HomeMy WebLinkAbout06_28-29_2017 PC Correspondence - Avila Ranch (CALTRANS)
From: Streder, Melissa@DOT <
Sent: Wednesday, June 28, 2017 9:55 AM
To: Advisory Bodies
Cc:
Subject: Caltrans Comments on Avila Ranch Development Project FEIR
Attachments: AvilaRanchDevelopment_FEIR CaltransComments06282017.pdf
RECEIVED
CITY OF SAN LUIS OSISPO
JUN Z S 2017
COMMUNITY DEVELOPMENT
Please find attached Caltrans Comments on the FEIR for the Avila Ranch Development Project FEIR. I sent these comments to
Tyler Corey, the primary contact person for this project, but it appears that he will be out of the office until next week. In his
absence we wanted to make sure that our comments were available for the planning commission to consider at this evenings
hearing regarding the project. Thank you for considering these comments and please feel welcome to contact me if you have
any questions.
Best Regards,
Melissa Streder
Associate Transportation Planner
California Department of Transportation
(805) 549-3800
(Mon-Thurs)
STATE OF CALIFORNIA—CALIFORNIA STATE TRANSPORTATION AGENCY EDMUND G. BROWN ir. Governor
DEPARTMENT OF TRANSPORTATION
50 HIGUERA STREET
SAN LUIS OBISPO, CA 93401-5415
PHONE (805) 549-3101
FAX (805) 549-3329
TTY 711
htti)://www.dot.ca.2ov/distO5/
June 28, 2017
Mr. Tyler Corey
City of San Luis Obispo Community Development
919 Palm Street
San Luis Obispo, Ca 93401
Dear Mr. Corey:
05-SLO-25.91
SCH: 2015081034
Flex your power!
Be energy efficient!
Thank you for the opportunity to review the Final Draft Environmental Impact Report (FEIR) prepared for
the Avila Ranch Development Project. Caltrans has provided comments on the Notice of Preparation
(NOP) and the Draft Environmental Impact Report (DEIR) and appreciates the continued coordination
with the City throughout the environmental review process. Caltrans supports the strategic goals of the
project of providing additional work force housing to address a jobs -housing imbalance while
incorporating Transportation Demand Measures and creative site planning that will help reduce vehicle
miles travelled and auto dependency.
After review of the response to comments provided in the FEIR, Caltrans maintains concern regarding the
disclosure of transportation impacts based on current assumptions and the technical analysis. These
concerns were identified in our September 14, 2015 letter on the NOP and January 17, 2017 letter on the
DEIR (enclosed). These issues include the following:
1. Caltrans continues to request a baseline that includes the recently completed Los Osos Valley Road
(LOVR) interchange project. Specifically, the LOVR interchange project included a ramp analysis that
identified three of the ramps would operate a Level of Service (LOS) D or LOS E in the AM peak hour
upon completion. However, the Avila Ranch project finding of LOS C (based on outdated data
collected for the NOP) is inconsistent with the more recent traffic data. Ultimately, by basing results
on conditions that no longer exist, it is unknown how the new LOVR interchange will respond to trip
loading generated by the Avila Ranch Development Project. Furthermore, in the response to comments
it was stated that a merge/diverge analysis was not needed due to the number of anticipated trips (no
more than 100 trips). Caltrans is not familiar with a 100 peak hour trip criteria that prevents disclosure
of merge/diverge impacts. Additionally, with the introduction of 720 homes, Caltrans anticipates
operational impacts at the ramps. Caltrans requests full disclosure of impacts at the LOVR interchange
based on current conditions.
