HomeMy WebLinkAboutSan Luis Ranch DEIR Public Comment received 1-30-2017 (Wyatt)
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Davidson, Doug
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Monday, January 30, 2017 7:34 AM
To:
Bergman, Katelin
Cc:
John Rickenbach
Subject:
FW: San Luis Ranch DEIR comments
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San Luis Ranch DEIR comments.pdf
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CITY OF SAN LUIS OBISPO
JAN 3 0 2017
COMMUNITY DEVELOPMENT
Hi Katelin, comments on San Luis Ranch for forwarding to Rincon consultants, Chris Bersbach. Thanks
From: AR Wyatt [
Sent: Sunday, January 29, 2017 11:48 PM
To: Davidson, Doug <ddavidson@slocity.org>
Subject: San Luis Ranch DEIR comments
Mr. Rickenbach/Mr. Davidson: Thank you for incorporating comments, attached here, into the project Final EIR. All
best. -a
anne wyatt
(
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January 30, 2017
Attention: John Rikenbach, Contract Planner, and Doug Davidson, Deputy Director
Community Development Department
City of San Luis Obispo
919 Palm St.
San Luis Obispo, CA 93401
Email: ddavidson@slocity.org
Re: ANNX-1502-2015; San Luis Ranch Draft EIR
Dear Mr. Rikenbach and Mr. Davidson:
Thank you for the opportunity to comment on the DEIR for the San Luis Ranch. While I
generally concur with and applaud the team's rigorous analysis and assignment of project
impacts and mitigations, there are a few impact areas which merit further discussion, analysis,
and in some cases, assigning a higher level of impact. Also, more analysis of the denser, less
impactive environmentally superior project Alternative 3 should be undertaken to better
understand its housing impacts and potential community enhancing benefit.
Traffic/Circulation
In general, the analysis follows a typical fair share analysis, requiring project to contribute its fair
share to improvements. This kind of analysis assumes, however, that there will be a large
enough pool of transportation funding to complete expected required improvements. What if the
funding pool is not large enough to complete expensive improvements, such as the required
Prado overpass? Given the recent failure of passage of transportation Measure J, the limited
SLOCOG budget for the future, the recent funding of the LOVR project (taking City fair share of
regional funding for the near to mid-term) and the limited number of city-wide development
projects slated to pitch in, the Final EIR should address and analyze the possibility there will not
be sufficient funding for the overpass.
Given that the Specific Plan for the area (A) emphasizes and requires an overpass or
interchange at Prado, and (B) mandates "circulation connections to integrate property
with surrounding circulation network for all modes of travel," yet no likely full funding
package is identified, this uncertainty on provision of Prado and other connectivity
provisions should be considered and identified as a Class -I impact. Further analysis of
how a pool sufficient for such a costly project could reasonably be expected --and when
it could be expected to be accumulated— should be analyzed.
Of further note and concern to cyclists and those with intention of reaching the City's LUCE
targeted multi -modal objectives, including 20% cycling, several traffic impacts at intersections
are proposed to be mitigated with double turn lanes. This may make sense for motorists, but it
conflicts with the goals of the LUCE and the Bicycle Transportation Plan. Double turn lanes
make cycling very difficult and dangerous. They are challenging for experienced cyclists to
safely navigate and are a major impediment to less skilled cyclists Such "solutions" will in fact
impede h City from meeting multi -modal goals not assist
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• Find alternate mitigations in the toolbox to alleviate Class -I impacts at intersections
other than proposed double turn lanes (whether left or right).
AG/FARMING
Housing Policy (11:2) states: Prevent new housing development on sites that should be
preserved as dedicated open space or parks...
Yet, despite this policy, the proposed project Specific Plan requests a zone (NG -1) with up to
350 single-family residential units. This zone would consume 35.33 acres of prime agricultural
soils. (Comparatively, the 150 proposed multi -family unit zone (NG -2) would consume only 6.52
acres.) A denser housing mix can happen, as the project specific plan proposal itself shows
(with a greater percentage of NG -2 land area). It is possible the environmentally superior
alternative project 3 would minimize some agricultural land disturbance by retaining the
historical structures in place, but without more detail included on alternative 3, this is difficult to
determine. Clearly, the number of housing units can be maintained with a denser option, while
maintaining agricultural lands.
• A viable project providing much-needed housing and also consuming less of the 109
acres of prime agricultural lands should be analyzed in the EIR. Not providing alternative
analysis- of a project upfront (with less NG -1 area and more NG -2 area, for example) forgoes
viable alternatives to a variety of identified impacts and conflicts with community plans and
gal , as if both ot''ectives to protect agricultural lands AND provide housing could not be met.
