #3 of the SLOCOG 2014 RTP/SCS states: “Provide safe and efficient connections for
biking and walking between transportation modes such as Park & Ride lots, transit facilities, and
other destinations for vehicles (shopping, schools, employment); as well as providing
recreational activities such as walking and biking.”
Transportation/Traffic
SR 227 Operations Study: background
Policy HSR 11 of the SLOCOG 2014 RTP/SCS states: “Work with Caltrans and other
transportation partners to develop corridor management concepts that integrate context
sensitive solutions that reflect community values in the planning and construction of projects.”
In December 2016, the SLOCOG Board approved the State Route 227 Operations Study (“227
Study”), which recommends operational improvements to address congestion, side street
access, multimodal level of service, and safety along SR 227 between the San Luis Obispo city
limits and Price Canyon Rd. The study used Caltrans’ Smart Mobility Framework and benefit-
cost analysis to estimate the most cost-effective set of improvements among two alternatives:
a widening-plus-signalization corridor and a roundabout corridor concept.
The roundabout corridor was found to be the most cost-effective. Specifically, the study states:
Based on the technical analyses performed as part of this study, the effectiveness of the
corridor to accommodate existing and future vehicular demand was determined to be
currently constrained by the inefficiency of the existing intersection control types. Per
the Smart Mobility Framework process, a detailed Benefit-Cost (B/C) analysis of the
operational, safety, emissions, and costing characteristics at each study intersections
indicate that the Roundabout Corridor Concept yields the greatest estimated return on
investment (highest B/C). Based on the B/C results, roundabouts will provide the most
efficient intersection control through the corridor that best balances operations and
capacity in concert with resource preservation, safety, emissions, maintenance, and
overall cost.
The 227 Study makes several phased recommendations, which are presented in the appendix of
this letter.
SR 227/Buckley Rd. intersection
P. 3.12-53 summarizes SLOCOG’s 2014 RTP-SCS and the 227 Study.
Note that the 2014 RTP/SCS includes the widening of SR 227 from two to four through lanes
(with left turn channelization) from Aero Drive to Los Ranchos Road in its financially-
constrained Tier I list of capital improvements. This project recommendation was considered in
the 227 Study, which ultimately found that improved intersection operations through
roundabout control would be more cost-effective, as discussed above.
The following revisions are suggested to the language on the SR 227 Operations Study:
“Additionally, the SR 227 Operations al Analysis Study currently under way is being, led
by SLOCOG in coordination with the County, City, and Caltrans, was approved by the
SLOCOG Board in December 2016. The study is focuses d on analyzing short-, medium-,
and long-term improvements along SR 227 to improve traffic congestion, side street
access, multimodal conditions, and safety, including improvements to this [Buckley/SR
227] intersection. The study recommends the conversion of the intersection from a
signalized intersection to a multi-lane roundabout (widening at 200 feet plus taper from
up/down stream of intersection, including signage, illumination, and striping for
pedestrian/bike crossings). This roundabout would include City of San Luis Obispo
Gateway signage and treatments…”
While a preferred alternative for the intersection has not yet been identified by an
environmental document, the recommendation of a multi-lane roundabout, associated
features, and the Edna-Price Canyon Trail at this intersection suggests that MM-TRANS-5 should
be revised as follows:
“The AASP shall be amended to include a fee program for improvements to the Buckley
Road/SR 227 intersection. Upon establishment of a fee program for improvements to
this intersection within the AASP, the Applicant shall pay a pro-rata fair share fee to
fund the installation of additional northbound and southbound lanes conversion to a
multi-lane roundabout, with accommodations for the Edna-Price Canyon Trail, at the
Buckley Road/SR 227 intersection. The City shall collect the fair share fee and coordinate
payment of Project fair share fees to help fund improvements with the County and/ or
Caltrans.”
Turning movement counts and cumulative plus project volumes
In reviewing projected turning movement counts at the SR 227/Buckley intersection, SLOCOG
wishes to point out a substantial amount of traffic growth shown under the Cumulative Plus
Project Conditions for some turning movements, compared to the SR 227 Study.