2. The FEIR states that the mainline section of US 101 in the vicinity of LOVR experiences "moderate"
levels of congestion and further implies the Caltrans Guide for Preparation of Traffic Impact Studies
support the decision to not fully analyze segments along US 101. However, the Guide does not state
the analysis should be avoided based on a quantified number of trips, particularly when empirical data
shows that conditions are worse than described. Caltrans freeway operational performance data shows
demand may exceed capacity on a recurring basis during most weekday peak -hour periods. Caltrans'
2014 Transportation Concept Report shows severe congestion and longer periods of forced -flow
conditions becoming more frequent by 2040. Without clearly quantifying and disclosing the proposed
development's potential impacts to US 101 mainline operations, the full impacts to US 101 are
unknown. Thus, it is also unknown if operational improvements including such things as auxiliary
lanes, ramp metering, or other improvements would be recommended.
Provide a safe, sustainable, integrated and efficient transportation system
to enhance California's economy and livability"
Mr. Tyler Corey
June 28, 2017
Page 2
3. In the Environmental Setting portion of the FEIR the baseline assumption is made that a full
interchange will be built at the US101/Prado Road intersection. At this time, it is premature to make
that claim since the ultimate need and viability of a full interchange or overcrossing is still under study
and has yet to be fully determined. Caltrans recommends that the traffic analysis base assumptions on
current conditions. Assuming a full interchange at US 101/Prado Road in the traffic analysis
minimizes the actual impact to other existing interchanges in the corridor, including those currently
located at South Higuera Street, Los Osos Valley Road, and Madonna Road.
4. The US 101/South Higuera Street interchange and ramp operations were not analyzed as requested in
Caltrans letters on the NOP and DEIR. In the response to comments on the DEIR, it was indicated that
analysis of the US 101/South Higuera Street interchange was not needed because it was estimated that
the project would add "less than 50 peak hour trips". Through empirical data, Caltrans believes that the
project is likely to generate more than 50 peak hour trips at the US 101/South Higuera Street
interchange, and potentially even more with the anticipated extension of Buckley Road (as further
discussed below). We request US 101/South Higuera Street interchange and ramp operations be
analyzed to fully disclose the impact and determine what/if any operational improvements may be
recommended at the interchange.
5. We understand that the Avila Ranch Development Project is being conditioned with extending
Buckley Road between Vachell Lane and South Higuera Street, bifurcating a parcel owned by Caltrans
intended for the development of a new district office and maintenance facility for the Department. In
the last year we have met with both the San Luis Obispo County Public Works staff and Avila Ranch
representatives to refine an alignment connecting the Buckley Road/Vachell Lane intersection with
South Higuera Street through our property.
This Buckley Road extension is an important improvement to the local transportation network.
Caltrans is agreeable to an alignment bifurcating the parcel that provides for two travel lanes (with a
two way left turn lane) and shoulders that will accommodate automobile and bicycle travel. Caltrans
staff is actively working on steps that need to be taken in order to complete a road easement that will
be transferred directly from Caltrans to San Luis Obispo County upon their agreement and acceptance.
We hope this letter helps the City identify transportation issues associated with the State Highway System.
Our interest is to work with our local partners in helping to support sustainable development. We want to
commend both the City and developer in addressing the work -force housing and transportation needs of
the community while implementing developments that support multimodal choices and quality of life. We
also appreciate the proactive and collaborative approach the applicant and developer's representatives have
taken with this project. Please contact us at (805) 549-3800 or melissa.streder@dot.ca.gov if you wish to
discuss the comments provided.
Sincerely,
�LL�«
MELISSA STREDER
Caltrans District 5
Development Review
Enclosure: 2015 Notice of Preparation Comments and 2017 Draft Environmental Document Comments
"Provide a safe, sustainable, integrated and efficient transportation system
to enhance California's economy and livability"
STATE OF CALIFORNIA—BUSMFSS TRANSPORTATION AND HOUSING AENCY EDMUND 0. MOWN Jr.,
DEPARTMENT OF TRANSPORTATION
50 HIGUERA STREET
SAN LUIS OBISPO, CA 93401-5415
PHONE (805) 549-3101
FAX (805) 549-3329
TTY 711
http://www.dot.ca. eov.'dist05/
September 14, 2015
Mr. John Rickenbach
City of San Luis Obispo
919 Palm Street
San Luis Obispo, CA 93401
�A T
Serious drought!
