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HomeMy WebLinkAbout06-07-2017 PC Correspondence - San Luis Ranch (Cross)1 Chair Stevenson and Planning Commission members: I’m pretty disappointed of the thoroughness in the review of the San Luis Ranch Specific Plan, Final Environmental Impact Report, General Plan Amendment, Vesting Tentative Tract Map, and Annexation. The detailed review by the Planning Commission that should be occurring with a project of this magnitude is missing. I understand that the timeline for review is very short in my opinion. “The Permit Streamlining Act is not applicable to the adoption of a specific plan. Therefore, prudence should prevail in the adoption of deadlines which are functional and realistic” (Governor’s Office of Planning and Research.) In discussions with Community Development Dept. Director Michael Codron the reasoning for the short review period was due to Housing (production?) being a Major City Goal. ” Housing. Implement the Housing Element, facilitating workforce, affordable, supportive and transitional housing options, including support for needed infrastructure within the City’s fair share.” (City of San Luis Obispo 2015 -17 Goals). I would note that the City’s 1% residential growth rate Land Use Element Policy 1.11.2 could be reached with the current construction of the Margarita Area Specific Plan, Orcutt Area Specific Plan and other residential developments, so I’m somewhat surprised that the meetings were scheduled within a short timeframe with review of the FEIR and Specific Plan review combined. This meeting all the elements of the project have been combined limiting public input as well as Commission review. The Commission is being asked to find the Specific Plan consistent with the General Plan Land Use and Circulation Element , Parks and Recreation Element, and Housing Element. The lack of discussion regarding particular policies within the General Plan is alarming. The provision to allow the developer to pay in lieu fees for not meeting the required Park land is appalling. The Parks and Recreation Commission supporting the payment of In - lieu fees is even worse. The Commission should not be allowing a development of 546 new single family and multi-family dwelling units and 34 new affordable units to immediately be underserved. There will be nearly 1300 residents living in this project not including those working (number?) in this Specific Plan area. The In-lieu program is designed for small projects where it is impractical to provide park spaces on site. Disadvantaged communities are lacking in parks and desperate communities allow developers to pay in lieu fees for infrastructure the community is unable to afford. San Luis Obispo is neither of these. The 2.4 acres the developer is not required to dedicate to parks is a financial windfall to the developer. The Planning Commission should be asking how much In-Lieu fees the developer is required to pay. The Planning Commission should also be asking if the Margarita Specific plan paid Park In-lieu fees 2 along with the Orcutt Area Specific Plan and Devaul Ranch. If those projects paid In - Lieu fees the City is getting even further behind in providing adequate park space. If they didn’t, why is this project being allowed to pay In -Lieu fees. The Commission discussed using the In-lieu fees to fund Laguna Lake Park improvements. I will note that Laguna Lake Park not intended to have intensive uses such as tennis courts, basketball courts, softball fields, or soccer fields. The City should be using its own monies for any potential park improvements. The community renewed the ½ cent sales tax, of which parks and open space acquisition and improvements were a determining factor in voting in favor of the ballot measure. Land Use Element Policy “2.3.10. Site Constraints The City shall (emphasis added) require new residential developments to respect site constraints such as property size and shape, ground slope, access, creeks and wetlands, wildlife habitats, wildlife corridors, native vegetation, and significant trees.” Land Use Element Policy 2.3.10 uses the word “shall”. “Shall” is not permissive. “Shall” means you have to do it. The project certainly doesn’t respect the significant trees which are found on the site. Unless you consider “respect” as to mean that the trees are going to be cut down. The project is not consistent with this Policy and there has been no discussion from the Commission regarding this specific Land Use Element Policy. The mitigation is speculative. There was some discussion regarding mitigation and new information but it appears from Natural Resource Manager Bob Hill’s explanation that the Heron in question was not the same species that is found on site. The removal of these trees which have been a part of the site for over 50 years will impact the character of the site and the community. The Specific Plan should be consistent with LUE Policy 2.3.10. The is no reason the project cannot be designed to meet this policy. The project is inconsistent with Housing Element Policy 4.1 Within newly developed neighborhoods, housing that is affordable to various economic strata should be intermixed rather than segregated into separate enclaves. The mix should be comparable to the relative percentages of extremely low, very-low, low, moderate and above-moderate income households in the City’s quantified objectives. I don’t how you can find the Specific Plan consistent with this policy. The housing types are clearly separated from each other. The highest density (NG 30) is the definition of a separate enclave. I guess there is a foot bridge that connects this section to the other 3 areas. I don’t see how you can find the Specific Plan consistent with Housing Element Policy 4.1. Table 4.9-1 of the Final EIR is the evaluation of the Specific Plan’s Consistency with City of San Luis Obispo General Plan. The Planning Commission is being asked make of finding of General Plan consistency. These City policies need additional discussion and review by the Commission and changes