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HomeMy WebLinkAbout04-07-2017 - Avila Ranch Draft Environmental Impact Report Recirculation - Los Verdes Parks 1 and 2 Homeowners' Association (Flickinger)Sarah Flickinger On Behalf of the Los Verdes Parks 1 & 2 Homeowners' Associations c/o Attn: Sarah Flickinger, Los Verdes Homeowners' Association, Inc. San Luis Obispo, CA 93401 Re: Recirculated Portions of the Avila Ranch DEIR April 7, 2017 RECEIVED CITY OF SAN LUIS OBISPO APR 0 7 2017 COMMUNITY DEVELOPMENT To the City of San Luis Obispo, City Planning Commission and Developers of Avila Ranch: In reviewing the recirculated portions of the Avila Ranch DEIR, our neighborhoods have concerns with the findings with regard to energy and other impacts, mitigations outlined therein. The report within the attachment appears to have some errors/omissions. For instance, there are areas where a section is available for listing mitigations, but no mitigations are listed in the appendix, but they are outlined within the summary. See in example mitigation measures for Waste. There are also measures such as Low VOC Paint and Low VOC Cleaning Supplies being listed as offset mitigations, though the developer has no ability to guarantee continued use of these materials within the homes, parcels, landscapes and other areas beyond the initial construction. These are short term single point mitigation that does not encompass operational aspects of the development. To use these measures as part of the calculations for ongoing balancing of environmental impacts presents a flaw in the long-term viewpoint. Air Quality Impacts can be mitigated to some degree over the long-term with urban forestry planning with the use of diverse female, monoecious and/or evergreen native trees. Some requirement or provision for maintaining any agricultural barriers and urban forest mitigations in perpetuity should be included to ensure the long-term benefits are attained. During the development plan phase, specification for larger mature trees at the time of development can help expedite the benefits. It was disappointing to see no grey water usage integrated into the commercial or residential portions of the development. While reclaimed water has benefits, the use of gray water can add an additional depth to water preservation and its inclusion in new developments offers benefits to restoring the water cycle. It was also disappointing to see standard building requirements such as solar commercial buildings and low -flow toilets being used as energy offsets. These must be included; they are not optional mitigations. Including them as such effectively double -counts their benefits to the environment and is misleading. Alternative measures that provide better mitigation in addition to building code requirements would be limiting the amount of uninterrupted paved areas with shade producing plantings to offset the heat island effect, use of permeable pavements or integration of living roofs on a certain percentage of buildings and facilities. We would like to express concern at the lack of water use during construction and grading, as presented in this document. What was an agricultural percolation field is slated to be graded and barren throughout early construction phases, and, in some cases according to the phasing herein, throughout the 10 -year duration of the project. This will have a negative impact on air quality in the vicinity for 10 years, with increased particulate matter. It will also have a negative impact on surface temperatures ("heat island effect") due to loss of vegetation. It could present challenges for neighboring areas with regard to storm runoff as well, and, without water or cover plants, the ground will become hardened and less penetrable until such time that a percolation area is added to the site. Additionally, there is a chance that some of the soil on this site may have been exposed to contamination, and to let contaminated soil become airborne for 10 years presents an additional health hazard to neighboring residences, cyclists and workers. Storm water retention measures should be integrated into the construction and design of the neighborhood as a mitigation measure to ensure longterm sustainability. Once complete, disturbed ground areas on and offsite not subject to development should be required to be replanted with native plantings to ensure reestablishment in the near term, which improves drainage, reduces runoff and creates a positive contribution to air quality and water cycle restoration. No such mitigation is currently included in the documents. This can create hazards for vehicles, pedestrians and cyclists in the form of dust and gravel spilling into sidewalks, bike lanes and streets. The additional fuel consumption for neighboring residential and commercial users due to construction impacts as well as future traffic impacts is also not included in this model. For instance, the addition of project traffic creates a_failure for multimodal transport at the intersection of Los Verdes Drive and Los Osos Valley Road. The DEIR's mitigation is that cyclists utilize a portion of the Bob Jones Trail that has yet to be built to access neighborhood commercial. For my personal household alone this would account for 8-12 vehicle trips per day no longer being taken by bicycle. As short - cycle neighborhood trips consume more fuel than freeway trips, this problem quickly compounds. Without signalization at Los Verdes Drive, it is unsafe to cycle and therefore fuel consumption for additional car trips to and from the nearly 200 homes in the Los Verdes Parks should be modeled as part of the energy impacts of this development, as well as the same for the neighboring Las Pradreras neighborhood, among others. As the Bob Jones Trail is the proposed mitigation measure (though it is not being built as part of the development), the energy consumed in the trail's development should also be taken into consideration in order to achieve a full and accurate assessment of the energy impacts of this development. There are also additional vehicle miles travelled that should be calculated based on the proposed temporary closure and future limited access to Buckley Road via Vachell. Many vehicles use this route daily. The additional distance to travel to Tank Farm Road and back via S. Higuera and 227 for all of these vehicles for 10 years (and beyond in some cases) should be calculated, considered and reported in a clear way. We feel strongly that this document underestimates the short and long-term energy impacts of this development with its currently proposed mitigations. Lastly, noise impacts remain unaddressed in the recirculated portions of this document, as do air quality impacts to neighboring residential areas. These need to be identified and addressed in a subsequent recirculation prior to publication of the final EIR. Sincerely, Los Verdes Park 1 Homeowners' Association, Inc. Special Board Member Representing the Los Verdes Parks 1 & 2 HOAs Sarah Flickinger