Help save water!
SCH# 2015081034
05-SLO-101-025.91
COMMENTS ON THE (NOP) NOTICE OF PREPARATION FOR THE AVILA RANCH
PROJECT DRAFT ENVIRONMENTAL IMPACT REPORT
Dear Mr. Rickenbach:
Thank you for the opportunity to comment on the NOP for the Avila Ranch project. The California
Department of Transportation (Caltrans) appreciates early coordination on projects such as this.
Caltrans offers the following comments for your consideration:
1) Caltrans supports local planning efforts that are consistent with state planning priorities that
promote an integrated multimodal transportation system for interregional, regional, and local
needs.
2) To ensure the traffic study in the Draft Environmental Impact Report (DEIR) includes the
information needed to analyze the cumulative and project -specific impacts of this effort, it is
recommended that the analysis be prepared in accordance with the Department's Guide for the
Preparation of Traffic Impact Studies. Further, Caltrans is willing to review a scope of work
prior to the kickoff of the traffic study.
3) Since Caltrans is responsible for the safety, operations, and maintenance of the state
transportation system, our Level of Service (LOS) standards should be used to determine the
significance of the project's impact. Caltrans endeavors to maintain a target LOS at the
transition between LOS C and D on all state transportation facilities. Therefore, LOS D would
constitute an impact, which may be different than the city's threshold.
4) For the traffic study, we request that the analysis include the following facilities:
a. US 101 mainline
b. State Route 227 mainline
"Provide a sale, sustainable, integrated and efficient transportation system
to enhance California's econoney and livability"
Mr. John Rickenbach
Page 2
c. US 101 / S. Higuera (and ramps)
d. US 101 /Los Osos Valley Road (and ramps)
e. State Route 227 / Buckley Road
5) Caltrans is supportive of efforts to include multimodal connections both across and within the
proposed project. Caltrans encourages the city to explore options to reduce vehicular trips by
carefully planning formal connectivity between land uses types.
6) Any mitigation measures recommended on the state highway system will require an
encroachment permit from Caltrans. As part of the application process, additional studies or
analyses may be required depending on the type of work proposed.
7) Given the proximity of the project to San Luis Obispo Airport, the city should consult with the
Department's Division of Aeronautics to ensure the compatibility of land use and airport
operations.
8) Caltrans owns property between Vachell Lane and S. Higuera Street. It is the long-term goal of
the Department to develop theproperty to accommodate its future office needs and maintenance
operations. To facilitate these needs, Caltrans is working with San Luis Obispo County to grant
an easement for the extension of Buckley Road to S. Higuera Street. While there may be utility
of this extension for the Avila Ranch project, Caltrans is pursuing this road extension
irrespective of the benefits that it may provide to adjacent development including the Avila
Ranch project.
If you have any questions or concerns, please contact me at (805) 549-3131 or
adain.fiikushima@dot.ca.gov.
Sincerely,
MadI Mi
�%��.�---
Adam Fukushima, PTP
Caltrans District 5
Development Review
"Provide a safe, sustainable, integrated and efficient transportation system
to enhance California's economy and livability"
STATE OF CALIFORNIA—CALIFORNIA STATETRANSPORTATIONAGENCY EDht iNDC BROWNS
DEPARTMENT OF TRANSPORTATION
50 HIGUERA STREET
SAN LUIS OBISPO, CA 93401-5415
PHONE (805) 549-3101
FAX (805) 549-3329
TTY 711
httDy✓
://ww.dotca.goy/dist05/ Flex your power!Be energy efficient!