to the Specific Plan to brin g the plan into consistency with the City’s General Plan. The buildout and financing of the Prado Rd. Overpass is of extreme concern. The financing of the overpass is not provided in the documents. The cost is unknown and the City’s financial obligation is unknown. The City is at great financial risk if funding is not available to complete the Prado Rd. intersection if development entitlements are granted to the property owner through annexation, Specific Plan Approval, and other development entitlements. The loss of property values potentially due to the City’s inability to secure funding for the City’s portion of the overpass will either result in the property owner suing for losses because the inability of individuals to access the site for commerce has a negative financial impact or the City having to reduce services or capital improvements in other spending categories to make good on the City’s obligation. The lack of discussion regarding the acquisition and resultant hardscape areas needed for widening of various intersections and the elimination of the landscape median West of El Mercado on Madonna Rd. in an attempt to mitigate curren t and future traffic impacts is concerning. The resultant loss in landscaping creates a hard urban 3environment and impacts the character of the community and quality of life for residents. The lack of detail with regards to the retail and office portions of the Specific Plan, including the transition from the housing component is alarming. There should be significantly more discussion by the Planning Commission with respect to these areas and how the residential portion and the office/retail portion adjoin. Housing components in the office designated areas should be required. The affordable housing units are not proportional in number to the housing t ypes proposed by the project. The affordable units should be proportionally represented throughout the project. The discussion regarding that changes to the Specific Plan would not meet the Project’s objectives are perplexing. The Project’s objectives are not superior to the lessening of environmental impacts through reduction in the number of housing units, retail area, or 4 office area. There should be more discussion regarding reducing environmental impacts from this project by reducing the number of housing units, retail space, or office space. The following are excerpts from the The Planner’s Guide to Specific Plans Governor’s Office of Planning and Research January 2001 Edition. The City should have followed the process as outlined in the document. Unfortunately the City did not and the San Luis Ranch Specific Plan bears this out. Sincerely, Brett Cross San Luis Obispo, CA Legal Adequacy A specific plan must meet the minimum requirements of the statute listed above in order to be legally adequate. Numerous specific plans reviewed by OPR commonly lack one or more of the following: • A discussion of the methods to be used for infrastructure financing and a program for implementation • A detailed statement of the relationship of the specific plan to the general plan, including consistency between both plans and a comparison of goals, objectives, and policies. • A discussion of how the plan implements the policies of the general plan. Adoption Deadlines: Deadlines should be incorporated into the work program to ensure the timely completion of the specific plan. The deadlines should be reasonable to ensure that the quality of the product is consistent with the expectations of the decision makers. The time lines are typically a product of either the political constraints of a local legislative body, or the development proposals which will follow after the adoption of the specific plan. The Permit Streamlining Act is not applicable to the adoption of a specific plan. Therefore, prudence should prevail in the adoption of deadlines which are functional and realistic. Public Participation: The participation of those working or residing within a specific plan area or more broad participation of the local citizens can play an important role in the preparation of a specific plan. Section 65453 states that “A specific plan shall be prepared, adopted and amended in the same manner as a general plan...” as such, opportunities for the involvement of citizens, public agencies, public utilities, civic education, and other community groups must be 5 provided pursuant to §65351. For example, the City of San Jose utilizes the assistance of a community-based task force composed of property owners, business owners, residents, other agencies, school districts, and other stakeholders when preparing specific plans. The city credits this involvement for the general support apparent during public hearings on and implementation of its specific plans. Policies, Implementation Measures, and Alternative Plans: For any set of objectives there will be a number of possible courses of action to pursue. Policies, implementation measures, and programs should be developed for each of the alternative planning scenarios. The relationship of each objective and alternative course of action should be considered in light of the general plan, zoning ordinance, subdivision ordinance, capital improvemen t program, and other programs that will be implemented. Consistency with the general plan should be carefully analyzed and the plan amended as necessary. The policies, programs and implementation measures provide for the creative application of the specific plan to the planning area. Each should be carefully reviewed for clarity, effectiveness, and functional application. The alternative plans enable the decision makers, stakeholders, and other participants to choose from a variety of scenarios, solutions, and programs which will shape the planning area. Although the alternatives may only differ in their treatment of a particular issue, each must be realistic to ensure that the alternative is viable. In addition, the alternatives may be used to satisfy the EIR’s requirements for a discussion of project alternatives.