Setting the scenario up as an "either/or" is falsely limiting and misleading Housing can be
reated AND farmlands rotected on this site. Because a viable protective option analysis is
not run in this DEIR, it seems to falsely assume this notasp sible.
• The loss of approximately 80 acres of Class I and Class II prime agricultural soils—over
half the site—should be designated as a Class -I impact. Given that the current acreage
remains viable next to City Farm and LESA score is 66, making it significant—the Class -1
impact designation is necessary. Section 4.2-17 of the DER includes circular thinking that
does not diminish Class -I impact: "Nevertheless, the project would convert Prime Farmland to
nonagricultural use, resulting in potential conflict with Land Use Element Policy 1.8.1.
However, Land Use Element Policy 1.9.2 allows development on prime agricultural land if the
development contributes to the protection of agricultural land."
Development contributing to the protection of AG land? This suggestion reads Orwellian
double -speak. Continuing farming protects AG land, not housing and commercial developments
taking over what was once farm land.
• Not only should Class -I impact be identified, but the EIR must recalculate actual agricultural
remainder land: It appears the 46% remnant agriculture calculation includes the proposed
homestead reconstruction. This area, if included in the project, should be part of the
developed area calculation. The farmstead commercial/social/history area is not active
farming, it is development.
While the re-creation may indeed be of community interest and of economic benefit—and
something special to draw people to the site—it should be considered as the development it is—
not be considered farming. If this is counted as farming, it seems akin to tearing down our actual
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downtown to construct a Disneyland Main St. re-enactment of a thriving small town and
counting that as a downtown.
There is sufficient project area to place the commercial operations within commercial
development zones. The circular logic of encroaching upon active agriculture in order to
"protect" it is egregiously flawed. After we build over farmland in order to protect it, let's go tear
down a trailer park and kick all the low-income residents out so we can construct a museum of
affordable housing. (Both would seem poor choices.)
As far as the project proposal to provide offsite mitigation for the lost farmland, DER 4.2-19 has
questionable logic, or possibly a typo: It states:
"Residual Impacts. Mitigation Measure AG -1 would reduce the impacts associated with
the conversion of Prime Farmland consistent with the intent of Land Use Element Policy 1.9.2.
In addition, Mitigation Measure AG -1 would require a minimum of 59.3 acres of land of
comparable agricultural productivity to be preserved in perpetuity to satisfy the requirement
that impacts to Prime Farmland be mitigated at a 1:1 ratio. In addition, pursuant to the Land
Use Element Policy 1.13.8, which requires that 50% of the project site's acreage be retained in
agricultural and/or open space uses, preservation of 59.3 acres of Prime Farmland offsite would
result in a mitigation ratio of approximately 10:1 (acres preserved off-site to acres required
onsite), which would appear to satisfy the intent of the "substantial multiplier" clause."
Huh? The 10:1 ratio doesn't make sense. Possibly it is a typo? This paragraph would only seem
to make sense if approximately 600 acres were to be conserved off-site for the 60 acres lost on-
site. As it is, the 50% of the onsite acreage is not being reserved, as required, and only a
minimal 1:1 replacement off-site is proposed. The suggested notion that the replacement meets,
never mind exceeds, requirements is confusing.
Housing
While the proposed project's 34 deed -restricted affordable housing units will help meet a small
fraction of the housing needs of lower-income city residents, the 34 units equate to only 6% of
the homes proposed. With 14 identified Class -1 project impacts, that's over 1 high-level
community -wide impact to every three affordable housing units. As not one of the housing units
of 580 is proposed to meet the needs of the City's estimated 26% extremely low-income
households (Housing Element, 132), the unit cost seems exceedingly high. It would seem that
with 580 housing units constructed and all the Class -I impacts noted, at least a hand full of
houses should serve the needs of some of the quarter of the City's households in the extremely
low income category. Housing policy 2.4 does in fact ask this of City projects.
Housing policy 2.4; Encourage housing production for all financial strata of the City's
population, in the proportions shown in the RHNA Allocation for the 2017-2019 planning
period... extremely low income 12%; very low income 12%; low income 16% ; moderate income
18%; above moderate 42%;.
(Housing Element, B.2) In 2010, approximately 4,959 extremely low-income households resided
in the City, representing 26 percent of the total households. Most (85 percent) extremely low-
income households are renters and experience a high incidence of housing problems.
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• If the project does not incorporate housing roughly in the range of 60 extremely -low
income, 60 very low income, 80 low income and 90 moderate income housing units, the
EIR should therefore designate the project "potentially inconsistent" with housing
policy 2.4.
