HomeMy WebLinkAboutSan Luis Ranch DEIR Public Comment received 1-25-2017 (Los Verdes Park Homeowners Assn. 1 and 2 - Flickinger 1)GW V4 61 25111 PC
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. RECEIVED
92 Los Verdes Drive CITY OF SAN LUIS OBISPO
San Luis Obispo, CA 93401 Meeting:JAN 2 7 2017
January 25, 2017 Item: 1; LIP- 0EI12__ COMMUNITY DEVELOPMENT
re: Planning Commission Hearing, San Luis Ranch DEIR
To the City of San Luis Obispo, City Planning Commission and the developers of San Luis Ranch:
The Boards of Directors of the Los Verdes Park 1 and Los Verdes Park 2 homeowners' associations are concerned with
the CEQA compliance of the San Luis Ranch DEIR documents as prepared and submitted for today's public hearing. The
following include some of the inconsistencies with CEQA and General Plan requirements. Due to these issues, we
respectfully request that the document be adjusted, properly noticed and recirculated for public review as required
under CEQA.
Impacted existing residences and other interests were not properly noticed of the DEIR's release as required under
CEQA.
The DEIR proposes changes and mitigation measures -that are not consistent with the goals and programs in the City of
San Luis Obispo's General Plan and suggests that changes to accommodate the inconsistencies be addressed with a
General Plan Update, including previously unreviewed and unapproved traffic mitigations, within the DEIR without
proper notice and separate public review of the proposed General Plan updates.
The DEIR proposes changes and mitigation measures relating to traffic circulation that are not consistent with the City's
stated objectives or plans for multi -modal transportation as outlined in the Land Use and Circulation Element of the
City's General Plan. CEQA requires consistencies with existing plans.
The DEIR is not consistent with CEQA requirements as it includes mitigation measures which cannot be legally imposed
due to conflicting legal commitments between our neighborhoods, the City and the State of California Transportation
Department.
The DEIR does not fully evaluate all significant impacts of the project, including, but not limited to, any evaluation of the
intersection of Los Verdes Drive and Los Osos Valley Road and noise impacts, air quality impacts and light pollution
impacts at known and additional sensitive receptors in proximity to the project and its traffic impacts, particularly in the
area of the Los Verdes Drive intersection with Los Osos Valley Road.
The DEIR does not accurately represent the totality of environmental impacts with regard to the Prado Road overpass or
future Prado Road Interchange at US 101. As this crucial crossing may still be impossible to build during the near term
for any variety of reasons, it should not be assumed as a viable mitigation measure for traffic impacts.
The DEIR should address updated traffic counts following completion of the LOVR Interchange Project for accuracy in
assessment of existing conditions, the need to assess and project future noise impacts, the need to ensure mitigation
measures from other projects that have not been completed are not assumed (i.e. mitigation measures for Chevron
development, incomplete mitigations remaining following LOVR Interchange Project, not yet approved mitigation
measures for Avila Ranch, etc.), a full detailed analysis of the project in all terms with and without the various options
for Prado Road interim and complete connectivity AND with and without the LOVR Bypass as it relates to changes at
Prado Road, and significant study of the LOVR Bypass effects in mitigating existing and long term traffic impacts in the
region, among others.
Furthermore, the use of traffic counts taken during March 2015 in the vicinity of Los Osos Valley Road, South Higuera,
US 101, Tank Farm Road and Buckley Road is misleading and inaccurate in assessing the current traffic conditions. At the
time of these traffic counts, normal traffic patterns were significantly altered as result of it being a late midpoint of
construction on the LOVR Interchange Project which included lane and other closures which discouraged use of this area
and encouraged uses at other areas such as Madonna Road, 227/Broad Street, etc. Current traffic counts now that the
LOVR Interchange Project is completed should be taken in order to accurately describe the current traffic and more
accurately assess/project the future traffic volumes in the DEIR. The traffic study began development following or at the
near point of completion of the Interchange Project; new traffic counts should have been taken at that time to have any
accuracy to the DEIR. The currently included traffic counts are not representative, should be revised and the mitigation
measures reassessed based on the current more accurate counts. Such significant changes would trigger rerelease of the
DEIR under CEQA.
Our neighborhoods and the neighborhoods where our schools are located failed to be noticed at every step of the
project as required, including, but not limited to, the scoping hearing, this DEIR hearing, the DEIR release and so forth.
We have followed this project, among others, and have continued to be vocal in this failure of notice. However, it
remains an ongoing problem, both under CEQA as well as the terms of our settlement agreement.
In conclusion, this DEIR needs to be revisited in so many ways to be compliant with CEQA requirements. Continued
failure to address these issues up to and including, but not limited to, fundamental changes to the DEIR and full
notification and recirculation of the document, may have the effect of putting the future of this project in jeopardy.
CEQA and General Plan requirements were enacted to protect citizens, developers, lead agencies and others through
the development process, and must be adhered to not only because it is law, but also because it is in the best interest of
balancing the sometimes -competing interests of all the parties involved. We remain committed to working with the City,
Developer and other interested citizens to ensure the best possible decisions are made.
Sincerely,
Los Verdes Park 1 Homeowners' Association, Inc.
Special Board Member
Representing the Joint Partnership of the Los Verdes Parks 1 & 2 HOAs
Sarah Flickinger