HomeMy WebLinkAboutPalm/Nipomo Parking Garage (Naficy) - received 05-11-20171504 Marsh Street
San Luis Obispo
California 93401
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Law Offices of Babak Naficy
May 10, 2017
Hand Delivered
Planning Commission
City of San Luis Obispo
RE: Conceptual Review of Palm/Nipomo Garage
Planning Commissioners,
I submit these comments as a resident of San Luis Obispo and a land use attorney with over
20 years of experience. For reasons that I explain in more detail below, I believe the City
should not pursue the proposed project at this time.
Based on the parking studies cited in the staff report, it is evident that there is no
demonstrable need for this project. The 2015 Parking Study does not justify the
expenditure of significant public funds on a parking structure that is not needed now,
and will not likely be needed for the foreseeable future. The existing parking
supplies (roughly 1/3) will be sufficient to offset the loss of parking associated with
the closure of the parking Lots 2, 3 and 11. If and when a new need for more parking
is identified, that need can be addressed in the future.
2. Even if the need for new parking can be established, there is no evidence to suggest
the parking should be provided in this part of downtown. With new private
development going forward at the other end of downtown, new parking should
likewise be provided where it is most needed. Moreover, parking demand could be
better met through smaller, decentralized parking lots. There is no need for another
large parking structure.
3. Building a substantial new parking structure would be inconsistent with City policies
that favor addressing climate change through promoting alternative transportation
and reducing vehicle miles travelled. If the City is interested in public finacing of
transportation infrastructure, those dollars would better be spent on promoting mass
transit and alternative transportation than parking.
4. The Staff Report's point that the City should spend $1.6 million on an EIR for this
Project at this time because this expenditure does not represent a commitment to the
project is not well -taken. Deciding to prepare an EIR is a significant step which will
give the project substantial momentum. Spending this money on an EIR at this time
makes it much more likely that the Project will eventually be built.
5. I am a fan of the theater as much as anyone. However, I don't understand why the
City would commit to essentially make a gift of public funds to the SLO Little
Theater without a robust public discussion. There are many worthwhile non -profits
who could use a publicly -funded facility. Why are we deciding to build a theater
without any public debate and discussion.
6. The Project will likely cause significant impacts on historic resources. Besides the
loss of two historically significant buildings, the relatively massive parking structure
would dwarf the historically significant residences on Monterey Street. The current
staff proposal is to require the evaluation of the impact on the City's most important
historic district in the course of the EIR preparation. However, the prudent approach
would be to evaluate the significance of the impact on these historically significant
resources before we commit $1.6 million for an EIR that may not be needed if you
decide that the parking structure is not worth the impact on these significant cultural
resources.
7. The Project's impact on traffic and circulation has not been fully evaluated. This
area of town poses unique circulation challenges because of the proximity of the
Mission Elementary and High School, the freeway entrance and exit on Broad, and
the proximity of downtown core. Accordingly, traffic and circulation must be
carefully considered. There is no reason why these issues should not be studied
before you spend the money on an EIR.
8. Finally, if you are convinced that a parking structure is needed at this location, there
are other alternatives that are cheaper and would avoid the impact on historic
resources. These include building a subterranean parking structure under the Mission
High School athletic field.
For all these reasons, I ask that you not move forward with this Project and an EIR at this
time.
Sincerely,
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Babak Naficy