January 17, 2017
Mr. Tyler Corey 05-SLO-25.91
City of San Luis Obispo Community Development SCH: 2015081034
919 Palm Street
San Luis Obispo, Ca 93401
Dear Mr. Corey:
Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) prepared for
the Avila Ranch Development Project. This project includes an amendment to the Airport Area Specific
Plan (AASP) and a rezoning to allow up to 720 new residential units to be built in five phases. The project
also includes 15,000 -square -feet of neighborhood commercial space that will create a town center
component. Caltrans supports the strategic project goals of providing additional work force housing to
address a jobs -housing imbalance while incorporating Transportation Demand Measures (TDM) and
creative site -planning reducing Vehicle Miles Traveled (VMT) and automobile -dependency. These
objectives are consistent with the Caltrans' Strategic Management Plan 2015-2010 and state planning
priorities.
Caltrans staff met with city Public Works staff on January 3, 2017 and discussed the following topics and
concerns:
1. It is unclear whether the Transportation Impact Study (TIS) for the Avila Ranch project used the
pre -or post -reconfiguration of the recently completed Los Osos Valley Road (LOVR) Interchange
project for establishing a baseline condition. The summary (pages 3.12-3 and 3.12-5) indicates the
LOVR Interchange evaluation of existing conditions was based on the pre -reconfigured condition.
However, that assumption does not appear consistent with the analysis in the Technical Appendix
P. Additionally, the Avila Ranch TIS did not include the ramp merge/diverge analysis, which was
included in the LOVR interchange project analysis. The latter indicates three of the ramps will
operate at level of service (LOS) D or LOS E in the AM peak hour. This finding is inconsistent
with the LOS C statement in the Avila Ranch DEIR. Potential inconsistencies with regard to
existing conditions at this location, as well as CEQA-level analysis conducted for the LOVR
Interchange, should be revisited prior to the release of the FEIR.
2. In the Environmental Setting portion of the DEIR, it is stated that the mainline section of US 101
in the vicinity of Los Osos Valley Road experiences moderate levels of congestion. However,
empirical data shows conditions are worse than described. Currently, demand is exceeding
capacity at this location daily during most weekday peak -hour periods. Caltrans' 2014
Transportation Concept Report shows severe congestion and longer periods of forced -flow
conditions becoming more frequent by 2040. The analysis should clearly quantify and disclose the
proposed development's potential impacts to US 101 mainline operations.
3. In the Environmental Setting portion of the DEIR, the baseline assumption is made that a full
interchange will be built at the Prado Road/US 101 intersection. Please note the ultimate need and
viability of a full interchange or overerossing is still under evaluation, and has yet to be fully
determined.
"Provide a sale, sustainable, integrated and efficient transportation systent to enhance California's economy and livability"
Mr. Tyler Corey
January 17, 2017
Page 2
4. It does not appear that the US 101/South Higaera Street interchange and ramp operations were
analyzed as advised in Caltrans' Notice of Preparation comments, dated September 14, 2015
(enclosed). Additionally, the impacts to mainline SR 227 were not sufficiently considered in the
project analysis. Please note that SLOCOG's recently completed 2016 SR227 Operations Study
identified deficiencies and strategies for improving this important transportation link to the city.
While specific improvement packages for the corridor have yet to be determined, it will be
important for this development and others to contribute fair share mitigation fees prior to
occupancy. As indicated on page 3.12-34, it is essential for the AASP Public Facilities Financing
Plan to evaluate and collect fees for future SR 227 improvements.
5. (Public Services -Schools) - Demand for new enrollment at the closest elementary school to this
development, Los Ranchos Elementary, would likely generate significant new AM peak hour
demand at the SR227Buckley Road intersection. Likewise, the transportation impacts of peak -
hour school trips for Laguna Middle School and San Luis Obispo High School would also increase
at certain locations. It is unclear whether school-based AM peak -hour trips were sufficiently
factored into the trip distribution and traffic analysis for this development. The table on page 3.11-
3 indicates a less than significant impact on the school facilities, but does not address the related
traffic impacts of school -trip vehicles originating from the Avila Ranch and the impact of these
trips on key transportation nodes such as SR227Buckley Road, and the LOVR interchange. We
suggest completing these analyses before releasing the FEIR. Further, we hope the city and
applicant will consider exploring possible TDM measures such as participating financially in a
school bus transportation program or other transit program.