Table 4. Comparison of selected turning movement counts at SR 227 and Buckley Rd., Avila
Ranch DEIR, Appendix P (Transportation Impact Study), and SR 227 Operations Study
Leg West North South
Study Year / peak hour EBR EBL SBR SBT NBL NBT
Avila Ranch DEIR - TIS Existing AM 113 35 59 426 198 1077
Avila Ranch DEIR - TIS Existing PM 282 50 26 1047 76 468
Avila Ranch DEIR – TIS Project-only trips AM 6 3 1 - 2 -
Avila Ranch DEIR – TIS Project-only trips PM 4 2 3 - 7 -
Avila Ranch DEIR - TIS Cumulative plus proj AM 175 83 151 750 355 1400
Avila Ranch DEIR - TIS Cumulative plus proj PM 361 72 203 1500 267 800
SR 227 Study Existing AM 110 27 51 458 214 1297
SR 227 Study Existing PM 280 48 28 1074 64 503
SR 227 Study 2025 Interim AM 111 27 53 498 215 1359
SR 227 Study 2025 Interim PM 312 52 29 1212 68 577
SR 227 Study 2035 horizon AM 112 27 54 538 215 1421
SR 227 Study 2035 horizon PM 343 55 29 1350 72 650
While the two studies’ existing conditions counts appear to be similar, the cumulative-plus-
project figures (Appendix P, Fig. 10) appear to show an outsized increase for some turning
movements. For example, Existing PM for southbound right jumps from 26 to 203 under
cumulative-plus-project. Can the increase in trips projected from General Plan buildout and the
City’s travel demand model be confirmed as to the scale and extent of the increase?
Buckley Rd. extension
The Buckley Rd. extension from Vachell Ln. to Higuera St. is included as a Regional Route Tier 1
in the 2014 RTP-SCS (Project # CEN-RORS-1006).
Additionally, Policy HSR 11 of the 2014 RTP/SCS states: “Work with local jurisdictions to
develop a well-connected street and road system, with parallel and/or alternative routes
adjacent to major highways.”
SLOCOG therefore supports the inclusion of the Buckley Rd. extension, as recommended by the
Airport Area Specific Plan and included in the development plan. SLOCOG further supports the
Appendix
Selected major phased recommendations in the SR 227 Operations Study
• Los Ranchos Road/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [short term]
• Crestmont Drive/SR 227 – subject to immediate-term coordination, install operational
improvements consistent with the Highway Design Manual (considered an interim
improvement prior to roundabout control) subject to Caltrans safety evaluation and
determination, engineering discretion and approval to provide safe ingress and egress
through this intersection [short term]
• Buckley Road/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings). This roundabout would include City of San Luis Obispo
Gateway signage and treatments [short term]
• Rehabilitate pathway from Los Ranchos Road to Crestmont Drive to become part of the
Edna-Price Canyon Trail. Install signage warning bicyclists of private driveway/s south of
Crestmont Drive [short term]
• Construct Edna-Price Canyon Trail from Crestmont Drive to Tank Farm Road based on
the Preferred Alignment adopted by SLOCOG [short and mid term]
• Convert SR 227/Farmhouse Lane to a four-legged intersection (convert to two-way stop
control in interim) [short term]
• Restripe northbound SR 227 for two through lanes between Farmhouse Lane to just
south of Kendall Road (widening would not entail any additional ROW) [short term]
• Restrict turn movements from Kendall Road to right-in/right-out and left-in, and provide
median channelization to restrict the left-out movement [short term]
• Farmhouse Lane/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [long term]
• Crestmont Drive/SR 227 – convert to multilane roundabout (widening at 200 feet plus
taper from up/down stream of intersection, including signage, illumination, and striping
for pedestrian/bike crossings) [long term]
• Widen southbound SR 227 for four through lanes from Farmhouse Lane to just south of
Kendall Road [long term]
Link to full study: http://slocog.org/highways-streets-roads/State-Route-227