The DEIR analysis seems undertaken with an implicit notion that any new housing in the City is
good and beneficial, and the limited mix of housing options offered by the project meets the
intent of City diversity goals. Despite talk of housing not keeping up with growth, the City of San
Luis Q i Housing Element states that betty en 2000 and 2010 more housing nits were
constructed in the City than there were new residents:
(Housing Element A24) Housing units added increased faster than population rate. Between
2000 and 2010, there were 1,247 housing units added compared to 945 people added.
Moreover, it has been median and above -median housing—most of what project proposes—
which has been created in excess of city resident identified need or actual population growth. In
fact, if one extrapolates and takes City average household size of 2.29 and multiplies it by the
1,247 units created in 2000-2010, housing was created for more than 2,700 persons—over
twice the increase in City population over the same time period. Given this disparity, one has to
wonder why city residents should shoulder such a number of Class -I impacts, many of their own
housing needs unanswered, in order to house incoming wealthier residents in housing likely
outside the range of affordability for most City residents? If this is the intent of the project or the
unintendedresult, i r h in impacts resultingfrom thes new re i n
should be analyzed including extra need for unprovided for very low and extremely -low income
affordable housing resultinci from increased low paid service job demand, such
housekeeping, gardening serves and retail clerking=
• A thorough, targeted housing impacts analysis will consider the above realities and
require housing targeted to this identified need, as policy 2.4 addresses. A project on this
site (possibly the environmentally superior Alternative 3) certainly can meet the actual housing
needs of a changing and growing City population. The proposed project mix offers only limited
solutions, however. In addition to disconnect between above -identified need and project
offerings, more robust EIR analysis should consider:
• Need for rental housing: lower income residents desperately need affordable rentals; for
purchase housing does nothing to meet their pressing needs
• Need for more smaller affordable housing for growing numbers of single -person
households—particularly single seniors: In the coming decade, half the new households
are projected to be single -person households, and almost all the household growth will be in
the over -sixty cohort. (Harvard JCHS at: littp://jclis.iiarvard.edL]lj-eseai-cil/publicationslu do ated-
lzouselio ld-pi-ojections-2015-2035-iii et hodo Ingy-and-resii.Its)
• Alternatives to the standard parking scenarios: Rather than the high number of
proposed outdated front loaded single family dwellings, which emphasize an outmoded car -
culture by siting housing around car storage, at least an equal number of housing units in
the mix should have no parking or shared parking options; the outdated 198O -s two car
- arage front-ioaded product encourages a high level of car trips, vehicle miles traveled and
ensuing -air -pollution and traffic impacts, which the EIR acknowledges cannot be mitigated.
Minor changes in project housing product mix and phasing could better meet multiple
objectives, including agricultural land preservation, multi -modal goals, water and energy saving
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and meeting targeted real community -wide future housing need. Class-[ impacts can be
reduced and housing needs more effectively met in several ways.
- In consideration of the proposed project or the more dense environmentally superior
Alternative 3, Final EIR analysis should consider:
1) Phasing and consequences of phasing: Mitigation: Require construction of the
smaller, more affordable housing first, reversing proposed phases 1, 2 and 3—or
construct concurrent with lower -density units. Often, in my experience studying a wide
variety of communities nationwide, single family housing residents block proposed higher
density (lower-income) units proposed in later project phases, and lower densities than
originally planned are constructed, despite original claims the project will one day benefit
lower income residents. late tusin of higher density housing effectively negates. or at
minimum delays, the low-income affordable housing benefit of ro'ects. Switchingthe
h s
ing. necessitating construction of the more nee ord ble_housin first will miti ate
housing related impacts ensuring provision of needed more affordable housing first, a_s.
opposed to hoping such units MAY get -built down the line
2) Require rental housing as a certain percentage of housing mix. Meeting a diversity of
housing need includes meeting the increasing need for rental housing. As proposed, this
project may not provide a single unit of desperately needed rental housing. Without
requirements for construction and ongoing rental housing provision, it is common for
projects constructed on claims of "residential mixing" of income groups to see the rental
housing never constructed or to see it gradually converted to ownership housing, eliminating
the proposed benefits to groups depending upon available rental housing.
3) Provide reduced parking analysis incorporating some housing units without parking:
While the DEIR notes Class -I impacts in relation to the project multi -modal standard
deficiencies and traffic and air pollution, it is deficient in failing to link some of these impacts
to housing, parking and land use choices dictated by the predominance of the NG -1 specific
plan single family detached with garage zone. The old -school two -car front or rear loaded
garage model of housing over a significant portion of project site maintains a status quo car -
centric approach—and negates multi -modal efforts. By emphasizing and providing easy
parking this zone and land use development pattern makes driving the easy go -to choice,
exacerbating traffic and traffic related air pollution issues. A different variety of housing
product, incorporating easy -grab bicycle parking in/adjacent to all units and no parking
attached to some units (for people who choose or must live care -free) should be analyzed in
some fashion and included in the project. If the housing assumption in a specific plan zone
set up for it is easy parking attached to all units, the result is going to be unacceptable traffic
impacts. There are options, even if perceived as less profitable, and the EIR should consider
actual impacts of land use provisions, such as the high level of attached garages.