6. (Hydrology and Water Quality) - The document shows a flood plain delineation differing from the
FEMA map. This is important as both the Avila Ranch property and the adjacent downstream
Caltrans property are within the same designated 100 -year flood plain. The Avila Ranch project, in
addition to the Buckley Road extension, may have implications for the development potential of
the Caltrans' property. The potential inconsistency in flood plain delineation must be addressed at
the earliest opportunity and prior to the adoption of a Buckley Road alignment.
(Off Site Project Improvements) - The transportation mitigation for phase two of the development
identifies the Buckley Road extension and a parallel Class 1 bicycle path through the Caltrans
parcel immediately west of the development. We were surprised by the inclusion of this feature in
the DEIR. In meetings, as recent as summer 2016, with the developer's representative, our
understanding was that other options for routing the Class 1 facility would be developed. Caltrans
purchased this parcel some years ago for the purpose of developing a new District office and
maintenance facility. In the last year, we have met with both the county Public Works staff and
Avila Ranch representatives to refine an alignment connecting the Buckley Road/Vachell Lane
intersection with South Higuera Street. This is an important improvement to the local
transportation network that should move forward either with or without the Avila Ranch
development.
Caltrans is generally agreeable to an alignment concept bifurcating the parcel, encompassing
sufficient width to accommodate a 12 -foot -travel -lane and eight -foot shoulder in each direction,
and the inclusion of a 14 -foot -wide, two-way, left -turn lane to accommodate the movement of
'Provide a safe, sustainable, integrated and efficient transportation system to enhance California's economy and livability"
Mr. Tyler Corey
January 17, 2017
Page 3
large combination vehicles. Further, county public works staff concurs with this geometric concept
with the understanding that this road extension will likely become part of the county road system
Caltrans recently made an agreement with the San Luis Obispo Land Conservancy that allows for
a temporary use of a large portion of the parcel that will facilitate the development of the Octagon
Barn/Bob Jones trail complex, an essential element to the city's bicycle and pedestrian network.
However, because the plans for the Caltrans' facilities are conceptual only, it remains unknown
how the impacts of hydrology and cumulative right-of-way demands would affect the property's
development potential.
Additionally, we have concerns about possible bicycle and pedestrian conflicts induced by a Class
1 facility that intersects a busy maintenance yard driveway. Large truck and trailer vehicles will be
entering and exiting the Caltrans maintenance yard daily. Our interest is in developing an
alignment and roadway design that accommodates all users in a safe and efficient manner. Please
explore other options to route a Class 1 facility that will offer a safer, higher -quality user
experience for bicyclists and pedestrians. We welcome the opportunity to meet with the city and
developer representatives to further explore these options. Ultimately, because of the need to
ensure the long-term viability of the parcel, details regarding the specific alignment, width and
geometry of the road extension must be resolved prior to any construction.
We hope this letter helps your agency better identify transportation issues associated with the State
Highway System. Our interest is to work with our local partners in helping to support sustainable
development. We want to commend both the city and developer in addressing the work -force housing and
transportation needs of the community while implementing developments that support multimodal choices
and improved quality of life. We also appreciate the pro -active and collaborative approach the applicant
and developer's representatives have taken with this project. If you have any questions, please contact me
at 805-549-3103 or larrv.newland(&dot.ca.eov.
Sincerely,
LA*-RENCE C. NEWLAND, AICP
Planning Branch Chief, South
Enclosure: 2015 Notice of Preparation Comments
"Provide a safe, sustainable, integrated and efficient transportation system to enhance California's economy and livability"