4) Further analysis of population need and housing diversity: While this project includes a
mix of relatively modest homes and some diversity in housing type, it could provide much
more substantial diversity to better meet city zero net energy, multi -modal and affordable
housing policy goals of the City. A wider, more useful housing product portfolio would better
meet housing policy 8.1, 2.4 and others, by including: zero parking units, more smaller units,
including studio rental units and live -work units— as opposed to the relatively low density
single-family housing with garage parking over a substantial portion of the site. Options not
offered and not comprising current City housing stock would better serve the needs of the
growing number of poorer, single, older renters, who will need smaller, affordable,
accessible rental units. Changing preference and technology means many City residents will
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not rely on cars and driving for mobility—and more single -person households will have only
one car at most, so why double park most every unit detached unit, charging residents and
community members for parking some may not choose? Because specific parking -related
impacts are unaddressed, the discussion of community -serving housing options is hindered
and housing policy 8.1 isn't met. The EIR should therefore consider the project
potentially inconsistent with housing policy 8.1.
Housing Policy 8.1: Encourage housing development that meets a variety of special needs,
including large families, single parents, disabled persons, the elderly, students, veterans, the
homeless, or those seeking congregate care, group housing, single -room occupancy or co -
housing accommodations, utilizing universal design.
5) Require mandated median -income and workforce -income affordable deed restrictions
or other options, such as smaller units and units with reduced parking, to mitigate for
impacts and target housing to identified City need: While this project is ostensibly
conceptualized to meet City workforce and lower income housing needs—and it well MAY meet
some—as is, there is no provision that it do so. Only 34 of 580 proposed housing units have any
deed restrictions mandating any level of "affordability," and there is no promise that any units will
be rental housing. Barring restriction of some kind, as housing prices continue to increase, the
vMtt mgjority of the houses will be priced with the market. The market may well -price-out-the
families the project is purported to help, as seen in other local projects, such as Serra Meadows,
where the average home price now is around $700,000 or the Marsh St. condos purportedly
selling for $1.2M—well above affordable, even for workforce households. As noted above, an
influx of above median households brings impacts, and growth inducing impacts (especially to
service worker housing) should then be analyzed.
Despite the notions of "mixed-use" used in the project plan and others, my experience watching
New Urbanist communities, such as Celebration, FL, suggests that despite claims that residents
will live and work in proximity—without true inclusionary and diverse housing allowing a
substantial percentage of very low income persons to live in the development—many residents
of the new developments commute out of the development to higher paying jobs elsewhere
(often commuting higher than average distances), while service workers commute into the
development to cover the minimum -wage grocery check out, coffee shop and gardening tasks
the developments demand. (Service workers cannot typically afford the for -sale workforce
housing that projects such as this provide.) Even with pleasant recreational parks and trails
within the development, traffic and vehicle miles traveled increase community -wide as a result.
Easy garage parking and recreational trails not connected to a viable community network of
safe, amenable options getting people places may provide convenient exercise opportunities to
area residents, yet they do not save car trips.
A wider variety of housing offerings in a denser mix, with less parking, may minimize project
traffic and air quality impacts and better meet a variety of City and project objectives. A more
detailed analysis of such a mix (under a denser, mixed project Alternative 3, for example) in the
Final EIR with above proposed discussion and mitigations included would help answer an array
of outstanding questions and ensure that project housing proposed meets City housing needs
and objectives for the near term and long term.
Practical Considerations and review challenges: Reviewing DEIRs, such as this, is made
more complicated when Appendices are labeled only with numbers, such as on the City of San
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Luis Obispo's website here: tt ://www.slocit .or 1 overnmen de m n -direct r f o mun t -
developmentldocumen S-anlinelenvironmental-review-documents/-folder-1882 . Finding out
what each appendix document is, when identified only with a number, requires clicking on each
individual numbered link. In the aim of facilitating review and public input, titles included in such
future appendices (along with the numbers), would help struggling readers considerably.
Slogging between links is challenging even when with labels.
Thank you again for the opportunity to review and comment on the DEIR, in hopes of creating a
higher level of detail capable of supporting a meaningful, well informed project review by the
public and decision makers. I look forward to the continuing process and the creation of a
sustainable, multi -modal, community -enhancing project which will in fact benefit a cross-section
of City residents and be a show piece and model for smart, innovative solutions.
Sincerely,
AR Wyatt